Antitrust partner Zak Goodwin joined the American Bar Association Antitrust Law Section’s weekly podcast, Our Curious Amalgam, to discuss how the new Hart-Scott-Rodino premerger notification form and rules, which were implemented in February 2025, are affecting deal planning and filings in practice.
Drawing on experience across a broad range of transactions, Zak highlighted key takeaways for practitioners and in-house teams. “The expanded disclosures can, in some cases, reduce the need for short-form inquiries or voluntary access letters,” Zak explained, noting that clearer overlap descriptions and ordinary-course documents now included in filings may allow agencies to resolve questions without outreach.
He also cautioned that compiling vertical supply data remains a heavy lift for complex organizations with disparate systems, while the new supervisory deal team lead custodian has been “manageable in most matters.” Early preparation - especially mapping data sources, identifying custodians, and inventorying ordinary-course materials - “pays dividends,” he said.
On timing, Zak observed that preparation periods “vary widely” by complexity, with 20 business days now common for many filings.
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