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David J. Kaufmann David J. Kaufmann

In response to what it perceived as the significant impact the COVID-19 pandemic has had on many franchise businesses, on June 17, the North American Securities Administrators Association (NASAA) Franchise and Business Opportunities Project Group—the quasigovernmental organization of federal and state franchise regulators that coordinates regulatory policy nationwide—issued guidance (the FPR Guidance) advancing new requirements, restrictions and prohibitions pertaining to Franchise Disclosure Document Item 19 franchise network historic financial performance representations (FPRs) (accessible at https://www.nasaa.org/wp-content/uploads/2020/06/FPRs-in-the-time-of-COVID-19.pdf).

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