Control no longer controlling for HSR reporting of not-for-profit combinations
By: Premerger Notification Office Staff | Oct 26, 2018 2:37PM
The PNO routinely provides informal guidance on Hart-Scott-Rodino reporting obligations that arise when combining not-for-profit entities, typically in the context of hospital combinations. In the past, much of this guidance focused on whether the combination resulted in a change of "control" of the board of directors of one or more of the combining entities. This was because those seeking guidance described hospital combinations primarily in terms of formal board governance.
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