FTC Premerger Notification Office Narrows Application of HSR Rule 802.5: The Investment Rental Property Exemption

The Federal Trade Commission (“FTC”) Premerger Notification Office (“PNO”) recently issued updated guidance regarding how the PNO will interpret and apply going forward the exemption for investment rental property set forth in 16 C.F.R. § 802.5 of the regulations promulgated under the Hart-Scott-Rodino Antitrust Improvements (“HSR”) Act.