Having been in the franchising industry for some time now, I always find it fascinating when a regulator arbitrarily decides that we need more laws. As if we do not have enough laws impeding commerce there is always some regulator somewhere who says we need more rules. I cannot think of any reason why unless maybe the work for Al Queda and want to cripple America’s economic might; no maybe they do not work for the International Terrorists group. Maybe they just want to insure job security now and later when the get a real job in the private sector defending businesses against the insanity of government regulations?

So you think I am anti-consumer? No, not even close, I love my customers and I do not wish to over charge them to make up for all the money I spend in complying with bogus regulations, which help no free man or free enterprise entrepreneur or corporation. It is for this reason that I am commenting on the Use of the words “Cost-Effective” when discussing the current Franchise Disclosure Documents in the Federal Trade Commission’s report on franchising.

I first would like to formally announce that entrepreneurs when commenting on public regulatory policy should in fact forgo the niceties and compliments that so often accompany letters to the Federal Trade Commission. I do not believe they are deserved, I sincerely hope the Commission understands the absurdity of the bureaucracy they create and purport as Justice. I believe professionalism and respect must be earned, I do not feel the commission has ever earned that, nor do I believe they are capable of earning such respect after 15 years of studying the Franchising Division of the Federal Trade Commission. In my opinion the Federal Trade Commission’s Franchising Division Efforts to the common good of America would better be classified as far closer to International Terrorism than anything resembling Truth, Justice or the American Way or the contrived notion of supporting free markets.

What is the Federal Trade Commission’s justification for further rule making in franchising and specifically in this letter on a comment made, found on page 21 of the special franchise report concerning “Cost-Effective” nature of the disclosure documents themselves. My concerns come from many different directions and the costs associated with them. Including over all costs to the country as a whole in economic factors such as; Tax Base Loss, Lack of Job Creation, Stifling of Innovation and cumulative effects of over disclosure, which are currently in play within the Franchise Rule. The real costs to franchisors in printing, ability to deliver, loss of proprietary information to competition, preparation, registration and up keep of these disclosures.

I would also like to touch on the fact that all costs associated to the disclosure process and rules are passed on to the very consumer we are supposedly are trying to help, thus making a franchise purchase harder, less inviting and often unattainable. Every entrepreneur knows that through documented real world reality based reasoning and observation that there is no way in hell over disclosure requirements in franchising are cost effective. There is absolutely, positively no possible way in which anyone might conclude that this current franchise rule and the 200 plus pages of disclosure which are now required to stay within the bounds of compliance are necessary or in any way Cost-Effective in the franchising industry and if the Federal Trade Commission would wake up, they might be able to see the absurdity of their over regulations. Think about it.