U.S. Court of Appeals for the Fifth Circuit

government

Last mentioned: Mar 20, 2026

Timeline

  1. FTC Guidance Issued

    The FTC confirms it will accept legacy forms while its appeal proceeds.

  2. Fifth Circuit Denial

    The appellate court denies the FTC's stay request, reinstating the old filing regime.

  3. District Court Vacatur

    A lower court finds the new HSR rules improperly promulgated and vacates them.

  4. New HSR Rules Effective

    The FTC's expanded premerger notification requirements officially take effect.

Stories mentioning U.S. Court of Appeals for the Fifth Circuit 1

regulation Neutral

Fifth Circuit Reinstates Legacy HSR Rules, Easing M&A Burdens for Startups

The U.S. Court of Appeals for the Fifth Circuit has denied the FTC's request to stay a lower court ruling, effectively suspending the rigorous 2025 HSR filing requirements. This decision provides immediate relief to dealmakers by reverting to the less-burdensome pre-2025 disclosure framework while the legal battle continues.

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