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Response to FTC Proposal to Aggregate Acquisitions for HSR Filings

We responded to an FTC proposal to redefine “person” under Hart-Scott Rodino premerger notification rules to include “associates.” Investment managers would need to aggregate acquisitions in an issuer across all clients to determine if the manager reaches the filing threshold. We argue that aggregation would harm investors and severely impact an adviser’s ability to meet its fiduciary duty, and that the proposal reflects a fundamental misunderstanding of how advisers treat their separate clients.

February 01, 2021

Keywords: Federal Trade Commission, Hart-Scott-Rodino Proposal on Aggregation, Registered Funds

Categories & Topics: Business Ops/HR, Industry Trends, Industry-Level, Registered Funds

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