Second Requests Settle In: HSR Data Points to a New Normal in M&A Scrutiny
While HSR filing volumes are recovering from their 2023 lows, the real story is the intensity of review. New FY 2024 data reveals that Second Request rates have rebounded to 3.0%—effectively double the rate seen during the pandemic deal boom. For eDiscovery professionals, this signals that the “new normal” isn’t about volume; it’s about the collision of high scrutiny and billion-dollar deal complexity.
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