NASAA’s Franchise and Business Opportunity Project Group (the “Franchise Project Group”) is re-releasing for public comment additional revisions to NASAA’s proposed Franchise Multi-Unit Commentary (the “Multi-Unit Commentary”). The 14-day public comment period is from June 16 to June 30, 2014. Accordingly, all comments should be submitted on or before June 30, 2014 by email or in writing and addressed to:

Dale Cantone, Chair
Office of the Attorney General
Division of Securities
200 St. Paul Place, 20th Floor
Baltimore, MD 21202-2020

Christopher Staley, Counsel
750 First Street, NE, Suite 1140
Washington, DC 20002



On April 15, 2014, NASAA authorized the re-release for public comment of a revised proposed Multi-Unit Commentary (the “Revised Commentary”). In response, NASAA received a total of 2 formal public comments and an additional informal comment. Some of the comments repeated suggested revisions the Franchise Project Group considered and rejected, and other comments suggested clarifying and improving specific items.

After reviewing all comments, the Franchise Project Group proposes to make some revisions to the Multi-Unit Commentary and we propose to add a new item (SF 20.3) that did not appear in the Revised Commentary, although a different version of SF 20.3 was included in the original Commentary. A black-lined copy of the specific items from the Revised Commentary the Franchise Project Group proposes to revise is attached, as well as a complete copy of the proposed final Multi-Unit Commentary.