Check financial performance representations against Item 19

Key facts

Human involvement: RedLawyer-led
How AI is used: List every sales, income, gross-profit or net-profit figure in the draft or the sales pack, the page, and whether it appears in Item 19. Collect the documents the draft cites as support. Write no earnings sentence.
What the lawyer must review: 16 C.F.R. § 436.1(e) defines a financial performance representation to include an oral, written or visual representation of a specific level or range of actual or potential sales, income, gross profits or net profits. Section 436.5(s) and § 436.9(c) require a reasonable basis and written substantiation when the representation is made, and require it to be in Item 19. Section 436.9(d) requires that substantiation be made available to the prospective franchisee and to the Commission on reasonable request. You decide whether the basis is reasonable. A new franchisee's results may differ; the rule requires that admonition.
Written for / version: United States versionUSCth

Who does what

Who does what
Role	What they do
Assistance	Supporting preparation only. Limit any support to organising, indexing or comparing the source material. Confirm the tool’s capability and permitted scope. The tool writes nothing into the document. Substantive advice, judgement and any restricted content remain with the responsible human.
Lawyer	Perform the substantive analysis and decisions. Independently check any permitted supporting work and approve the exact output for its intended use.

Trace every relied-on figure to its source, confirm dates and assumptions, and independently recalculate totals or derived amounts.
Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.