Comments to the Commentary: Fisher Zucker’s Response to NASAA
As we mentioned in a previous blog post, the North American Securities Administrators Association (“NASAA”) published a notice of request for public commentary regarding financial performance representations (“FPRs”) that franchisors disclose within Item 19 of their franchise disclosure documents (“FDDs”). The request by NASAA was a follow up to a similar request they made a year ago. In both requests, NASAA has sought feedback from the public regarding a proposed
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