Since the emergency regulations and guidelines are evolving rapidly and each of your circumstances are unique, we encourage you to reach out to us if you have questions about how this or other COVID-19 related government action.

NASAA FRANCHISE COMMENTARY FINANCIAL PERFORMANCE REPRESENTATIONS. In September 2016 the North American Securities Administrators Association Inc (NASAA) issued a notice of request seeking public comment on a proposed financial performance representations (FPR) commentary regarding franchise disclosures. Media Contacts: Bob Webster Director of Communications Noelle Lane Communications Specialist. <>/ExtGState<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/Annots[ 16 0 R 17 0 R] /MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> the presentation of data based on, or involving, company-owned outlets versus franchised outlets; disclosures of gross sales, gross profit or net profit; use of subsets (eg, based on performance, geography or other criteria); disclosures of 'average' and 'median' numbers. dcantone@oag.state.md.us, NASAA Legal Department Further, the disclosure requirements under the FTC Franchise Rule are largely based on prior guidelines issued by NASAA. Wed 14 Oct, 2020 - 6:30 AM ET . The NASAA comment period is from October 1, 2015 to November 2, 2015. - Robert Johnson, Edenville Township, "Bill is accessible and provides prompt responses to requests for documents or legal opinions. Several state franchise administrators have asked the NASAA Franchise Project Group. Contact Michelle to get the Township Law E-Letter delivered directly to your inbox each month!

Christopher Staley, Counsel This NASAA Commentary addresses a number of questions raised by franchisor representatives and state franchise examiners about financial performance representations (FPRs). "Trustworthy, experienced, protective, and insightful are words I would use to describe Mr. Burzych and his law practice.

As we previously reported last year, on May 8, 2017, the North American Securities Administrators Association (NASAA) voted to adopt a Financial Performance Representation Commentary for franchises (FPR Commentary). NASAA Financial Performance Representation Commentary. Also, many franchisors updated their FDDs in the spring of 2020, before the COVID-19 shutdown that included a Historical FPR in Item 19. Cary Ichter is, by far, the most exceptional litigator in the state of Georgia. It does not address every question that may arise regarding FPRs. Baltimore, MD 21202-2020 According to NASAA's notice of request, the proposed FPR commentary seeks to address various questions raised by franchisor representatives and state franchise examiners regarding FPRs. - James Porter, Oshtemo Charter Township, "William Fahey has a depth of knowledge and practical advice which has made him a recognized leader in Michigan Land Use Law. NASAA’s Franchise and Business Opportunity Project Group  is releasing for internal and public comment a Proposed Franchise Commentary on Financial Performance Representations. June 2020 . Notice of Request for Comments Regarding a Proposed Franchise Commentary on Financial Performance Representations. The North American Securities Administrators Association Inc (NASAA) recently issued a notice of request seeking public comment on a proposed financial performance representations (FPR) commentary regarding franchise disclosures.

<> Copyright©2019, NASAA. We have a high degree of confidence in Bill's legal expertise." cs@nasaa.org. And for less. His reputation within the Georgia legal community is exceptional.

For further information on this topic please contact Jess A Dance at Gardere by telephone (+1 720 437 2011) or email (jdance@gardere.com).

%���� Choosing Cary as legal counsel is one of the best decisions I have ever made. Bill has presented numerous seminars I have attended..." - William Woodruff, Union Charter Township, "We have used William Fahey for the past 12 years, previously when he was with Foster Swift. Note: After the comment period has closed, NASAA will post to its website the comments it receives as submitted by the authors.

We are very fortunate to have his firm represent us whenever we need legal help or guidance. Topics addressed in NASAA's proposed FPR commentary include: NASAA, an association of state securities administrators, is influential in the franchising world. Whether the franchise business has been significantly impacted by the pandemic; The type of data the franchisor includes in the FPR; The reasonable inferences a prospective franchisee can draw from the FPR; When the franchisor estimates a prospective franchisee can expect to open for business after entering into a franchise agreement; Whether and how the franchisor adapts the franchise business to account for current market conditions resulting from the pandemic; and. I am incredibly fortunate to have found Ichter Davis. The FPR Commentary also includes the three questions and answers related to FPRs that NASAA adopted in the 2008 Franchise Commentary.
- Al McFadyen, Delhi Township DDA, "Bill is a tireless worker with fine skills." The commentary supplements NASAA’s Commentary on … You want an attorney who has experience in mediation, negotiation, trial and the court system. Media Contacts: Bob Webster Director of Communications Noelle Lane Communications Specialist. His knowledge of state and federal laws, his ability to retain even the most miniscule of details associated with a case, his preparation for depositions and court appearances are all unsurpassed. <> REALLY? I recommend his firm to anyone seeking assistance in matters of Labor Law."

This FPR Commentary provides additional guidance for making and substantiating an FPR. FSBR COVID-19 UPDATE: How We Are Serving and Protecting Our Clients.
He is a fine person and a consummate professional. NASAA states that there are a number of factors that need to be considered when a franchisor is looking to continue to use a Historical FPR in 2020 without amending this disclosure (state franchise law requires franchisors to amend a registration to reflect any material changes in a registered FDD). There’s a certain piece of mind you get with professional, aggressive, and knowledgeable attorneys that do what they say they can do. Intellectual Property Litigation & Arbitration. Mr. Burzych was instrumental in helping us at BD's Mongolian Grill develop and grow our franchise..."    -Billy Downs, BD's Mongolian Grill & Mongo Consulting, L.L.C, "Schultz's easy-going, capable demeanor made him a pleasure to work with.

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