Department Stores (United States) — NAICS 455110

A Histometrics industry primer for public-market and private investors.

1. Overview

A department store sells a broad mix of new merchandise — apparel, accessories, jewelry, cosmetics, home goods, toys — organized into separate departments, with no single line dominating, through stores and, increasingly, digital channels. Think Macy's, Nordstrom, Dillard's, Kohl's, Bloomingdale's, Saks Fifth Avenue, JCPenney, Neiman Marcus, and Belk.[1] For most of the 20th century this was the anchor format of American retail. Today it is a shrinking, consolidating category that has ceded share for two decades to off-price chains, mass-market supercenters, specialty brands, and e-commerce.[5][6]

The industry matters beyond its size because its economics are unusual. A department store is part retailer, part lender, and part landlord: a large share of profit historically comes not from selling clothes but from store credit cards and, more recently, from advertising and prime real estate.[7][8] That is why cheap-looking chains can be value traps or hidden real-estate plays, and it is the single most important thing to understand about how the money works.

Ways in. Only three pure-play department-store companies still trade publicly — Macy's, Kohl's, and Dillard's. Everything else has gone private or been rolled up: Nordstrom was taken private in 2025, Saks and Neiman Marcus merged into a private luxury group, and JCPenney folded into privately held Catalyst Brands.[9][11][14] Private investors reach the industry through private equity, family-controlled chains, mall real estate, senior and distressed credit, private-label sourcing, loyalty and retail-media infrastructure, and the credit-card receivables the stores generate. The industry is therefore much broader than its public stock-market footprint.

2. What it is, and how it's structured

Federal definition. The North American Industry Classification System (NAICS) is the U.S. government's standard for classifying business activity. Code 455110 covers establishments "generally known as department stores" that carry separate departments of general merchandise with no one line predominating; perishable grocery sales, if any, are insignificant.[1]

What 455110 excludes — this is where most of the confusion lives:

• Warehouse clubs, superstores, and supercenters (a general line of goods plus a large, varied grocery section) → NAICS 455211. Walmart Supercenters, Target, Costco, Sam's Club, and BJ's sit here — not in department stores.[1]
• All other general-merchandise retailers not known as department stores (dollar stores, variety stores) → NAICS 455219.[1]
• Clothing-only stores with little housewares or general merchandise → NAICS 458110 (Clothing and Clothing Accessories Retailers). Off-price chains such as TJX/T.J. Maxx, Ross, and Burlington generally sit here or in other general-merchandise codes — not in 455110.[1]
• Electronic shopping and mail-order houses → NAICS 454110. A department-store company may run large digital channels, but that online activity can be classified separately from its stores.[1]
• Used-merchandise stores → NAICS 459510.[1]

So 455110 is specifically the traditional, full-line apparel-and-home department store — the mall-anchor model — and deliberately leaves out the giant general-merchandise big boxes. (455110 is a 2022-vintage NAICS code; in earlier classifications department stores lived under code 4521.)[1]

Ownership mix. This is not a fragmented small-business industry — federal data count just 63 firms in the entire industry.[2] The rest are a handful of large chains owned by public shareholders (Macy's, Kohl's, Dillard's), private-equity and holding companies (the Saks/Neiman luxury group; Belk under Sycamore Partners; JCPenney inside Catalyst Brands), founding families (the Nordstrom family with Mexico's El Puerto de Liverpool; the Dillard family via a controlling share class; Von Maur; Boscov's), and mall landlords who have become part-owners of the stores they lease to.[9][11][14][15][31][32] The industry is broader than any one of these lenses suggests.

3. How big it is

Ground-truth U.S. federal statistics for NAICS 455110:

(CR4/CR8/CR20 = the combined market share of the largest 4, 8, and 20 firms. HHI = a concentration index that squares and sums each firm's market share; above ~1,800 is considered highly concentrated. SBA = U.S. Small Business Administration.)

The picture is a small, highly concentrated, and contracting industry: four firms sell roughly 85% of everything, and the ~$60.7 billion of receipts is a fraction of overall U.S. retail.[2] Department-store spending peaked around January 2001 and has fallen almost continuously since; on the Census Bureau's older, broader monthly "department stores" series (a different, now-discontinued basis), sales slid to about $132.7 billion in 2023 — a record low outside the 2020 shutdown year.[24][25]

A measurement caveat — narrow definition, not undercount. Unlike many industries, 455110 is not undercounted by tiny operators — it is dominated by a few giants, and the employer-based coverage of County Business Patterns and the Economic Census (which omit nonemployer businesses and most government activity) is unlikely to distort a branded, chain-based, employee-intensive industry.[2][3] The real caveat runs the other way: the definition is deliberately narrow. America's largest general-merchandise sellers (Walmart, Target, Costco) are booked to sibling code 455211, and off-price chains sit in clothing/other codes.[1] Note too that the ~2,434 establishments and ~$60.7 billion of receipts sit below the combined store-network revenue of just the four biggest traditional chains — a reminder that company-reported revenue bundles in e-commerce, credit-card income, off-price banners, and corporate operations that the Census books under other codes. Read 455110 as "traditional full-line department stores," not "everywhere Americans buy general merchandise."

The supplied federal file does not provide industry-wide same-store sales, digital penetration, floor space, gross margin, or operating profit; those figures below come from individual company disclosures, not from the Census.

4. The investable universe

The New York Stock Exchange (NYSE) is the listing venue for all three remaining public operators.

Public companies (pure-play department stores):

Recently taken private / no longer public:

• Nordstrom — delisted from the NYSE on May 21, 2025 after a $6.25 billion take-private by the Nordstrom family (50.1%) and Mexico's El Puerto de Liverpool (49.9%) at $24.25/share. Fiscal-2024 revenue was about $15 billion.[9][10]

Major private and other owners:

• The Saks/Neiman luxury group (private) — Saks Fifth Avenue, Saks Off 5th, Neiman Marcus, and Bergdorf Goodman, combined after Saks's parent acquired Neiman Marcus for $2.7 billion in December 2024 (with minority equity from Amazon and Salesforce). Branded "Saks Global," the tie-up struggled badly with vendor-payment problems and falling sales, pushed the group into bankruptcy restructuring, and in 2026 emerged under new ownership rebranded as Exemplar Luxury Group.[11][12][13]
• Catalyst Brands (private) — formed January 2025 by merging JCPenney with SPARC Group (Aéropostale, Brooks Brothers, Eddie Bauer, Lucky Brand, Nautica); roughly $9 billion revenue, ~1,800 stores, 60,000 employees. Owners include mall landlords and brand managers — Simon Property Group, Brookfield, Authentic Brands Group, and Shein.[14]
• Belk (private) — Sycamore Partners retained majority control in a 2021 recapitalization while lenders took minority ownership.[15]
• Von Maur and Boscov's — family-owned regional chains.[31][32]
• Sears / Transformco — Sears and Kmart survive only as legacy remnants under private holding company Transformco, no longer a like-for-like national peer.[33]

If you want broad "general merchandise" exposure, the adjacent public names are off-price (TJX, Ross/ROST, Burlington/BURL) and mass/supercenters (Walmart/WMT, Target/TGT, Costco/COST) — but those are different NAICS codes, and they are the very competitors taking department stores' share.[23]

5. How the money works

A department store buys inventory before it sells it, marks it up, then discounts what doesn't move. Revenue less returns, promotions, and markdowns, minus cost of goods sold (COGS — merchandise, freight, markdowns, and shrink), leaves gross margin; selling, general and administrative (SG&A) costs then cover store labor, occupancy, distribution, technology, and marketing.[19] Owners make money through several levers — and the merchandise margin is often the least profitable of them:

• Comparable (same-store) sales, or "comps." The headline growth metric: sales at a stable store-and-digital base open at least a year, excluding openings, closings, and relocations. Positive comps signal a healthy base; negative comps against a big fixed-cost base cause profits to fall faster than sales (operating deleverage). The reverse is also true — a turnaround can produce strong operating leverage with little store growth.[5][6]
• Gross margin and markdowns. Heavy coupon/promotional cultures (Kohl's, Macy's) train shoppers to wait for sales and compress margin; inventory turnover, shrink (theft/loss), returns, and markdown timing drive profitability.[5][19]
• Store credit cards — the profit engine. Co-branded and private-label cards run through bank partners (Macy's with Citi, Kohl's with Capital One, Dillard's with Wells Fargo, Nordstrom via its own bank and TD Bank Group). The retailer keeps a share of finance charges and fees. This income has at times dwarfed store profit: credit reportedly generated about 87% of Nordstrom's operating profit in 2022 and a large share of Kohl's.[7][8] It is also the industry's most exposed line — to consumer credit losses in downturns and to regulation (see §7).
• Retail media and other income. Newer, high-margin advertising revenue (e.g., Macy's Media Network), plus loyalty programs, unused gift cards, vendor funding, and leased/licensed departments (beauty, brands).[8][16][19]
• Real estate. Many chains own prime property — Macy's flagship at Herald Square, Dillard's owning >90% of its stores.[20] The market value of that real estate has at times exceeded the whole company's stock-market value, which is why activists periodically push for sale-leasebacks or breakups, and why Dillard's can carry a market cap larger than a rival with three times its sales.[22]
• Unit economics: sales per square foot, which mall-traffic decline steadily erodes — pushing operators to close weak stores and shrink the footprint.[18]

Seasonality is extreme: the November–January holiday quarter drives an outsized share of annual sales and nearly all of the year's profit.

6. What drives demand

• The health of the consumer: disposable income, wages, employment, and confidence. Apparel and home goods are discretionary and get cut early when budgets tighten.[5]
• Where and how people shop. Decades of migration to off-price, mass, specialty, and online formats. Off-price alone (TJX ~21%, Ross ~8%, Burlington ~4% of that segment in early 2025) keeps opening hundreds of stores a year and taking department-store share.[23]
• Mall and physical-retail traffic. Department stores are mall anchors; when foot traffic falls, so do their sales — and vice versa when shoppers return to stores.[23]
• Trade-down and inflation. When the cost of necessities rises, shoppers trade down into value merchandise — a headwind for full-price and luxury operators but a potential tailwind for value chains, which then face fierce off-price and mass competition.[5]
• Credit and interest rates. Rates affect both consumer spending power and the profitability of the store-card business.[7]
• Fashion and product cycles, tourism (flagship luxury stores in gateway cities), loyalty and personalized marketing, and omnichannel convenience (buy-online-pickup-in-store, ship-from-store). Luxury banners are more exposed to wealth effects; value banners to the broad household budget.

7. Regulation

Department stores are lightly regulated as retailers, but several regimes matter:

• Consumer credit. Because store cards are core to profit, the industry is sensitive to the Consumer Financial Protection Bureau (CFPB) and rules like the Credit CARD Act (Credit Card Accountability Responsibility and Disclosure Act) and TILA (Truth in Lending Act). A 2024 CFPB rule capping credit-card late fees at $8 (from a ~$32 average) threatened card income across the sector; a federal court vacated the rule in 2025 after the CFPB moved to drop it, removing that overhang for now.[26][27]
• Product safety. The Consumer Product Safety Commission (CPSC) requires retailers to report potentially hazardous or non-compliant products, generally within 24 hours.[29]
• Advertising, pricing, and labeling. The Federal Trade Commission (FTC) polices deceptive "original price"/reference-price and markdown claims (a recurring source of class-action litigation for promotional retailers) and enforces textile, wool, and care-labeling rules requiring disclosure of fiber content, country of origin, and the responsible party.[28]
• Labor. Federal and state minimum-wage, overtime, and scheduling laws; unionization at some Macy's and Bloomingdale's stores; workplace-safety rules under the Occupational Safety and Health Administration (OSHA).
• Sales tax. The 2018 South Dakota v. Wayfair decision requires collecting sales tax on interstate e-commerce, raising compliance costs for omnichannel sellers.
• Trade and tariffs. Apparel and home goods are heavily imported, so import tariffs feed directly into the cost of goods — a live margin and pricing risk that Macy's specifically flagged in its latest results as U.S. tariff policy tightened.[16]
• Antitrust. Further consolidation is reviewed under the FTC and Department of Justice (DOJ) 2023 Merger Guidelines, which weigh concentration levels, lost competition, and trends toward greater concentration.[30]

8. Competitive dynamics and consolidation

This is a structurally declining, consolidating category, and it competes less within NAICS 455110 than against businesses outside the code — warehouse clubs, supercenters, off-price chains, specialty apparel, direct-to-consumer (DTC) brands, and online marketplaces (Amazon, Shein, Temu). The direction of travel over the past decade:

• Extinctions and near-extinctions: Sears and Kmart have all but disappeared.[33]
• Take-privates and mergers: Nordstrom went private (2025); Saks and Neiman Marcus combined, then restructured as Exemplar Luxury Group (2024–2026); JCPenney merged with SPARC into Catalyst Brands (2025); Belk sits under private equity.[9][12][13][14][15] Only three pure-play public names remain.
• Activist pressure and real-estate value. Macy's has been a repeat target (an Arkhouse/Brigade buyout approach failed in 2024), and Kohl's endured a takeover battle in 2022 — both driven by the gap between store value and real-estate value.[7]
• A widening split between winners and laggards. Disciplined and luxury operators (Dillard's, Bloomingdale's, Nordstrom, Belk) posted growth into 2025, while mid-market nameplates (Kohl's, Macy's flagship stores, JCPenney) are stabilizing at best.[5][6] Concentration is high (CR4 84.9%, HHI 2,386.8), but it reflects bargaining and scale potential, not durable competitive advantage: consumer switching costs are low and competitors keep entering through other formats.[2][23]

9. Risks

• Secular decline of the format and dependence on struggling malls.[5]
• Share loss to off-price, mass/supercenters, specialty, DTC brands, and marketplaces.[23]
• Credit-card concentration risk: an outsized share of profit rides on card income, exposed to rising consumer credit losses and to regulation.[7][8]
• Operating deleverage: high fixed occupancy, labor, and lease costs mean falling sales hit profit hard.[6]
• Inventory and fashion risk: wrong bets force margin-destroying markdowns; shrink and returns compound the pressure.
• Tariff and supply-chain cost inflation on imported apparel and home goods.[16]
• Consumer downturn / trade-down, since spending here is discretionary.
• Execution risk on multi-year turnarounds and store-closure programs.[18]
• Real-estate realization tension: the value is often in the property, but monetizing it (sale-leasebacks) can weaken the operating business, and commercial real estate has softened — so "hidden real estate" can be overstated where stores need heavy reinvestment.
• Vendor and liquidity risk, vividly illustrated by the Saks/Neiman payment crisis; and, for private owners, opaque leverage and limited disclosure.[12]
• Cybersecurity, privacy, and product-safety/recall exposure, plus antitrust scrutiny of further consolidation.

10. How to invest, and the outlook

Public routes. Analyze the three remaining pure-plays — Macy's (M), Kohl's (KSS), Dillard's (DDS) — as separate businesses, not one industry multiple. Recent disclosures show dispersion, not a uniform recovery: Macy's returned to +1.5% comparable-sales growth on ~$21.8 billion of net sales; Kohl's net sales fell 4.0% with ~29% digital penetration; Dillard's posted +3% comparable sales.[16][19][20][21] Key lenses: comps and traffic, gross-margin/markdown trends, inventory turns and aged inventory, SG&A as a share of sales, credit-card and retail-media contribution, store-closure and remodel returns, and lease/debt/liquidity/free cash flow (and EBITDA — earnings before interest, taxes, depreciation and amortization — adjusted for one-offs). Dillard's is the outlier: buyback-driven scarcity and owned real estate give it a market cap larger than higher-revenue peers, and it pays modest regular plus periodic special dividends; Macy's yields around the mid-single digits; Kohl's has offered a high but less secure dividend.[20][22] Treat all share prices, dividend yields, and multiples as date-stamped and cyclical — a low multiple or high yield can reflect structural decline, debt risk, or a shrinking store base, not value.

• Adjacent plays on the same shift: off-price (TJX, ROST, BURL) and mass/supercenters (WMT, TGT, COST) — the competitors gaining share.[23] The card issuers behind the store programs (Synchrony/SYF, Capital One/COF, Citi/C) capture much of the credit economics. Mall REITs (real estate investment trusts) such as Simon Property Group (SPG) are landlords — and, via Catalyst Brands, part-owners — of department-store space.[14]

Private routes. Direct equity in regional or specialty chains (Von Maur, Boscov's, the Dillard family's control block); private-equity and holding-company positions (the Saks/Neiman backers, Sycamore's Belk, Simon/Brookfield/Authentic Brands/Shein in Catalyst Brands); senior secured or distressed credit; retail real estate and anchor redevelopment, including sale-leaseback and property-backed financing; private-label sourcing, logistics, and fulfillment; and loyalty, retail-media, and customer-data infrastructure. Retail credit-card receivables are often financed through asset-backed securities (ABS).[13][14] The core diligence questions: is inventory current, do stores generate cash before corporate costs, can leases be renegotiated, is owned real estate genuinely monetizable, and does the capital structure leave enough liquidity for a turnaround?

Near-term drivers to watch (forward-looking): the strength of the U.S. consumer and interest rates; how much tariff-driven cost inflation stores can pass through; the regulatory fate of store-card fees; holiday-season comps; real-estate monetization; and further consolidation or take-privates.

Outlook (a judgment, not a forecast). The format is structurally challenged but not dying. After years of decline, 2025 brought genuine signs of stabilization — growth at Dillard's, Bloomingdale's, Nordstrom, and Belk, and steadier results at Macy's, Kohl's, and JCPenney — as operators closed weak stores, leaned into luxury and beauty, and shored up profitability.[5][6][16][18] The base case is continued bifurcation and consolidation rather than a broad revival: fewer, more productive stores, with disciplined value operators and the luxury tier faring best while undifferentiated mid-market chains keep ceding ground to off-price and online. The most attractive opportunities are likely to be selective — public turnarounds with improving store economics, private credit with strong downside protection, and real-estate situations where operating and property value are valued separately. For investors, the enduring question is whether a given chain is a fading retailer or an underpriced pile of real estate and credit-card cash flow — because in this industry it is often both.

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Sources

1. U.S. Census Bureau, "2022 NAICS Definition — 455110 Department Stores" (2022 NAICS Manual). https://www.census.gov/naics/reference_files_tools/2022_NAICS_Manual.pdf
2. U.S. Census Bureau, 2022 Economic Census — "Selected Sectors: Concentration of Largest Firms for the U.S.: 2022," NAICS 455110 (receipts, firms, CR4/CR8/CR20/CR50, HHI). https://data.census.gov/table/ECNSIZE2022.EC2200SIZECONCEN
3. U.S. Census Bureau, County Business Patterns 2023, NAICS 455110 (establishments, employment, annual and Q1 payroll). https://www.census.gov/data/datasets/2023/econ/cbp/2023-cbp.html
4. U.S. Small Business Administration, "Table of Small Business Size Standards," 2023 (NAICS 455110 = $40 million). https://web.data.sba.gov/en/dataset/small-business-size-standards
5. Modern Retail, "'There are superior business models': Why department stores are losing sales," 2025. https://www.modernretail.co/operations/there-are-superior-business-models-why-department-stores-are-losing-sales/
6. Modaes Global, "Winners vs. Laggards in U.S. Department Stores," 2025. https://www.modaes.com/global/companies/winners-vs-laggards-us-department-stores-redefine-themselves-in-the-face-of-a-changing-model
7. CNBC, "Department stores face another squeeze. This time, with store credit card revenue," 2024. https://www.cnbc.com/2024/04/10/store-credit-cards-deal-department-stores-another-revenue-squeeze.html
8. CNBC, "Profits from store-branded credit cards hide depth of retail's troubles," 2017. https://www.cnbc.com/2017/05/12/profits-from-store-branded-credit-cards-hide-depth-of-retails-troubles.html
9. CNBC, "Nordstrom to go private in $6.25 billion deal with founding family, Mexican retailer," 2024. https://www.cnbc.com/2024/12/23/nordstrom-private-company-founding-family-el-puerto-de-liverpool.html
10. Nordstrom, Inc., "Nordstrom Announces Completion of Acquisition by Nordstrom Family and Liverpool," 2025. https://press.nordstrom.com/news-releases/news-release-details/nordstrom-announces-completion-acquisition-nordstrom-family-and/
11. Digital Commerce 360, "Saks Global completes $2.7 billion Neiman Marcus acquisition," 2024. https://www.digitalcommerce360.com/2024/12/31/saks-global-completes-neiman-marcus-acquisition/
12. CNBC, "How Saks' acquisition of Neiman Marcus plunged the company into bankruptcy," 2026. https://www.cnbc.com/2026/01/15/saks-acquisition-of-neiman-marcus-led-to-bankruptcy.html
13. PR Newswire, "Saks Global Successfully Emerges as Exemplar Luxury Group," 2026. https://www.prnewswire.com/news-releases/saks-global-successfully-emerges-as-exemplar-luxury-group-offering-unrivaled-customer-experiences-across-neiman-marcus-saks-fifth-avenue-and-bergdorf-goodman-302812339.html
14. JCPenney, "SPARC Group Has Merged with JCPenney To Form Catalyst Brands," 2025. https://corporate.jcpenney.com/2025/01/08/sparc-group-has-merged-with-jcpenney-to-form-catalyst-brands/
15. Belk, "Sycamore Partners Reaches Agreement to Recapitalize and Retain Control of Belk," 2021. https://newsroom.belk.com/restructuring
16. Macy's, Inc., "Macy's, Inc. and Macy's Return to Annual Comparable Sales Growth; Fourth Quarter and Fiscal Year 2025 Results," 2026 (net sales, comps, tariff commentary). https://investors.macysinc.com/newsroom/news/news-details/2026/Macys-Inc--and-Macys-Return-to-Annual-Comparable-Sales-Growth-Fourth-Quarter-and-Fiscal-Year-2025-Results-Exceed-Guidance/default.aspx
17. U.S. Securities and Exchange Commission, Macy's, Inc. Form 10-K — store and employee counts. https://www.sec.gov/Archives/edgar/data/794367/000162828025014315/m-20250201.htm
18. CNBC, "Macy's will close 150 stores, open new Bloomingdale's, Bluemercury" (Bold New Chapter), 2024. https://www.cnbc.com/2024/02/27/macys-will-close-150-stores-open-new-bloomingdales-bluemercury.html
19. U.S. Securities and Exchange Commission, Kohl's Corporation Form 10-K (net sales, digital penetration, merchandise-cost and other-revenue disclosures). https://www.sec.gov/Archives/edgar/data/885639/000119312526115982/kss-20260131.htm
20. U.S. Securities and Exchange Commission, Dillard's, Inc. filings — 272 stores and owned real estate (Form 8-K, Nov. 2025; Form 10-K). https://www.sec.gov/Archives/edgar/data/28917/000002891725000029/dds-20251113xex99.htm
21. Dillard's, Inc., "Dillard's Reports First Quarter Results" (comparable-store sales +3%). https://investor.dillards.com/static-files/154c5abe-9c62-41a7-9032-5d13b30e0de9
22. Macrotrends, "Market Cap — Macy's (M), Kohl's (KSS), Dillard's (DDS)," mid-2026. https://www.macrotrends.net/stocks/charts/DDS/dillards/market-cap
23. Retail Dive, "Off-price retailers poised to take even more market share from department stores," 2024–2025 (TJX ~21%, Ross ~8%, Burlington ~4% of the off-price segment, Q1 2025). https://www.retaildive.com/news/off-price-retailers-tjx-ross-burlington-q2-take-market-share-department-stores-macys/725711/
24. Experian, "How Department Store Spending Has Changed in the Last 30 Years" (peak ~January 2001). https://www.experian.com/blogs/ask-experian/research/how-department-store-spending-has-changed/
25. Statista, "U.S. Department Stores — Statistics & Facts" (2023 sales ~$132.7 billion on the broader Census-based series). https://www.statista.com/topics/4396/department-stores-in-the-us/
26. Consumer Financial Protection Bureau, "Issue Spotlight: The High Cost of Retail Credit Cards" / credit-card late-fee rule, 2024. https://www.consumerfinance.gov/data-research/research-reports/issue-spotlight-the-high-cost-of-retail-credit-cards/
27. Consumer Financial Services Law Monitor, "CFPB Abandons Credit Card Late Fee Rule," 2025. https://www.consumerfinancialserviceslawmonitor.com/2025/04/cfpb-abandons-credit-card-late-fee-rule/
28. Federal Trade Commission, "Apparel and Labeling" (textile, wool, and care-labeling requirements). https://www.ftc.gov/news-events/topics/tools-consumers/apparel-labeling
29. U.S. Consumer Product Safety Commission, "Duty to Report to CPSC: Rights and Responsibilities of Businesses." https://www.cpsc.gov/Business--Manufacturing/Recall-Guidance/Duty-to-Report-to-CPSC-Rights-and-Responsibilities-of-Businesses
30. Federal Trade Commission, "FTC and DOJ's Joint 2023 Merger Guidelines Are in Effect," 2025. https://www.ftc.gov/news-events/news/press-releases/2025/02/ftc-chairman-andrew-n-ferguson-announces-ftc-dojs-joint-2023-merger-guidelines-are-effect
31. Von Maur, "About Us," 2026. https://www.vonmaurcareers.com/about-us-v3
32. Boscov's, "Our Story," 2026. https://www.boscovs.com/our-story
33. Transformco, "About Us," 2026. https://transformco.com/about