Page 76 - The CFIUS Book
P. 76

45-day review period (and, potentially, an additional 15 days for investigations in extraordinary circumstances).104 Strategically filing a CFIUS notice during the period when Team Telecom is winding down its review of the same transaction can have the benefit – due to CFIUS’ statutory deadlines – of encouraging Team Telecom to complete its review. However, we recommend that practitioners stay in close contact with Team Telecom staff during the review process and seek guidance as to the appropriate time for filing an accompanying CFIUS notice.
Because Team Telecom review remains somewhat of a black box – without formal review frameworks or timelines – dissatisfaction with the current process has recently led to calls for reform. While the FCC has not acted on a proposed formalization of the process as of this publication, there continues to be bipartisan support to reform the Team Telecom process.
In any event, both practitioners and clients should be aware that Team Telecom review is a unique aspect of telecommunications law that presents challenges both similar to and distinct from the CFIUS process.

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