HSR Second Requests per Year (In-Depth Merger Investigations)

## What this measures

The number of merger investigations in which the FTC or the DOJ Antitrust Division issued a second request in the fiscal year, from Appendix A of the annual report. A second request extends the waiting period and asks the parties for a large volume of documents and data.

## Why it matters

Second requests are where antitrust enforcement bites: they add months and millions of dollars to a deal and often end in a lawsuit, a settlement with divestitures or an abandoned deal. Their number reflects both deal volume and enforcement intensity.

## How to read it

Higher means more deals face in-depth review. Compare it with transactions reported (hsr.us.transactions.annual): the share facing a second request is a gauge of enforcement intensity.

## What it does not say

Counts depend on the filing thresholds: on 1 February 2001 the size-of-transaction threshold rose from $15 million to $50 million, which removed many small deals, and since 2005 the thresholds have been adjusted every year for growth in gross national product. Reports are published about a year after the fiscal year ends. A filing is not a completed deal: some are abandoned, and some reported transactions are exempt or found not to be reportable.

## How it's built

Palanor reads each annual report's tables from the published PDF: Appendix A (ten fiscal years of transactions reported, second requests and early termination), Appendix B Table 1 (transactions reported by month) and Exhibit A Table I (the report year's transactions by size). Every fiscal year appears in up to ten reports; the value is taken from the newest report that covers it, because reports restate earlier years. Across the reports from fiscal 1999 to 2025, values for the same year agree, apart from a handful of small restatements. Fiscal years run October to September and are dated at their last day. A weekly job checks the FTC page for a new report. Second requests are counted by the date issued, not the date the investigation opened.

## Source

Federal Trade Commission and Department of Justice Antitrust Division, Hart-Scott-Rodino Annual Reports to Congress (ftc.gov/policy/reports/annual-competition-reports), Appendix A, Appendix B and Exhibit A. 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.