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1906013 Informal Interpretation
us-ftc-hsr-informal-interpretations-c40a87c43f792eb33db4ceb2e5ec98cf1906013 Informal InterpretationGuidance
Date
Rule
Item 5, Item 7
Response/Comments
You are correct about the non-manufacturing codes. There is no de minimus threshold for manufacturing codes. Remember, you still have to report any overlaps in item 7. It is helpful in our review to see all item 5 overlaps, even if these amounts are less than $1 million.
Question
[Redacted]
You are correct about the non-manufacturing codes. There is no de minimus threshold for manufacturing codes. Remember, you still have to report any overlaps in item 7. It is helpful in our review to see all item 5 overlaps, even if these amounts are less than $1 million.
Sam
From: [Redacted]
Sent: Friday, June 14, 2019 1:49:32 PM (UTC-05:00) Eastern Time (US & Canada)
To: [Redacted]
Subject: Item 5 Question
Dear PNO,
The instructions for Item 5(a) indicate that “If the dollar revenues for a non-manufacturing NAICS code totaled less than one million dollars in the most recent year, that code may be omitted from Item 5(a).” I’m curious if that suggests there is no de minimus threshold for reporting manufacturing NAICS codes? In other words, and dollar value at all for manufacturing NAICS codes must be reported. Thanks.
1 Sheinberg, Samuel I. From: Sheinberg, Samuel I. Sent: Friday, June 14, 2019 4:39 PM To: Cc: Subject: RE: Item 5 Question You are correct about the non‐manufacturing codes. There is no de minimus threshold for manufacturing codes. Remember, you still have to report any overlaps in item 7. It is helpful in our review to see all item 5 overlaps, even if these amounts are less than $1 million. Sam From: Sent: Friday, June 14, 2019 1:49:32 PM (UTC-05:00) Eastern Time (US & Canada) To: Subject: Item 5 Question Dear PNO, The instructions for Item 5(a) indicate that “If the dollar revenues for a non‐manufacturing NAICS code totaled less than one million dollars in the most recent year, that code may be omitted from Item 5(a).” I’m curious if that suggests there is no de minimus threshold for reporting manufacturing NAICS codes? In other words, and dollar value at all for manufacturing NAICS codes must be reported. Thanks.
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