The Board of Directors of the North American Securities Administrators Association, Inc. (NASAA) has authorized the release, for both internal and public comment, the attached proposal for states that register franchise offerings to accept, as of July 1, 2007, franchise disclosure documents prepared under the Federal Trade Commission’s amended Franchise Rule with certain additional requirements, including a state risk factor cover page.

The proposal allows franchisors to continue to file with franchise registration states franchise disclosure documents prepared under NASAA’s Uniform Franchise Offering Circular (“UFOC”) until July 1, 2008, or until NASAA adopts a replacement for the UFOC Guidelines.

The public comment period will remain open for 14 days.  Comments on the proposal are invited, and written comments should be sent to Dale Cantone, Chair of the Franchise and Business Opportunity Project Group. To facilitate consideration of comments, please include copies of your comment to each member of the Project Group and the NASAA Legal Department.


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
Office No. (410) 576-6368
Fax No. (410) 576-6532

Joseph J. Punturo
New York Department of Law
Bureau of Investor Protection & Securities
120 Broadway, 23rd Floor
New York, NY 10271
Office No. (212) 416-8211
Fax No. (212) 416-8816

Martin Cordell
Department of Financial Institutions
210 11th Street
3rd Floor West, Room 300
Olympia, WA  98504-1200
Office No. (360) 902-8732
Fax No. (360) 586-5068

Henry Lew
California Department of Corporations
320 W 4th Street
Suite 750
Los Angels, CA 90013-2344
Office No. (213) 576-7582
Fax No. (213) 576-7179

Kathryn Denton
Wisconsin Securities Division
345 West Washington Avenue
4th Floor
Madison, WI 53703
Office No. (608) 266-1365
Fax No. (608) 264-7979

Stephen Okumura
Hawaii Department of Commerce& Consumer Affairs
335 Merchant Street, Rm. 203
Honolulu, HI 96813
Office No. (808) 587-2619
Fax No. (808) 587-7559
NASAA Legal Department

Rex Staples
General Counsel

Joseph Brady
Assistant General Counsel

NASAA Corporate Office
750 First Street, NE
Suite 1140
Washington, DC  20002
Office No. (202) 737-0900
Fax No. (2020 783-3571