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Date

Tags:

Rule
801.30; 803.5
Staff
Kate Walsh
Response/Comments

The word “executed” is not necessary in the buyer’s affidavit in an 801.30 filing. 

Question

From: Walsh, Kathryn E.
Sent: Thursday, May 05, 2016 11:41 AM
To: [REDACTED]
Subject: RE: Your HSR Filing [REDACTED]

[REDACTED]:

We agree that “executed” is not necessary in the buyer’s affidavit in an 801.30 filing.  In fact, there is really no reason for the buyer to mention any agreement(s) in its affidavit for an 801.30 transaction – reference to an agreement is not required, and may cause confusion about whether the transaction is actually an 801.30 or not.  Of course, the buyer should discuss the agreement(s) in Item 3(a) and submit any agreement(s) with the filing.

Kate

From: [REDACTED]
Sent: Wednesday, May 04, 2016 11:55 AM
To: 'Walsh, Kathryn E.'
Subject: RE: Your HSR Filing

Kate:

In an 801.30 transaction based on shareholder agreements, I wasn’t clear what is required in the buyer’s affidavit.  Do I need to say “executed” agreements? 

Many thanks,

[REDACTED]

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Informal interpretations provide guidance from previous staff interpretations on the applicability of the HSR rules to specific fact situations. You should not rely on them as a substitute for reading the Act and the Rules themselves. These materials do not, and are not intended to, constitute legal advice.

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