“Changes Good and Bad Coming to HSR Compliance”
Compliance Week, November 2, 2010
Jon Dubrow addressed a proposed revision to FTC pre-merger notification rules, which would require identifying and collecting data from “associates” – entities that are under common management with, but not control of, the acquiring party. Mr. Dubrow urged acquiring companies to start early on the difficult process of defining who their associates are and what data they will need from them for merger approval. “This will be burdensome to those transactions that raise no legitimate competitive issues,” he said of such new required documentation.