Individuals whose stock ownership exceeds certain thresholds can be required to file reports with the FTC and the DOJ. Learn more about how these rules apply to stock compensation.
The memo by Morrison & Foerster summarizes the new HSR Act filing thresholds for 2020.
The memo by Morrison & Foerster summarizes the new HSR Act filing thresholds for 2019.
On January 26, 2018, the FTC announced the adjusted HSR Act notification thresholds for 2018. The new thresholds will become effective on February 28, 2018.
Common equity-based compensation-related transactions, such as restricted stock grants, settlement of
restricted stock units (RSUs), exchange of operating partnership units (OP units) and option exercises, may
trigger filing obligations under the Hart-Scott-Rodino Antitrust Improvements Act (HSR Act) for executives of
REITs or other companies who own significant amounts of their company’s stock. Executives should be aware
of how these filing requirements may apply to them, as filing fees are not insignificant ($45,000 or more) and
failing to make a required filing can bring about stiff consequences, including fines of up to $40,000 per day, a
governmental inquiry, and potential embarrassment.
The Federal Trade Commission obtained a $250,000 civil penalty against James Dondero, the operator of the Highland Capital hedge fund and a director of Motient Corporation, for making a late Hart-Scott-Rodino Act filing in connection with his 2005 exercise of options to acquire 10,000 Motient shares.
Failure to comply with the Hart-Scott-Rodino Act can be a $40,000 per day mistake. Read this blog entry to learn more about the HSR Act and find out what the filing thresholds are for 2020.
Failure to comply with the Hart-Scott-Rodino Act can be a $40,000 per day mistake. Read this blog entry to learn more about the HSR Act and find out what the filing thresholds are for 2019.
The FTC has announced the new Hart-Scott-Rodino Act thresholds, which will go into effect on February 28, 2018.
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