June 25, 2012
HSR Filings Increased 24% in 2011; FTC Continues Go After D&O’s Acquisitions of Stock
As noted in this Perkins Coie memo, the FTC and DOJ recently published their HSR Annual Report Fiscal Year 2011. The number of HSR filings in fiscal 2011 increased by 24% over the number of filings in 2010 – and the agencies continue to enforce the HSR Act’s notification requirements with respect to acquisitions of company stock by corporate officers and directors, often in an inadvertent “failure to file” situation.