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NASAA - Notice of Request for Comments on the Proposed Franchise Multi-Unit Commentary
By Karen Johnson on October 16, 2013 at 8:13 PM

The North American Securities Administrators Association, Inc. (NASAA) has released, for both public and internal comment, a proposed Multi-Unit Commentary related to disclosure of multi-unit franchising arrangements under the various state franchise disclosure laws.

The proposed Multi-Unit Commentary describes 3 multi-unit franchising structures and provides practical guidance related to disclosing such structures, which were not previously addressed under the NASAA’s 2008 Franchise Registration and Disclosure Guidelines or the Federal Trade Commission’s Franchise Rule. The proposed commentary also includes answers to questions concerning disclosure of multi-unit franchising arrangements specifically raised by franchise attorneys and state franchise examiners.

Beginning October 15, 2013 and continuing for a 30 day period, the public may submit comments to the proposed commentary. During the comment period, the Franchise and Distribution Group plan to prepare and submit its comments to the proposed Multi-Unit Commentary.

For more information on submitting comments to the proposed Multi-Unit Commentary or to obtain a copy of the proposed commentary, visit

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