高铁更新：第五次电路行动恢复了之前的高铁规则和表格

US – March 2026 On March 19, 2026, the US Court of Appealsfor the Fifth Circuit denied the FTC’s motionfor a stay pending appeal inChamber of Commerce v. FTC, allowing the district court’sdecision vacating the FTC’s 2024 overhaul of Practical Guidance For near-term filings, parties should generally consider usingthe prior form to reduce upfront burden. The new form maystill be appropriate where parties wish to provide additionaldetail upfront to potentially streamline review. Parties should We will continue to monitor developments and are availableto discuss filing strategy for upcoming transactions. The vacated rule had significantly expanded filing requirements,including new narrative disclosures and broader documentproduction obligations. The district court held that the FTCexceeded its statutory authority in adopting key aspects of the Contacts Christopher GordonPartner, Washington DCT +1 202 626 6284E christopher.gordon@squirepb.com The FTC’s Premerger Notification Office has announced thatit is immediately accepting filings using the pre-February 10,2025, form and instructions and will make those materialsavailable shortly. The agency will also continue to accept Michael WisePartner, Washington DCT +1 202 457 5239E michael.wise@squirepb.com Practical Implications Mary WalserOf Counsel, Washington DCT +1 202 457 5249E mary.walser@squirepb.com •The prior HSR form is reinstated and governs current filings.•Parties may optionally use the 2025 form.