The 2010 Merger Guidelines: Do We Need Them? Are They All We Need?

The release of the 2010 Merger Guidelines was largely an anticlimax. Unlike the 1982 and 1992 Merger Guidelines, the 2010 Merger Guidelines did not offer any radical changes in Agency policy or introduce any innovative principles or modes of analysis. Instead, the 2010 Merger Guidelines can best be characterized as reflecting existing Agency practices. To be sure, those practices have evolved over the last 18 years and, consequently, the 2010 Merger Guidelines diff