Earlier this month we posted about the recently released proposed commentary on Item 19 Financial Performance Representations. This is a reminder to everyone that the drafter, NASAA's Franchise and Business Opportunity Project Group, are accepting comments through November 2, 2015. Dale Cantone of the Maryland Securities Division and a member of the Project Group, was a presenter of the seminar on "Recent Changes and Hot Issues in Federal and State Franchise Regulation" at the ABA Forum on Franchising this year in New Orleans and provided his recommendations on how to provide useful comments if you have not given the Project Group your thoughts yet. Mr. Cantone stated that the most useful way to address your concerns to the proposed commentary is to frame the response by saying "The commentary does not properly address 'X' and here are the real world situations why. . ." Mr. Cantone doesn't say that he will necessary agree with you but it will make it much easier to evaluate the strength and accuracy of your comments and is the best way of getting your point across.
To have your voice heard send your comments to Dale Cantone, Chair at dcantone@oag.state.md.us or NASAA Legal Department at cs@nasaa.org. A copy of the proposed commentary can be found here.
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