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Articles by Thomas Hogan
What Turned a Stock Market Crash into the Great Depression?
To most Americans, October is “scary” because of Halloween. Economists recall another scary day: Black Tuesday, October 29, 1929. Over that Monday and Tuesday alone, the US stock market plummeted by almost 25 percent, eventually falling 89 percent from its peak by 1932. The crash is widely recognized as the start of the Great Depression, the most severe economic downturn in US history.
Warsh Wants the Federal Reserve to Rethink the Rules
At its most recent meeting, the Federal Reserve held rates constant, as most investors were expecting. Prior to the meeting, which resulted in a split 9–3 vote, there were rumblings of discontent among members of the Federal Open Market Committee (FOMC), mostly over Chairman Warsh’s controversial views on inflation, interest rates, and the Fed’s balance sheet. What do we know about Warsh’s views?
Why Is the Federal Reserve Paying Banks Billions in Interest?
When will the Federal Reserve finally stop losing money? The Fed has been effectively bankrupt (operating at a loss) since 2023 because the interest it pays to banks each month exceeds the returns on its assets. But these losses are a policy decision that the Fed can end at any time. Since October 2008, the Fed has been paying interest to private commercial banks. Banks currently earn 3.65 percent interest on reserves (IOR) that they hold at the Fed.
Fifth Circuit Denies The FTC’s Motion For Stay Pending Appeal; HSR Filers May Now File On The Old, Simpler HSR Form
Effective immediately, parties may use the old, simpler HSR form for premerger notification to the FTC and the DOJ. On March 19, 2026, the Fifth Circuit denied the FTC’s motion for a stay pending appeal of a district court order invalidating the new HSR form that has been in effect since February 2025.1 Effective immediately, HSR filers may revert to filing on the old, simpler HSR form to satisfy their premerger notification requirements for transactions subject to the HSR Act.
The Fed Has a Groupthink Problem. Warsh Can Fix It | The Daily Economy
President Trump has nominated Kevin Warsh for the top spot at the Federal Reserve. Though a former member of the Federal Reserve Board of Governors in Washington, DC, Warsh is out of sync with prevailing views at the central bank. That diversity of thought could improve the Fed’s monetary policy decisions. Warsh’s candidacy for Fed chair has been widely construed as an effort to further politicize the Fed. The implicit assumption is that Fed policy is better if everyone is in sync.
Federal Court Vacates And Sets Aside The New HSR Form
BakerHostetler are most popular: within Compliance topic(s) On February 12, 2026, the United States District Court for the Southern District of Texas vacated and set aside the 2024 final rule that created the New HSR Forms. The New HSR Forms have been in effect for just over one year. The court stayed its opinion for seven days to allow the FTC to seek emergency relief from the Fifth Circuit. No changes to statutory thresholds, reportability requirements, exemption rules, or filing fees.
Thomas E. Hogan - Concurrences
BakerHostetler (Washington) Partner Thomas E. Hogan is a partner at Baker & Hostetler, based in the firm’s Washington office. He represents clients in complex commercial, environmental, antitrust and administrative law litigation. He also advocates for clients in their dealings with regulators and counsels them on proactively managing potential liabilities.
Aleksey Pricinovskis – Concurrences
Key Takeaways On February 12, 2026, the United States District Court for the Southern District of Texas vacated and set aside the 2024 final rule that created the New HSR Forms. The New HSR Forms have been in effect for just over one year. The court stayed its opinion for seven days to allow the (…)
2026 HSR Filing Thresholds and Filing Fees Announced; 2026 Interlocking Directorate Thresholds Announced
The Federal Trade Commission (FTC) announced the 2026 filing thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (the HSR Act). Minimum reportable size-of-transaction (SOT) threshold increases to $133.9 million, and size-of-person (SOP) thresholds increase to $26.8 million and $267.8 million. The FTC also announced the new HSR filing fees for 2026.
Is Crypto Just a Meme Coin Casino?
Bitcoin and other cryptocurrencies are widely – but wrongly – panned as unregulated casinos or Ponzi schemes that create no real value. For example, US Senator Elizabeth Warren called crypto a “threat to financial stability,” while the UK’s Treasury Select Committee said that cryptocurrency ownership “more closely resembles gambling than a financial service.” While some cryptocurrencies are mainly speculative, many serve specific business or functional purposes.
The NYPD Prepares for a Mamdani Mayoralty
Original Article Posted By: gaboy, 11/13/2025 2:54:26 PM The New York City Police Department has to be feeling cursed these days. Having barely recovered from the dark years of Bill de Blasio and still emerging from the chaos of the Eric Adams era, the NYPD now faces the daunting prospect of reporting to democratic socialist Zohran Mamdani. But don't bet against the men and women in blue.
State-Level Merger Scrutiny Grows: Washington, Colorado Lead Expansion of State Premerger Notification Laws
By: Thomas E. Hogan, Aleksey Pricinovskis & Jeffrey E. Liskov (BakerHostetler) Get the Full Story Complete the form to unlock this article and enjoy unlimited free access to all PYMNTS content — no additional logins required. yesSubscribe to our daily newsletter, PYMNTS Today. By completing this form, you agree to receive marketing communications from PYMNTS and to the sharing of your information with our sponsor, if applicable, in accordance with our Privacy Policy and Terms and Conditions.
State-Level Merger Scrutiny Grows: Washington, Colorado Lead Expansion Of State Premerger Notification Laws
Washington and Colorado are set to become the first states to substantially adopt the Uniform Antitrust Pre-Merger Notification Act. Beginning July 27, certain companies and individuals will be required to submit electronic copies of their Hart-Scott-Rodino Act filings with the Washington state attorney general. Barring a constitutional referendum, a similar requirement will go into effect in Colorado on Aug. 6.
Supreme Court Invalidates Certain ‘Narrative’ Water Quality Limitations in NPDES Permits
Key Takeaways: SCOTUS has directed EPA (and state counterparts) to more clearly “spell out what a permittee must do or refrain from doing” in NPDES permits. Broadly worded, non-specific, “end-result” narrative limits are not longer enforceable. Additional legal challenges over permissible vs. impermissible “narrative” limitations in NPDES permits now seems likely. Facilities should evaluate their NPDES permits to flag limitations that may no longer be enforceable.
2025 HSR Filing Thresholds And Filing Fees Announced; Uncertainty Concerning The New HSR Forms Abounds; 2025 Interlocking Directorate Thresholds Announced
The Federal Trade Commission (FTC) announced the 2025 filing thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (the HSR Act). Minimum reportable Size of Transaction increases to $126.4 million, and Size of Person thresholds increase to $25.3 million and $252.9 million. The FTC also announced the new HSR filing fees for 2025. The new thresholds will apply to all transactions closing 30 days after the date of forthcoming publication in the Federal Register.
Rare FTC-DOJ Joint 'Gun Jumping' Action Results In Record Penalty
On January 7, the Federal Trade Commission (FTC) and Department of Justice (DOJ) jointly filed suit against XCL Resources Holdings, LLC (XCL), Verdun Oil Company II, LLC (Verdun), and EP Energy LLC (EP) for alleged "gun-jumping" in violation of the Hart-Scott-Rodino (HSR) Act. This is the first time the FTC has participated in a gun-jumping enforcement proceeding since 1999. The most recent gun-jumping suit was brought by the DOJ in August 2024.
Trump 2.0 - What To Expect In Antitrust Enforcement
Under a second Trump administration, the Department of Justice (DOJ) and the Federal Trade Commission (FTC) will still have strong and targeted enforcement agendas. Merger review and enforcement may decrease, but some targeted scrutiny will likely remain, particularly for technology-related transactions. We also expect that the form for reporting transactions will be impacted.
FTC Unveils Sweeping Modifications To HSR Merger Notification Form
B BakerHostetler More Recognized as one of the top firms for client service, BakerHostetler is a leading national law firm that helps clients around the world address their most complex and critical business and regulatory issues. With five core national practice groups — Business, Labor and Employment, Intellectual Property, Litigation, and Tax — the firm has more than 970 lawyers located in 14 offices coast to coast.
FTC Unveils Sweeping Modifications to HSR Merger Notification Form
Key Takeaways On October 10, the FTC published new HSR forms, representing the first “significant” overhaul to the HSR forms in 45 years. The new HSR forms will become effective 90 days following the publication of the Final Rule in the Federal Register, which is likely to be published in the next two weeks. The new HSR forms require substantial additional information and documentation from filing parties. The new HSR forms do not alter current filing thresholds or filing fees.
Fed admits it was wrong - kind of
Fed admits it was wrong – kind of By Thomas L. Hogan web posted March 11, 2024 During the pandemic recovery, inflation reached the highest rates in 40 years, largely driven by the Federal Reserve's excessive monetary policy. The Fed got "behind the curve" by not raising its interest rate target fast enough, even once it became apparent its own policy was to blame. While some officials are reluctant to accept it, Fed Chair Jerome Powell now acknowledges the Fed's mistakes.
Fed admits it was wrong - Kind of
During the pandemic recovery, inflation reached the highest rates in 40 years, largely driven by the Federal Reserve’s excessive monetary policy. The Fed got “behind the curve” by not raising its interest rate target fast enough, even once it became apparent its own policy was to blame. While some officials are reluctant to accept it, Fed Chair Jerome Powell now acknowledges the Fed’s mistakes.
2024 HSR Filing Thresholds and Filing Fees Announced; 2024 Interlocking Directorate Thresholds Announced
Key Takeaways On Jan. 22, the Federal Trade Commission (FTC) announced the 2024 filing thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (the HSR Act). A forthcoming notice in the Federal Register is expected in the coming days. Minimum reportable Size of Transaction increases to $119.5 million, and Size of Person thresholds increase to $23.9 million and $239 million. The FTC also announced the new HSR filing fees for 2024.
Fed Delivers Christmas Champagne to Wall Street
Stock-Markets / Stock Market 2023 By Thomas L. Hogan, Money Metals Exchange : It's Christmas on Wall Street as the long-awaited pivot is here, with Jerome Powell last week announcing the Fed's giving up on inflation and turning to that long-promised recession. The so-called Federal Reserve dot-plot, which measures Fed members' rate projections, went dovish – meaning inflationary – for the first time since the pandemic.
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