Record a request for the franchise disclosure document before signing

Key facts

Human involvement
YellowClose supervision
How AI is used
Record the date of the request, what was asked for, the date anything was furnished, and whether the file includes quarterly revisions. Do not decide whether the request was reasonable.
What the lawyer must review
16 CFR 436.9(e) makes it an unfair or deceptive act to fail, upon reasonable request, to furnish the disclosure document earlier in the sales process than 16 CFR 436.2 requires. 16 CFR 436.9(f) makes it an unfair or deceptive act to fail, upon reasonable request, to furnish the most recent disclosure document and any quarterly updates before the prospective franchisee signs. 16 CFR 436.7 requires a revised document within 120 days after the fiscal year closes, and quarterly revisions for a material change within a reasonable time after each quarter, given with the document for the most recent period available. The lawyer decides whether the request was reasonable and whether what was sent meets those rules. ABA Model Rules 1.1 and 5.3 and Formal Opinion 512 leave that decision with the lawyer.
Written for / version
United States versionUS

Who does what

Who does what
RoleWhat they do
AssistanceDo not begin AI assistance until the responsible lawyer has defined and confirmed its permitted scope.
LawyerSet the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output.

Checklist

  1. Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
  2. Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.

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