2001005 Informal Interpretation

Date:

Tags:

Rule:
801.1, 803.9
Staff:
Karen Berg
Response/Comments:

These sound like separate, unrelated filings, so even though they may have similar responses, each must have its own form and attachments.

Question

From: Berg, Karen E.


Sent: Friday, January 3, 2020 11:01:10 AM (UTC-05:00) Eastern Time (US & Canada)


To: [Redacted]


Cc: HSRHelp


Subject: RE: Two Acquired Person Filings on Same Form

[Redacted]

These sound like separate, unrelated filings, so even though they may have similar responses, each must have its own form and attachments.

Thanks,

Karen

From: [Redacted]


Sent: Friday, January 3, 2020 10:30:19 AM (UTC-05:00) Eastern Time (US & Canada)


To: HSRHelp


Subject: Two Acquired Person Filings on Same Form

Good morning,

I have a quick question about how we need to file a transaction. Two related funds are buying voting securities of the acquired person (our client). The names of the acquiring person and acquired entities are different, but everything else in the acquired person filings will be the same (amount and percentage of voting securities to be acquired, Item 4(c)/4(d) docs, Item 5, etc.). Can we file on a single Form and provide one set of Attachments? We could easily provide four copies of the Form instead of the usual two, but I’m hoping to eliminate the need to print multiple sets of Attachments.

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Informal interpretations provide guidance from previous staff interpretations on the applicability of the HSR rules to specific fact situations. You should not rely on them as a substitute for reading the Act and the Rules themselves. These materials do not, and are not intended to, constitute legal advice.

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