HSR Early Terminations Granted per Month (FTC)

## What this measures

How many transactions the FTC and DOJ allowed to close before the end of the 30-day HSR waiting period in the month: the early termination notices the FTC publishes, dated by the date granted.

## Why it matters

Early termination is granted to deals with no competitive issues, at the parties' request, so in normal times the count tracks the flow of routine, sizeable deals within weeks. It is also a record of antitrust policy: the agencies all but stopped granting it for four years.

## How to read it

Higher means more deals cleared early. The program was suspended from February 2021 and resumed after the new HSR form took effect on 10 February 2025: the zeros in between are the policy, not a lack of deals (the FTC lists a handful of notices granted during the pause, in 2021 and 2024). Shorter pauses, such as the two weeks from mid-March 2020 and the government shutdowns of January 2019 and October to mid-November 2025, show as dips that are policy, not demand.

## What it does not say

Early termination is discretionary and requested by the parties, so the count depends on agency policy as much as on deal flow, and it covers only deals that asked for it and raised no concerns. The FTC publishes the parties but not deal values. It is not a count of all HSR filings (hsr.us.transactions.monthly).

## How it's built

Palanor reads the FTC's early termination notices (the FTC API at api.ftc.gov, with the legal-library list at ftc.gov as the fallback) every day and counts notices by the date granted, one per transaction number, from January 2014. The FTC's list is less complete for earlier years: for fiscal years 2001 to 2013 it holds 14 to 42 percent fewer notices than the early terminations the annual HSR reports count as granted, against a gap of 7 percent or less either way since fiscal 2014, so earlier years are left out. The current month is left out until it ends.

## Source

Federal Trade Commission, Early Termination Notices (ftc.gov/legal-library/browse/early-termination-notices; also api.ftc.gov/v0/hsr-early-termination-notices). Public domain: "Most material on the FTC's website is considered work of the United States Government, meaning that the material is in the public domain and is not subject to copyright restrictions (17 U.S.C. 105)" (FTC website policy). Source: United States Federal Trade Commission, www.ftc.gov.