How may a franchisor taking advantage of the amended Rule’s disclosure provisions effectively comply with the Item 23 receipt requirement?
The amended Rule permits franchisors flexibility in complying with the Item 23 receipt requirements. Below is the staff of the Commission’s view on three possible alternatives posed by practitioners. A. Use of link to external receipt webpage Section 436.6(d) of the amended Franchise Rule prohibits franchisors from including in any electronic disclosure document external links to materials outside of the disclosure document itself. The first requester proposes an exception to this prohibition for the limited purpose of facilitating compliance with the amended Rule’s Item 23 receipt requirement. Specifically, he proposes that franchisors be permitted to place an icon (such as a “submit” or “submit receipt” button) on the Item 23 receipt page that links it to an external receipt webpage where the prospective franchisee could acknowledge receipt of the document. According to this proposal: • The external receipt webpage would be accessible only from a link in either of the two receipt pag
