A Standard Document that may be used by counsel advising a client that acquires privately held or publicly traded voting securities on how to implement a compliance program to prevent violations of the Hart-Scott-Rodino (HSR) Act. This Standard Document discusses how to implement an effective compliance program, how to identify a client's ultimate parent entity (UPE), and the number and percentage of voting securities held by that UPE, including which voting securities must be aggregated with a client's holdings. This Standard Document also discusses how to determine a client's previous HSR filings and how to track the date of expiration of those filings, including under Rule 802.21, and how to monitor changes in investment intent that affect a client's ability to rely on the investment-only exemption under Rule 802.9.