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NASAA Implements E-filing Procedures for FDD Filings

By Ania Gonzalez

In a step aimed at eventually allowing franchisors to make one filing of their disclosure documents for all states, the North American Securities Administrators Association (“NASAA”) has expanded its Electronic Filing Depository (“EFD”) beyond securities filings to now accept state franchise filings. The EFD system will allow filers to submit multiple state filings and pay filing fees in one place. Although not all registration and business opportunity states have agreed at this time to accept filings via the EFD system, filers will likely find that this system will create efficiency in the filing process.

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Could It Really Be Time Already to Amend Your FDD?

Most franchisors completed and filed their franchise disclosure documents in the last ten weeks, and the last thing they will be thinking about is stopping sales to amend that document so soon after renewal. However, under both state and federal law, there is an obligation to amend as material changes occur in the information disclosed in the FDD, and recent events, including COVID-19 and civil unrest, may have created events in your system that require amendment at this time, or could soon require an amendment.

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Attorney Ania Gonzalez Joins Franchise Team

The franchise team would like to welcome its newest attorney Ania Gonzalez. Ania Gonzalez graduated from Mitchell Hamline School of Law last year after working at Larkin Hoffman as a summer associate through law school. Prior to attending law school, Ania served as an in house paralegal and held various other positions within the legal department at Great Clips, Inc., a national franchisor.

2020 Legal Eagles 

We are also pleased to announce that five of our franchise attorneys were recognized this spring as 2020 Legal Eagles by Franchise Times. They are Joe Fittante, Chuck Modell, Sawan Patel, Jim Susag and Susan Tegt. Joe and Chuck are members of the Legal Eagles Hall of Fame, having been recognized for more than ten consecutive years. 2020 marks the first year that Sawan and Susan were recognized, highlighting the strength, depth and growth of our franchise practice.

Susan Tegt to Present on Franchise Business Valuation Damages

Susan Tegt is currently working on a paper covering franchise business valuation damages in litigation, which she will present as a panelist at the ABA’s Annual Franchise Forum in October in Arizona.

Community Service 

Melissa Bayne Receives Bob Hoffman Community Service Award

Larkin Hoffman is pleased to announce that Melissa Bayne has been honored as the firm’s recipient of the annual Bob Hoffman Community Service Award. The annual award is presented to an employee who most exemplifies the spirit of service to the community that was established as a guiding principle for the firm by our late founder Bob Hoffman. Bob built his reputation not only as a great real estate and land use attorney but also as a giant in community service. Throughout his long career, Bob helped establish and oversee many important nonprofit organizations.

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Franchising with Larkin Hoffman

If you are interested in franchising your business or would like to know more about franchising, please visit our website for additional information and resources.


Summer 2020

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Larkin Hoffman provides counsel to a wide variety of ‎organizations, from ‎small businesses and nonprofits to  Fortune 500 companies, in ‎many areas of practice including ‎corporate and governance matters, litigation, real ‎estate, government relations, labor and employment, intellectual property, ‎information technology, ‎franchising and taxation. The firm also serves the needs of individuals in many ‎areas ‎including trusts and estates, personal injury and family law.


This newsletter is provided as a service to our clients and firm associates. While the information provided in this newsletter is believed to be accurate, it is general in nature and should not be construed as legal advice.