FDD Compliance Requirements
The complete rulebook.
Always up-to-date.
Federal, NASAA, and state — every layer of compliance, refreshed within minutes of new regulations being published.
Request Access
The Regulatory Framework
FTC Franchise Rule, NASAA, and state registration in one review
The federal FTC Franchise Rule (16 CFR Part 436) establishes the baseline: what must be disclosed, when it must be delivered, and what format it must follow. But franchise compliance doesn't stop at the federal level.
The North American Securities Administrators Association publishes Franchise Registration and Disclosure Guidelines that supplement the FTC Rule with additional commentary on disclosure adequacy. These guidelines carry significant weight with state examiners. On top of that, the 14 franchise registration states each have their own statutes, rules, and examiner preferences that go beyond both the FTC Rule and NASAA Guidelines.
Dale's rulebook synthesizes all three layers into a unified analysis. When a finding is surfaced, it cites the specific rule: 16 CFR 436.5(a)(1), NASAA FDD Guidelines Section 3, or a California-specific registration requirement.
Every finding is graded by severity so attorneys and examiners can triage their review. Address critical deficiencies first, confirm compliant areas last.
Anatomy of a Finding
Every finding traces back to a specific rule.
Dale doesn't generate opinions. Every finding it surfaces is checked against your organization's Rulebook, cites the regulation it implicates, quotes the relevant passage from the document, and is graded by severity so counsel can triage the review.
Sample finding, as rendered in review
Earnings claim lacks disclosed substantiation basis
The financial performance representation in Item 19 states an average revenue figure without disclosing the underlying data set, reporting period, sample size, or geographic scope required to substantiate the claim.
What's in every finding
A rule, not an opinion
Each finding is generated against a specific rule in your Rulebook and cites the source. No citation, no finding — Dale won't flag a passage if it can't point to the regulation it implicates.
Graded by severity
Critical, Non-Compliant, Needs Review, and Compliant. Severity is assigned by the rule itself, not by Dale's discretion, so counsel can triage the review and escalate issues that would trigger a deficiency letter.
Anchored in the document
Every finding includes the page, the quoted excerpt, and a highlight on the redline so counsel can verify the finding against the source in one click — without re-reading the document.
Three regulatory layers, one Rulebook
Dale's Rulebook unifies the FTC Franchise Rule (16 CFR Part 436), NASAA Guidelines and commentary, and state-specific registration requirements into a single authority. When a rule changes, your Rulebook updates — and every review run after that point is graded against the new language.
State-Level Requirements
Federal compliance is the floor,
not the ceiling.
Fourteen states require franchise registration before a franchisor can offer or sell franchises within their borders. Each state's examiner reviews the FDD against their own checklist. A document that passes federal review can still receive a deficiency letter at the state level.
Registration states
California, Hawaii, Illinois, Indiana, Maryland, Michigan, Minnesota, New York, North Dakota, Rhode Island, South Dakota, Virginia, Washington, and Wisconsin each require franchise registration. Dale's rulebook includes state-specific requirements that go beyond the FTC baseline.
Filing states
Connecticut, Florida, Kentucky, Nebraska, North Carolina, South Carolina, Texas, and Utah have franchise filing or notice requirements. While these states don't conduct substantive review, the filing requirements still impose disclosure obligations that franchisors must meet. Dale checks against those too.
Business opportunity states
Several states regulate franchise-like arrangements under business opportunity laws rather than franchise statutes. When a client's offering structure may trigger these laws, disclosure requirements change. Dale identifies provisions that may create exposure under business opportunity statutes in addition to franchise laws.