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Email In a recent blog post, the Acting Director of the Federal Trade Commission Bureau of Competition announced the reversal of the Federal Trade Commission’s (“FTC”) decades-long position regarding the treatment of debt repayment when determining whether a premerger notification filing under the Hart-Scott-Rodino (“HSR”) Act is required. Effective September 27, 2021, companies and individuals that do not file HSR based on excluding retired debt from the transaction value may face enforcement action. https://www.cadwalader.com/resources/clients-friends-memos/one-two-punch-ftc-does-about-face-on-treatment-of-debt-for-hsr-purposes-and-casts-doubt-on-informal-interpretation-program