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FTC Franchise RuleNASAA GuidelinesItem 19 DisclosuresBrand DiligenceCited ResearchMarket BenchmarkingIn-Document DraftingTracked Changes

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Item 19 · Financial Performancep. 94

“…other than the information in this Item 19, we do not make any financial performance representations. Average gross sales for franchised units open two or more years were $1,284,000 in fiscal year 2025…”

Non-compliant

Discloses an average of gross sales without the median, or the highest and lowest numbers in the range.

NASAA FPR Commentary § 19.16

1 of 24 findings · Full FDD8m 42s

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Item 19 Financial Performance Representations: What the FTC Franchise Rule Actually Requires

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The 23 Items of a Franchise Disclosure Document, Explained

A section-by-section walkthrough of every item in a Franchise Disclosure Document under the FTC Franchise Rule, what franchisors must disclose, and where the real compliance risk hides.

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