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In general, commenters were supportive of the proposed rule changes and praised the FTC for its detailed approach. An introductory statement in the comment from the law firm Kaufmann, Feiner, Yamin, Gildin & Robbins LLP (New York) called the Staff Report “a remarkable effort to ascertain, and as prudent, incorporate … the desires, needs, and policy positions both of franchisors who will be regulated by the forthcoming revised Franchise Rule, and franchisees whose interests are sought to be protected and advanced thereunder.”
One indication of the overall positive reaction to the proposed changes came in the comments of the North American Securities Administrators Association, Inc. (NASAA), the organization that spearheaded the writing of the UFOC in 1993. “NASAA agrees with Commission staff that the additional disclosures suggested in the Staff Report would benefit prospective franchisees,” NASAA wrote. “We also agree that some disclosures currently required in the UFOC Guidelines could be stated more clearly, and we concur with many of the clarifications which the Commission staff proposed.” NASAA added that its members who oversee franchise issues at the state level support harmonizing the UFOC with the Franchise Rule when the Rule is completed.
Why is it that those who are best skilled at advocating for others are ill-equipped at advocating for their own skills and what to do about it?
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
Active reading comprises many daily tasks lawyers engage in, including highlighting, annotating, note taking, comparing and searching texts. It demands more than flipping or turning pages.
Blockchain domain names offer decentralized alternatives to traditional DNS-based domain names, promising enhanced security, privacy and censorship resistance. However, these benefits come with significant challenges, particularly for brand owners seeking to protect their trademarks in these new digital spaces.