Following years of study and deliberation, the North American Securities Administrators Association (NASAA) Franchise Project Group—the quasigovernmental body of federal and state franchise officials which coordinates franchise regulatory activity, initiatives and policy nationwide—recommended to NASAA a new series of Franchise Disclosure Document (FDD) “state cover pages,” which NASAA voted to adopt on May 19, 2019. (Full disclosure: This author serves, and has served for over 20 years, as an Advisor to the NASAA Franchise Project Group.)

Each of the 14 states featuring franchise registration/disclosure statutes (California; Hawaii; Illinois; Indiana; Maryland; Michigan; Minnesota; New York; North Dakota; Rhode Island; South Dakota; Virginia; Washington; and Wisconsin) will in one fashion or another adopt these new FDD state cover pages mandate. This will be accomplished by NASAA adopting revisions to the Instructions to the NASAA Guidelines governing the preparation of a Franchise Disclosure Document.