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Date
Rule
New HSR Form - Supervisory Deal Team
Staff
Kristin Shaffer
Response/Comments

Please see the Statement of Basis and Purpose, 89 Fed. Reg. 89,216 at 89,279 (Nov. 12, 2024): “In the situation where the only individuals supervising the strategic assessment of the deal are already either an officer or director, filers can state that this is the case and identify an officer or director as the supervisory deal team lead.”

Question

From: Shaffer, Kristin 
Sent: Friday, March 7, 2025 11:04:54 AM (UTC-05:00) Eastern Time (US & Canada)
To: [Redacted] 
Cc: HSRHelp 
Subject: RE: Supervisory Deal Team Lead
 
Please see the Statement of Basis and Purpose, 89 Fed. Reg. 89,216 at 89,279 (Nov. 12, 2024): “In the situation where the only individuals supervising the strategic assessment of the deal are already either an officer or director, filers can state that this is the case and identify an officer or director as the supervisory deal team lead.”
Best regards,
Kristin

From: [Redacted]
Sent: Friday, March 7, 2025 10:26 AM
To: HSRHelp 
Subject: Supervisory Deal Team Lead
 

Hello,
I have a question about the Supervisory Deal Team Lead (SDTL). What are the search and filing obligations if the person primarily responsible for supervising the strategic assessment of the transaction is an officer of the filing person? They would fall outside the definition of an SDTL and their documents would already be potentially responsive. Must an SDTL be named in every filing? If so, how would that be possible in the scenario described?
Thanks in advance.

 

About Informal Interpretations

Informal interpretations provide guidance from PNO staff on the applicability of the HSR rules to specific fact situations. They do not necessarily reflect the position of the Commission. 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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