Informal Interpretations

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.

Learn more about Informal Interpretations.

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1901001 Informal Interpretation

Staff:
Timothy Carson
Rule:
801.1, 801.10

Response/Comments

The facts shared in your email do not necessarily demonstrate that Investor A is instrumental. If investigated, the agency would look at the totality of the circumstances, so Investor A will need to...

1811007 Informal Interpretation

Staff:
Nora Whitehead
Rule:
801.2

Response/Comments

It is our preference that you use two forms. This usually reduces confusion both in the front office and with the attorney review, and we see fewer filing errors this way. Of course, less confusion...

1811003 Informal Interpretation

Staff:
Robert Jones
Rule:
801.1(a)(2), 803.3, 803.4

Response/Comments

The UPE has an obligation to comply with the Act. Rule 803.4 only applies to acquired persons and 803.3 only applies when the UPE is unable to provide a response, not when the UPE is unwilling to do...

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