August 2, 2021

Volume XI, Number 214

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July 30, 2021

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Hart-Scott-Rodino Reporting Thresholds Adjusted Downward

The Federal Trade Commission recently announced new reporting thresholds for the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (“Act”). The new thresholds became effective on March 4, 2021. Unlike previous years, this year, the threshold levels have been decreased instead of increased. The minimum size-of-transaction threshold went down to $92 million from the 2020 threshold of $94 million. As a result of that change, transactions valued below $92 million (as of the time of closing) will not be reportable. The size-of-parties thresholds also decreased from the 2020 values of $18.8 million and $188 million to now $18.4 million and $184 million, respectively, and transactions valued in excess of $919.9 million (down from $ 942 million) are reportable regardless of the size of the parties. In contrast, the civil penalties for violations of the Act increased to a maximum of $43,792 (up from $43,280) per day, effective January 13, 2021.

©2021 Epstein Becker & Green, P.C. All rights reserved.National Law Review, Volume XI, Number 70
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About this Author

John Steren, Epstein Becker Law Firm, Health Care Litigation Attorney
Member

E. John Steren is a Member of the Firm in the Health Care & Life Sciences and Litigation & Business Disputes practices, in the Washington, DC, office of Epstein Becker Green. Mr. Steren devotes a significant portion of his practice to helping health care organizations manage the antitrust risks of joint ventures and other business arrangements. He also focuses his practice on other complex commercial and civil litigation matters.

202-861-1825
Patricia M. Wagner, Epstein becker green, health care, life sciences
Member

PATRICIA M. WAGNER is a Member of the Firm in the Health Care and Life Sciences and Litigation practices, in the firm's Washington, DC, office. In 2014, Ms. Wagner was selected to the Washington DC Super Lawyers list in the area of Health Care.

Ms. Wagner's experience includes the following:

Advising clients on a variety of matters related to federal and state antitrust issues 

Representing clients in antitrust matters in front of the Federal Trade Commission and the United States Department of...

202-861-4182
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