ANALYSIS: 2020 CFIUS Data Show Steady Workload Amid Hectic Year

摘要

There is a general trend here of increased review by CFIUS over the past decade: The body of the reportstates that “While the number of notices filed in 2020 decreased from 2019, the overall number oftransactions reviewed or assessed by the Committee increased substantially [from 2011 to 2020], due tothe introduction of [short-form] declarations as a method for filing any type of transaction with theCommittee.”2020 was an unusual year—both for the transactional ecosystem in general and for CFIUS as well.Considering that the regulations implementing FIRRMA went into effect on Feb. 13, 2020, just a monthbefore the March 11 pandemic declaration by the World Health Organization, the summary data in thereport do not indicate drastic changes. The data in the report suggest that CFIUS had a comparable workload to 2019. Even so, the impacts of FIRRMA’s changes to the process, by way of higher numbers ofdeclarations and lower numbers of notices and investigations, are starting to show.