News & Analysis as of

Reporting Requirements State Attorneys General

Skadden, Arps, Slate, Meagher & Flom LLP

Pre-Merger Notification Proliferation

What is new: Some U.S. states have enacted pre-merger notification regimes of general applicability, requiring parties making HSR filings to also notify state attorneys general, with similar legislation pending in other...more

Holland & Knight LLP

PFAS in Cosmetics: State-Led Regulatory Surge Demands Proactive Compliance

Holland & Knight LLP on

States are rapidly enacting and implementing bans and reporting requirements for per- and polyfluoroalkyl substances (PFAS) in cosmetics, creating a complex and evolving compliance environment for manufacturers, distributors,...more

Miles & Stockbridge P.C.

Colorado Becomes Second State to Enact Uniform Antitrust Premerger Notification Act

On Aug. 6, Colorado became the second state to enact the Uniform Antitrust Premerger Notification Act (APNA), following Washington earlier this year. ...more

Sheppard Mullin Richter & Hampton LLP

Privacy Compliance Insights from Connecticut’s First Privacy Law Settlement

Can we take any insights from Connecticut’s first settlement under the state’s Data Privacy Act, reached with TicketNetwork, an online ticket marketplace? The AG concerns mirrored priorities outlined in Connecticut’s 2025...more

Clark Hill PLC

Colorado and Washington’s new UAPNA reporting requirements: What M&A dealmakers need to know about these groundbreaking laws

Clark Hill PLC on

Colorado and Washington have enacted groundbreaking laws modeled after the Uniform Law Commission’s Uniform Antitrust Pre-Merger Notification Act (UAPNA), requiring parties to certain Hart-Scott-Rodino Act (HSR) reportable...more

Orrick, Herrington & Sutcliffe LLP

CFPB scraps rule allowing states to enforce the CFPA without notice

On July 21, the CFPB published a notice in the Federal Register withdrawing its direct final rule that would have rescinded procedures requiring state officials to notify the Bureau when taking action to enforce the CFPA. As...more

Morrison & Foerster LLP

True Facts About False Claims: MoFo's FCA Newsletter - July 2025

Designed for busy in-house counsel and compliance professionals, this newsletter seeks to bring you up to speed on key federal and state False Claims Act (FCA) developments, with links to primary resources. Each quarter,...more

Cozen O'Connor

Washington and Colorado Enact Uniform Premerger Notification Laws: What Businesses Need to Know About The New Era in State AG...

Cozen O'Connor on

As of July 27, Washington State is now the first state to enact a uniform antitrust premerger notification law, and as of August 6, 2025, Colorado will be the second. Both new notification laws are similar, as they are...more

Vinson & Elkins LLP

“Mini-HSR Acts” Multiply in the States; Merger Enforcement Developments in Washington, Colorado and More

Vinson & Elkins LLP on

Parties to transactions should be aware of new requirements for state-level merger reporting – so-called “mini-HSR Acts” – modeled on the Uniform Antitrust Pre-Merger Notification Act (“UAPNA”). Washington and Colorado have...more

Fenwick & West LLP

Washington Becomes First State to Enact ‘Mini HSR’ Notification Requirement

Fenwick & West LLP on

As of July 27, 2025, federal Hart-Scott-Rodino (HSR) Act filings will also need to be submitted to the Washington Attorney General (WA OAG) under Washington State’s Antitrust Premerger Notification Act (APNA) if the parties...more

Sheppard Mullin Richter & Hampton LLP

CFPB Withdraws Rule to Eliminate State Enforcement Notification Requirements

On July 21, the CFPB withdrew its plan to repeal rules that provide procedures for state officials to notify the Bureau before initiating enforcement actions under the Consumer Financial Protection Act (CFPA). The CFPB cited...more

Paul Hastings LLP

New Mini-HSR Laws Take Effect This Summer

Paul Hastings LLP on

Starting Sunday, July 27, 2025, any party to an M&A transaction that triggers a federal Hart-Scott-Rodino (HSR) Act filing must also submit a copy to the Washington attorney general if the filing party (1) maintains a...more

Miles & Stockbridge P.C.

Washington State Enacts First Uniform Antitrust Premerger Notification Act

On April 4, Washington became the first state to enact the Uniform Antitrust Premerger Notification Act (APNA). Under the APNA, a person making a Hart-Scott-Rodino (HSR) filing on or after July 27, 2025 must provide a copy of...more

Goodwin

Louisiana Enacts Law Regulating Earned Wage Access Services

Goodwin on

Louisiana has enacted a law that establishes a financial services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to access earned but unpaid income before payday....more

Orrick, Herrington & Sutcliffe LLP

CFPB to rescind state requirement to notify Bureau on CFPA enforcement

On May 21, the CFPB published a notice in the Federal Register withdrawing its procedures that required state officials to notify the Bureau when taking action to enforce the CFPA. The direct final rule, effective July 21,...more

Bass, Berry & Sims PLC

Indiana Enacts Legislation Affecting Health Care Transactions and Imposing Ownership Reporting Requirements

Bass, Berry & Sims PLC on

On May 6, 2025, Indiana Governor Mike Braun signed Indiana HB 1666 into law. This new law grants Indiana’s attorney general authority to investigate market concentration of health care entities, modifies existing requirements...more

Benesch

Updates to Reporting Requirement of Dental Support Organizations’ Mergers and Acquisitions in Indiana

Benesch on

Indiana currently has a reporting requirement related to health care entity mergers and acquisitions that requires parties to covered health care entity transactions—including Dental Support Organization (“DSO”)...more

Hogan Lovells

Indiana implements new ownership reporting requirements, authorizes health entity market concentration investigation - Proposal to...

Hogan Lovells on

On May 6, 2025, Indiana state enacted HB 1666, which modifies Indiana’s existing transaction law to exempt certain practitioner-owned practices, grants the Attorney General additional authority to investigate health care...more

McDermott Will & Schulte

Washington State Enacts Merger Review Regime

Washington is the first state to enact the Uniform Antitrust Premerger Notification Act, which requires merging parties that submit a federal filing under the Hart-Scott-Rodino (HSR) Act (15 U.S.C. Sec. 18(a)) to also submit...more

Goodwin

Washington Becomes First State to Adopt Filing Requirements for HSR-Reportable Transactions Outside of Healthcare

Goodwin on

On April 4, 2025, Washington became the first state to enact a law requiring a general pre-merger notification of HSR-reportable deals to state enforcers, regardless of industry....more

McDermott Will & Schulte

Texas Bills Would Implement Notice Requirements for Healthcare Transactions

In February 2025, Texas Representative James Frank (R) and Texas Senator Kelly Hancock (R) introduced bills to implement notification requirements for healthcare transactions. House Bill (H.B.) 2747 and Senate Bill (S.B.)...more

Cozen O'Connor

Illinois Insights: An update from Cozen O'Connor (3/26)

Cozen O'Connor on

Illinois AG pushes for more funding amid legal battles with Trump administration- “Illinois Attorney General Kwame Raoul is pushing for additional funding for his office as it takes on a host of lawsuits and legal filings...more

Goodwin

States Continue to Pursue and Expand Healthcare Market Oversight at an Unprecedented Pace, with Significant Implications for...

Goodwin on

In recent years, states have shown an increased interest in regulating healthcare markets. The trend has accelerated further since the start of 2025, with a flurry of proposals in at least 12 states. ...more

McGuireWoods LLP

Bill Could Create Notification Requirement for Texas Healthcare Transactions

McGuireWoods LLP on

On Feb. 12, 2025, the Texas House of Representatives introduced House Bill 2747, which would require entities to report certain healthcare transactions to the Texas attorney general. Currently, Texas does not require entities...more

Foley & Lardner LLP

Colorado: Proposed Expanded Medical Care Transaction Oversight - What Providers and Investors Need to Know

Foley & Lardner LLP on

On March 5, 2025, two Senators and one Representative introduced SB 25-198 (the Bill), designed to enhance transparency in transactions involving health care entities. The Bill seeks to impose notification and reporting...more

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