What it is
Item 19 is the one section of the FDD where you're allowed to make financial performance representations — what units actually earn. It's optional, but a program without one is telling candidates "trust us" while showing them nothing.
The rule that governs everyone selling for you
If it's not in Item 19, nobody on your team — and nobody selling for you — can say it. No "our stores do about a million a year" over coffee, no revenue hints in a text, no earnings whispering at discovery day. Statements outside the Item 19 create legal exposure for the franchisor — not the salesperson who said them.
What a strong one looks like
Built from real store-level financials, clearly scoped (which stores, which periods, which costs), and defensible in front of a skeptical attorney. Serious sellers build a strong Item 19 first and then sell strictly inside it — which is exactly how our sales & development engagements are run.
Nothing here is legal advice — Item 19 preparation belongs with your franchise counsel and your accountants.