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Date
Rule
801.2
Staff
Sam Sheinberg
Response/Comments

You can indicate in Item 1(a) or in an endnote that the UPE is a husband and wife. Yes, one can certify on behalf of both.

Question

From: Sheinberg, Samuel I. 
Sent: Monday, September 16, 2024 10:52 AM
To: [Redacted]
Cc: HSRHelp <HSRHelp@ftc.gov>
Subject: RE: HSR Form / Question about Listing Spouses as UPE

You can indicate in item 1(a) or in an endnote that the UPE is a husband and wife. Yes, one can certify on behalf of both.

From: [Redacted]
Sent: Monday, September 16, 2024 9:45:21 AM (UTC-05:00) Eastern Time (US & Canada)
To: HSRHelp <HSRHelp@ftc.gov>
Subject: HSR Form / Question about Listing Spouses as UPE

Hi:

In a sale of voting securities, the UPE for an Acquired Person is a husband and wife, who each own 50% of the voting securities. Thus, each is individually a UPE and, through aggregation are each the owner of 100% of the voting securities. How should the spouses be listed in item 1(a)? Can one of them certify the filing on behalf of himself or herself and the spouse?

About Informal Interpretations

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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