The EXIT Alliance today submitted comments to the Federal Trade Commission and Department of Justice in response to the agencies' Request for Information on the Hart-Scott-Rodino (HSR) premerger notification process, urging regulators to adopt a more targeted, proportionate, and evidence-based approach to merger review.

Representing founders, investors, business owners, and M&A professionals, the EXIT Alliance's comments make a simple point: well-functioning acquisition markets are essential to innovation, entrepreneurship, and long-term economic growth. Merger review should focus scrutiny where genuine competitive concerns exist without imposing unnecessary costs and delays on the overwhelming majority of transactions that present little or no competitive risk.

"Acquisition is not merely an exit strategy—it is a core engine of innovation, capital formation, and business creation. Regulatory frameworks should reflect that reality."

The filing highlights extensive research demonstrating that healthy acquisition markets encourage venture capital investment, strengthen incentives for entrepreneurs to build new companies, and help innovative technologies reach broader markets. It also notes that compliance burdens associated with the expanded HSR filing requirements often fall most heavily on founder-led and middle-market businesses that lack the resources of large corporations.

Rather than expanding filing requirements, the Alliance encourages the agencies to evaluate whether recent changes have actually improved merger review outcomes. Among other recommendations, the submission calls on regulators to publish data showing whether the updated HSR form has reduced review times, lowered the need for Second Requests, or otherwise improved enforcement efficiency before considering additional reporting requirements.

"An evidence-based regulatory process should be guided by evidence. Before imposing additional costs on thousands of businesses, policymakers should demonstrate that those costs produce measurable public benefits."

The comments also emphasize the importance of timely review in fast-moving sectors such as artificial intelligence, robotics, biotechnology, and other emerging technologies. In industries where products and business models evolve rapidly, prolonged regulatory uncertainty can itself undermine innovation by causing otherwise beneficial transactions to collapse before review is complete.

Finally, the Alliance argues that merger policy should recognize the broader role business exits play throughout the economy. Successful acquisitions allow founders to realize the value of what they have built, provide liquidity for investors, preserve jobs, and recycle capital into the next generation of American businesses.

"Competition policy should protect competition—not unnecessarily impede the business transitions that fuel entrepreneurship, investment, and economic growth."

The EXIT Alliance appreciates the opportunity to participate in the agencies' review and looks forward to continued engagement as policymakers evaluate opportunities to modernize the premerger notification process.