The Federal Trade Commission is assisting competitor to cheat and encouraging this unethical behavior thru their disclosure rule on franchisors. Competition in the market place is far more competitive and the stakes are high enough that Over Disclosure Regulatory Rules cause competition to take the advantage and cheat. And before you say I am off base on these comments, let me tell you that 20% of every single inquiry to buy our franchise comes from a competitor. Thats right 20%.

So with 70% misrepresenting themselves on applications (consumers often lie about their financial where with all) and 20% being competitors, that leaves 10%. Only one in ten is actually a possibility of becoming a franchise buyer and then they have to like us. One in ten is not a good ratio. That would mean out of twenty inquiries that we contact and talk to we would send out 18 UFOC franchise disclosure documents in vain at a cost of $8.00 or $144.00. That is not cost effective for a small franchisor and it when multiplied times ten is not cost-effective for large ones either. Please, oh brilliant grand Pooba, at the Federal Trade Commission enlighten us as to how this is so darn cost-effective will you? After all this is what they proclaimed in the most recent franchise regulatory report on the franchising industry.

Well the current franchisees, the consumers pay for it in the market place due to competitive information leakage and we as franchisors pay for it in real time lost and $144.00 per 20 leads. For our company that is times five per week or $720.00 per week and over a year you just added $37,440.00, and just think we are only getting 100 leads a week, what about those who spend a lot in advertising their franchises, what are their costs? And here is one for the Liberals out there reading this who want to save the planet by stifling the free enterprise that our ancestors died to protect and give you the standard of living you now have. Our franchise agreement and UFOC with attachments was 115 plus pages in 1995, some were 235 pages at that time. Other franchisors have larger documents. Companies like Dwyer, Grow Biz, Service Master, etc., have over 280 pages with all the disclosures and attachments.

So how many trees are we going to cut down to disclose people who are not even legitimate, do not have the money, are simply looking for free information to attack their competitors? Yes we can cut down the number by further scrutinizing the buyers, who are more and more reluctant to give out personal information in the first place because of the Federal Trade Commissions failure to curb identity theft. If you think my figures are too high you are wrong because long about June 2002 the United States Post Office is raised rates and there is talk they are going to raise them again in 2005? Why? Because people are using SPAM instead (which is costing American Business 35 Billion a year in lost productivity, wake-up FTC), because the Federal Trade Commission has not been able to stop it and therefore the junk mail or commercial mail that pays the bills at the USPS is dwindling. Did you know that $37,000 pays for our entire annual meeting for our franchisees, yet this over disclosure you call cost-effective is eating up real profits and monies we could use helping our franchisees.

Where will I as an entrepreneur cut costs to cover this increase in paperwork that the added pages in the UFOC will need when the Federal Trade Commission enacts these additional rules? Hmm? How nice of the Federal Trade Commission comment on my costs and the cost-effectiveness of the insanity of over disclosure? How dare they copy the comments of Lawyers who specializing in suing franchisors as factual, this shows how out of touch our regulatory bodies are and it is unforgivable and unacceptable, we need to take these disclosure laws back to the drawing board. These current disclosure laws and this trend is a plague against America, which more resembles a Smallpox laced Ebola virus than anything else.

The Federal Trade Commission needs to think on these things before making any more laws or franchise rules.