FTC Announces New HSR and Section 8 Thresholds
Client Alert | 1 min read | 02.19.19
On Friday, the Federal Trade Commission announced that it will increase the jurisdictional thresholds applicable to both the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (the HSR Act) and Section 8 of the Clayton Act. These dollar thresholds are indexed annually based on changes in the U.S. gross national product.
The HSR Act requires that certain large transactions be notified prior to their consummation. This year, the minimum "size-of-transaction" threshold for reporting mergers and acquisitions will increase from $84.4 million to $90 million. In addition, the "size-of-person" and filing fee thresholds will also increase. These revisions will become effective thirty days after their publication in the Federal Register, which we expect will occur shortly.
The Commission also issued revised thresholds relating to the prohibition of certain interlocking directorates under Section 8 of the Clayton Act. These revisions will take effect immediately upon their publication in the Federal Register.
Click here to read a full copy of the Commission's announcement, including all of the revised thresholds.
Contacts
Insights
Client Alert | 7 min read | 11.02.26
DOL Finalizes PBM Fee Disclosure Requirements
On October 29, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued a 350-page final rule requiring providers of pharmacy benefit management services and their affiliated brokers and consultants to disclose fees and compensation received to fiduciaries of covered large, self-insured ERISA group health plans. According to DOL’s accompanying fact sheet, the disclosures will give employers more visibility into the payments PBMs may receive from various sources and help fiduciaries evaluate and monitor arrangements over time.
Client Alert | 4 min read | 10.30.26
Client Alert | 3 min read | 10.29.26
What University Licensors Should Learn From TexasLDPC v. Broadcom
