---
title: "Check a same-terms renewal for a written disclosure opt-out"
url: "https://ailawframework.com/practice/franchising-and-distribution/record-a-written-opt-out-of-disclosure-and-the-code-on-a-renewal/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A34-OB20261022-24-US"
practice_area: "Franchising & Distribution"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Check a same-terms renewal for a written disclosure opt-out

> Where the renewal continues without interruption and the new terms do not differ from the original agreement, record any writing the franchisee signed about disclosure.…

Canonical page: https://ailawframework.com/practice/franchising-and-distribution/record-a-written-opt-out-of-disclosure-and-the-code-on-a-renewal/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Franchising & Distribution](https://ailawframework.com/practice/franchising-and-distribution.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | Where the renewal continues without interruption and the new terms do not differ from the original agreement, record any writing the franchisee signed about disclosure. Report that the opened rule contains no franchisee opt-out form for that renewal. Do not draft one. |
| What the lawyer must review | Under 16 CFR 436.1(t), extending or renewing an existing franchise where there has been no interruption is not a sale of a franchise unless the new terms differ materially from the original agreement. Where there is no sale, Part 436 does not require a disclosure document for that renewal. The opened text provides no form on which the franchisee opts out of disclosure for a same-terms renewal. The large-investment acknowledgment in 16 CFR 436.8(a)(5)(i) is an exemption writing for a sale that meets that paragraph. It is not an opt-out of a renewal. The lawyer confirms the terms are the same and that operation was not interrupted. ABA Model Rules 1.1 and 5.3 and Formal Opinion 512 leave that confirmation with the lawyer. |
| Written for | United States |
| Applies to | [Record a written opt-out of disclosure and the Code on a renewal](https://ailawframework.com/practice/franchising-and-distribution/record-a-written-opt-out-of-disclosure-and-the-code-on-a-renewal.md) |

## Checking plan

- What the AI does: Where the renewal continues without interruption and the new terms do not differ from the original agreement, record any writing the franchisee signed about disclosure. Report that the opened rule contains no franchisee opt-out form for that renewal. Do not draft one.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- The opened rule does not give the franchisee a written opt-out of disclosure on a same-terms renewal. Disclosure is not required because that renewal is not a sale, unless the terms differ materially or operation was interrupted.
- The 16 CFR 436.8(a)(5)(i) acknowledgment is a different document. It belongs to the large-investment exemption, not to a renewal opt-out.
- The eCFR page says it is not an official legal edition of the CFR.

## Sources

- [eCFR, 16 CFR Part 436, Disclosure Requirements and Prohibitions Concerning Franchising](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-436) (checked 2026-10-22)
- [eCFR, 16 CFR 436.8, Exemptions from the Franchise Rule](https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-436/section-436.8) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*