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The Registration Experience: Six Easy Lessons from the Converted

By Rochelle Spandorf and Janet Reyes
August 28, 2008

If you have registered a few dozen Uniform Franchise Offering Circulars (“UFOCs”) and spent the better part of 2008 converting your current stable to the Amended Rule's disclosure format, you can probably relate to the throbbing headache we experienced during this spring's annual filing season when we registered our clients' freshly converted franchise disclosure documents (“FDDs”) with state franchise agencies. Before the annual spring filing crunch, we had found clear sailing in registering FDDs early.

As it turns out, we were not smarter earlier in the process; state examiners had not received training in the details of the Amended Rule until March, after which they turned up the heat. Part of the challenge this spring was in finding state examiners preoccupied with their own learning curve, mastering the FDDs' subtleties and devising state registration policies along the way. We would like to share the top six lessons we learned from this spring's inaugural filing season under the Amended Rule.

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