2503010 Informal Interpretation

us-ftc-hsr-informal-interpretations-bbe6ae7d6dad5500aa1916b0990f4b492503010 Informal InterpretationGuidance

Date
Rule
New HSR Form - Supervisory Deal Team
Staff
Kristin Shaffer
Response/Comments

Please see the Statement of Basis and Purpose, 89 Fed. Reg. 89,216 at 89,279 (Nov. 12, 2024): “In the situation where the only individuals supervising the strategic assessment of the deal are already either an officer or director, filers can state that this is the case and identify an officer or director as the supervisory deal team lead.”

Question

From: Shaffer, Kristin
Sent: Friday, March 7, 2025 11:04:54 AM (UTC-05:00) Eastern Time (US & Canada)
To: [Redacted]
Cc: HSRHelp
Subject: RE: Supervisory Deal Team Lead

Please see the Statement of Basis and Purpose, 89 Fed. Reg. 89,216 at 89,279 (Nov. 12, 2024): “In the situation where the only individuals supervising the strategic assessment of the deal are already either an officer or director, filers can state that this is the case and identify an officer or director as the supervisory deal team lead.”
Best regards,
Kristin

From: [Redacted]
Sent: Friday, March 7, 2025 10:26 AM
To: HSRHelp
Subject: Supervisory Deal Team Lead

Hello,
I have a question about the Supervisory Deal Team Lead (SDTL). What are the search and filing obligations if the person primarily responsible for supervising the strategic assessment of the transaction is an officer of the filing person? They would fall outside the definition of an SDTL and their documents would already be potentially responsive. Must an SDTL be named in every filing? If so, how would that be possible in the scenario described?
Thanks in advance.

Sheinberg, Samuel I.
From: 	HSRHelp
Sent: 	Friday, March 7, 2025 11:05 AM
To: 	HSR Auto Forward List
Subject: 	FW: Supervisory Deal Team Lead
From: Shaffer, Kristin
Sent: Friday, March 7, 2025 11:04:54 AM (UTC-05:00) Eastern Time (US & Canada)
To:
Cc: HSRHelp
Subject: RE: Supervisory Deal Team Lead
Please see the Statement of Basis and Purpose, 89 Fed. Reg. 89,216 at 89,279 (Nov. 12, 2024): “In the situation where
the only individuals supervising the strategic assessment of the deal are already either an officer or director, filers can
state that this is the case and identify an officer or director as the supervisory deal team lead.”
Best regards,
Kristin
From:
Sent: Friday, March 7, 2025 10:26 AM
To: HSRHelp
Subject: Supervisory Deal Team Lead
Hello,
I have a question about the Supervisory Deal Team Lead (SDTL). What are the search and filing obligations if the person
primarily responsible for supervising the strategic assessment of the transaction is an officer of the filing person? They
would fall outside the definition of an SDTL and their documents would already be potentially responsive. Must an SDTL
be named in every filing? If so, how would that be possible in the scenario described?
Thanks in advance.
Best,
.
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Complete printed PDF page 1
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Complete printed PDF page 2

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