The Franchise Group at the Federal Trade Commission in all their ego and glory has proclaimed that franchise disclosure laws are Cost Effective. I hate to break it to the FTC, but your comments and court are completely naked. The folks at the FTC are wearing no clothes. In a recent franchise report put out by the commission they actually had the tenacity to say that these rules and regulations in the franchise law are cost effective.

What on Gods Earth are they talking about? How can the FTC purport that as truth? That is a farce indeed. For instance the printing costs alone do not show anything in the way of cost-effectiveness. Printing costs are the real costs after the preparation costs of 25-35k, not including the registration costs and on-going changes which are made every time another brilliant judge in some Kangaroo Court wants to make a statement triggering additional case law and therefore new clauses in the franchisors UFOCs. The whole thing is just a complete joke really. Yet no one says anything, because if you complain about it, you are Unprofessional instead franchisors are to simply accept this and pardon the figure of speech bend over and take it like a man from the parasites of the regulators and the terrorists, extortionists lawyers. (CYA- this is personal opinion, using common phrases and figures of speech, well know in the entrepreneurial sector; those noble innovators who provide and build everything you see, every where you go, anywhere you live and everything you buy).

The cost alone to print UFOCs is not cost effective. What is the real cost. Ill throw out the number $4.65 to print a UFOC, and most franchisors do not print just one at a time, we print 50 or so at time, some franchisors print 250 500 at a time due to the number of potential inquiries. These are 1998 costs, generally UFOCs have gotten bigger since then as lawyers have further put a strangle hold on the industry and without some tort-reform; they will just get bigger and bigger. I imagine they will continue to bulge at the seams as we add more pages due to this Federal Trade Commission future ruling.

Many UFOCs never get used because there is always new case law showing up on the ABA Forum on franchising and so we are constantly modifying them. It makes it hard to lead a franchise company when all the agreements are somewhat different to CYA yourself from the changes caused by litigation in the private sector, apparently franchising has joined the ranks of mold, ADA law, employment law, sexual harassment, wrongful death as a good way to make easy money for lawyers? Think about it, spilt hot coffee, the hamburgers made me too fat, forgot to disclose or mention your dogs name when you were five years old and suddenly and magically a lawsuit. We made 22 changes in the 2002 UFOC for the state of CA for renewal. We had about 10 left over, which became invalid and were be tossed out as the new redlined copy becomes the latest CA version. So really we had $46.50 in throw-aways, and that is just CA, one state. Remember we have 12 viable registration states. So multiply that times twelve and a yearly occurrence. And large franchisors are probably stuck with 10 times that number. Especially those who print 50 or more copies and deliver them to master franchises, who are told to throw them all out and start over every time some new case law shows up or a state registration renewal comes due. Cal-if-forn-ia is not the only registration state, just the most ridiculous one, you would swear that the Liberal crowd in Boston, Merry Land and NY are trying to become close runners up by the proposed franchise legislation and the insanity of their registration requirements. Someone really needs to talk to those folks about what capitalism is, how it works and what is meant by free markets. Any and all UFOCs, which were printed as of this date will most likely be thrown out due to law and rule changes, case law and future possible rule changes here at the Federal Trade Commission. I have talked with some larger franchisors, who claim a $500,000 per year budget in printing. Yah sure, like that is somehow Cost-effective? Of course the way government throws around and wastes money, apparently they believe money grows on trees just like the ones that are cut down to print all this over disclosure. May I ask what happened to the Paper Work Reduction Act? The idea behind it is to streamline, not pass on the problem to the private sector.

Yah, what a joke and we pass this off as responsible government, its time to bring Ronald Reagans ass back down from Heaven and cut out the fat. Cost effective indeed and what on Earth would government know about being cost effective, give me a break. Think about it and thanks for listening.

Lance Winslow

Currently Lance is retired at age 40 and is running an Online Think Tank Forum while traveling North America. Perhaps considering something extremely challenging to do that will exercise his mind and utilize all his experiences, observations and skills. Any ideas?