So, you may have noticed that it’s been rather awhile, but I’m going to try to get back into the swing of the whole blogging thing again, so let’s look around and see what’s new.
Oh, there’s something. It’s super exciting, guys. I know you’re going to love it. The FTC’s got some new HSR rules, y’all.
Okay, so that’s not really all that exciting for you, but hey, those of us who prepare HSR notifications for a living have to pay attention to this stuff.
One thing that sometimes surprises clients is that HSR notifications are printed out on physical paper for filing. That’s right, you email us documents (or send them on a some sort of removable media), we take a look at them and then print them out, single-sided and generally in black and white, and pass them on to DOJ and the FTC. All those pretty images you added to the board presentation? Nope. Gray scale. All the fancy formulas in your synergies spreadsheet? Nope. Flat paper.
There actually used to be a way to file electronically, by uploading materials directly to the FTC, but I honestly never even looked how that was supposed to work. No one used it and (I learned from reading the notice), it was actually discontinued (I thought it was still active).
Anyway, it’s all moot now as the FTC has sprung into the technology of the late 1990s! You can now submit your HSR notification on a DVD.
Sounds like a pretty obvious development to adopt, right? While I’ve never worked in intake at either agency, you have to image that handling a bunch of paper isn’t particularly efficient on their end either. You’d assume they immediately scan whatever they get for ease of storage, sharing and usage. Except that apparently is wrong as they still want multiple copies of the DVD (how does that make any sense) and multiple copies of paper cover letters. Okay. Whatever.
Anyway, it brings to mind the time I accidently sent one of my personal James Bond DVDs back in the a Netflix envelope. Let’s hope no one accidentally tries to file their vacation video. Or worse.