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When on-site supervision by the owner is not required

Where personal on-premises supervision is not required, Item 15 asks for the following information about the operator (the franchisee). These questions describe your offer; they are not conditions shared by every franchise.

  • For an individual franchisee, whether you recommend that individual’s on-premises supervision.
  • Limits on whom the franchisee may hire as the on-premises supervisor.
  • Whether that supervisor must successfully complete your training programme.
  • For a company or other business-entity franchisee, the ownership share (equity), if any, the supervisor must hold in the operating business.

Sources: Federal Trade Commission: Item 15: Participation in actual operation

Explain manager restrictions separately

Item 15 also requires disclosure of restrictions the operator must impose on its manager, such as confidentiality or a stated noncompetition restriction. That duty is not limited to the no-personal-supervision situation. Disclosure does not establish whether a restriction is enforceable under other applicable law.

Sources: Federal Trade Commission: Item 15: Participation in actual operation

Check the job you are promising can be staffed

For example, an owner staying in Singapore may plan to hire a U.S. manager. Check the actual training, ownership and replacement conditions before assuming any experienced employee can cover an absence. Budget salary, employer costs, benefits and backup cover. Permission to use a manager does not pay for one; employment and work-permission questions remain separate.

Sources: Federal Trade Commission: Item 15: Participation in actual operation

Scope

  • This explains the federal disclosure item, not whether a particular staffing arrangement or manager restriction is permitted under every applicable law.

Next step

Before describing the offer as manager-run, make the participation, supervisor and replacement conditions match the operation you will actually support.

Sources & review notes

Federal Franchise Rule

FTC overview · Compliance Guide · Guide PDF · Current regulation

The Compliance Guide is May 2008 explanatory guidance. The current regulation and later official updates control current requirements and dollar amounts; state and territorial rules are separate.

The source records distinguish access dates from substantive review dates. Updating an explanation does not itself recheck the law.

16 CFR §436.5(o): FDD Item 15

Federal Trade Commission

Passage, dates and research notes

primary · Item 15: Participation in actual operation

Disclose the franchisee's obligation to participate personally in the direct operation

Accessed: 2026-11-12T20:51:48.875978+00:00 · Meaning reviewed: 2026-11-12 · Next review target: 2026-12-12

Current substantive item read in full from current eCFR. This guide explains selected management implications; it is not a substitute for all prescribed disclosure text.

16 CFR §436.6: FDD preparation and records

Federal Trade Commission

Passage, dates and research notes

primary · section-436.6

Respond fully to each disclosure Item.

Accessed: 2026-11-12T20:51:48.875978+00:00 · Meaning reviewed: 2026-11-12 · Next review target: 2026-12-12

Current eCFR displayed through 2026-11-09; eCFR is authoritative but not the official legal edition.

Detailed rule records (1)
FDD Item 15: Participation in actual operation Source checked

Item 15 addresses personal participation requirements or recommendations and applicable on-premises supervision, manager training or equity conditions. Review both written agreements and practice. A promise that an owner can remain abroad must fit the actual staffing obligations.

When to check: Preparing, updating or comparing an FDD. Source review: 2026-11-12.

16 CFR §436.5(o): FDD Item 15
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