Notice of Request for Public and Internal Comment: Proposed Model Franchise Exemptions
Download: Proposed Model Franchise Exemptions
The Board of Directors of the North American Securities Administrators Association, Inc. (NASAA) has authorized the release, for both internal and public comment, of proposed Model Exemptions relating to state franchise registration and disclosure laws.
The proposal includes model language for states to use to promulgate exemptions from registration and disclosure provisions under current state franchise laws. The proposal adopts four types of franchise exemptions: (1) a fractional franchise exemption; (2) an experienced franchisor exemption; (3) a set of three sophisticated purchaser exemptions; and (4) a discretionary exemption. The Proposal contains some elements of existing exemptions adopted by several franchise registration states, although requirements have been updated to reflect current conditions in franchising and the U.S. economy
The comment period begins on July 1, 2011, and will remain open for 30 days. All comments should be submitted on or before August 1, 2011. Comments should be directed by e-mail or in writing to:
Franchise and Business Opportunity Project Group
Dale Cantone, Chair
Office of the Attorney General
Division of Securities
200 St. Paul Place, 20th Floor
Baltimore, MD 21202-2020
dcantone@oag.state.md.us
NASAA Legal Department
Joseph Opron
Counsel
NASAA
750 First Street, NE, Suite 990
Washington, DC 20002
jjo@nasaa.org
Comments Received
- Carl E. Zwisler, Gray Plant Mooty
- Charles S. Modell, Larkin Hoffman Daly & Lindgren Ltd.
- David L. Cahn, Counsel, Whiteford, Taylor & Preston L.L.P.
- David Byers, Director, Corporate Counsel, Starbucks Corporation
- Karen Boring Satterlee, Vice-President & Senior Counsel, Hilton Worldwide
- Samuel B. Morrison, Morrison Law Offices, P.C.
