We now have all of the requirements of the FTC's Amended Franchise Rule being implemented.
All franchisors should be complying with the Amended Rule's disclosure requirements, and most franchisors who have sales activities in the registration states are now doing battle with the state examiners, as they test the procedures and borders of the revised disclosure requirements. That brings to mind two topics of discussion, one of which I will address below, and the other (a look at the overall system for regulating franchise sales disclosure) I will save for another column.
Today's subject: How are the state examiners reacting to the changes in franchise disclosure/registration?
Answer: I can't respond to this question from the examiner's viewpoint, but from this practitioner's standpoint, not well...