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Identify the arrangement

The item covers compensation or benefits given or promised for public-figure use in the franchise name or symbol, or for endorsing or recommending the franchise to prospective operators. It also addresses relevant management involvement and investment, including the stated value of services.

A public figure can be generally known in the area of the proposed franchise; the definition is not limited to international celebrities. Ordinary consumer advertising should not automatically be treated as franchise-offer promotion.

Sources: Federal Trade Commission: Item 18: Public figures

Separate promotion from delivery

If a presenter appears in recruitment material, state what that person actually does. Promotion, investment and managing training are different roles.

Use the assistance disclosures for support promises and the financial disclosures for financial claims. The public figure’s visibility does not supply that evidence.

Sources: Federal Trade Commission: Item 18: Public figures

Scope

  • This explains the selected federal disclosure item. State and territorial requirements and the terms of the particular offer remain separate.

Next step

Make recruitment statements match the actual public-figure arrangement and the disclosures about role, benefits and involvement.

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(r): FDD Item 18

Federal Trade Commission

Passage, dates and research notes

primary · Item 18: Public figures

The extent to which the public figure is involved in the management or control of the franchisor.

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 18: Public figures Source checked

Item 18 addresses compensation or benefits to public figures for use or endorsement, their management involvement and investment. A recognisable face is not evidence of unit economics, legal compliance or operating support.

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

16 CFR §436.5(r): FDD Item 18
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