Legal Tools
How COVID-19
is Impacting State Registration
and Filing Deadlines for Franchisors by Julie Lusthaus As the coronavirus spreads across the U.S., the federal and many state governments are providing relief to businesses by extending the deadlines on various filings. Among the areas receiving attention are state registration and filing deadlines for franchisors. Franchise Disclosure Documents (FDD) must be prepared and
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updated annually within 120 days after the franchisor’s fiscal yearend under the FTC Franchise Rule. Franchisors that ended their fiscal year in December must update their FDDs before the end of April. In addition, some states have their own registration and filing obligations before a franchise can be sold within the state and then renewed annually. State requirements vary. Some mirror
the FTC 120-day rule; others require renewal within a year of the franchisor’s initial registration. Depending on the state(s) in which the franchisor offers and/or sells franchises, the annual renewal filings must be made within 90 to 120 days following the end of the franchisor’s fiscal year or prior to the anniversary of the effective date of the franchise registration.