Pay-to-Play 2: CFIUS Filing Fees Go Into Effect May 1, 2020
Client Alert | 1 min read | 04.28.20
The Committee on Foreign Investment in the US (CFIUS) has announced an Interim Final Rule requiring payment of filing fees in connection with any Joint Voluntary Notices submitted on or after May 1, 2020 for “covered transactions” under 31 C.F.R. Part 800 or for “covered real estate transactions” under Part 802. The Interim Final Rule adopts, without change, the sliding scale fee structure as initially proposed, but in light of the COVID-19 pandemic, will continue to accept comments until June 1, 2020.
The fee schedule is:
Total Transaction Value |
Filing Fee |
|
< $500,000 |
$0 |
|
> $500,000 but < $5 million |
$750 |
|
> $5 million but < $50 million |
$7,500 |
|
> $50 million but < $250 million |
$75,000 |
|
> $250 million but < $750 million |
$150,000 |
|
> $ 750 million |
$300,000 |
CFIUS rejected comments seeking to limit the transaction value to just the value of the U.S. business and denied concerns that the lack of any fee for submission of mandatory or voluntary declarations would provide a financial or administrative incentive for CFIUS to fail to conclude action under Section 721 of the Defense Production Act in evaluating such declarations.
Contacts
Insights
Client Alert | 3 min read | 01.26.26
8(a) Participants – and the 8(a) Program – Under the Microscope or on the Chopping Block
The Small Business Administration (SBA) has rolled out changes to its 8(a) Program even as it suspends 8(a) participants for failure to respond to the SBA’s December 5, 2025 8(a) audit letters.
Client Alert | 3 min read | 01.21.26
Atlantic Biologicals Opioid DPA: DOJ Continues Ramp Up of Criminal Corporate Healthcare Enforcement
Client Alert | 3 min read | 01.21.26
FedRAMP Proposes Updates to Authorization Process—Six New RFCs Released for Public Comment
Client Alert | 3 min read | 01.20.26
DoW Joins SBA’s Fight Against Alleged Pass-Through Fraud in the 8(a) Program

