Map a draft franchise disclosure document to the FTC items
Key facts
- Human involvement
- RedLawyer-led
- How AI is used
- List each item in the 16 C.F.R. § 436.4 table of contents and whether the draft has that heading, with a page cite or the word missing. Write no disclosure-document sentence.
- What the lawyer must review
- 16 C.F.R. § 436.2 requires the franchisor's current disclosure document to be furnished at least 14 calendar days before the prospective franchisee signs a binding agreement with, or makes a payment to, the franchisor or an affiliate. Section 436.4 sets out 23 items, from the franchisor and its parents through receipts. The FTC's rule page describes the same document as containing 23 specific items. Section 436.10 does not preempt a state law that gives equal or greater protection, including registration of disclosure documents. You write the document. A gap table is not a franchise disclosure document, and no agency has verified it.
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. |
Checklist
- Trace every relied-on figure to its source, confirm dates and assumptions, and independently recalculate totals or derived amounts.
- Review operative clauses in the complete document, including definitions, cross-references, schedules and inconsistencies with the instructions.
- Verify the applicable jurisdiction and the version of each relevant law, rule or instrument in force at the material time.
- 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.