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The Suspension of Coordinated Review: A Giant Step Backward on the Road to Uniformity

By Rupert M. Barkoff
August 31, 2007

In a disappointing announcement released on Aug. 6, 2007, Dale Cantone, chairman of the Franchise and Business Opportunity Project Group of the North American Securities Administrators Association, informed the franchise bar that the state authorities that participate in the coordinated review program ('Coordinated Review') have suspended the program until further notice. The announcement also stated the franchise administrators would re-evaluate whether to reintroduce the program after July 1, 2008.

Under the now-suspended Coor- dinated Review program, franchisors would submit franchise registration applications for multiple states, up to 11, in one package, and one of those registration states would be assigned the task of coordinating the registration process. The comments of the regulatory officials for each state in which registration applications had been made were consolidated, and the franchisor or its counsel would receive one letter describing the deficiencies noted by all the state examiners. In curing the deficiencies, the franchisor or its counsel would deal only with the one designated representative of the state regulatory authorities as the franchise registration applications moved forward.

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