A franchise examiner is a state regulatory official who reviews Franchise Disclosure Documents submitted in franchise registration states. Examiners analyze the franchisor’s filings, financial statements, agreements, risk disclosures and supporting materials to ensure they comply with state franchise laws. Their review must be completed before a franchisor can legally offer or sell franchises in that state.
Franchise examiners typically work within departments such as a state’s securities division, department of commerce, attorney general’s office or financial regulation bureau.
Franchise examiners play a critical role in franchise consumer protection. Their review:
ensures disclosures are complete and accurate
requires franchisors to correct errors or omissions
prevents misleading or unlawful franchise sales
enforces state specific franchise regulations
safeguards potential franchisees from unfair practices
Their oversight adds an additional compliance layer beyond the FTC Franchise Rule.
Franchise examiners typically evaluate:
the entire Franchise Disclosure Document
audited financial statements
proposed franchise, area development and multi unit agreements
marketing materials used in franchise sales
risk factor disclosures
Item 19 financial performance representations
territory descriptions
ownership and litigation histories
franchisee lists and contact information
Examiners may issue comment letters requiring clarification or revisions before granting approval.
The review process generally includes:
filing submission by the franchisor
initial examiner review
issuance of a comment letter
franchisor’s response with revisions
final review and approval
issuance of a state effective date or registration permit
Communication normally occurs via email or the national filing portal.
Franchise examiners operate in the formal registration states, including:
California
Maryland
Illinois
Washington
Minnesota
Michigan*
Virginia
Hawaii
North Dakota
New York
Rhode Island
Indiana*
(*Some states are registration states with more limited review processes.)
Franchise Registration State
FDD Renewal
Material Change
Franchise Exemption
Notice Filing State
Non Registration State
Stop Order
Franchise Registration Management
Franchise Territory Mapping
Integrated Document Signing
CRM Tools
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Last updated: November 26, 2025
