Probably the most difficult requirement of franchise sales is the use or nonuse of Item 19 of the UFOC guidelines. This stipulates that no written or oral statement of actual average, projected, or forecasted sales, earnings, or profits may be provided to a prospective franchisee unless properly stated and recorded as directed by item 19. The vast majority of franchisors do not make such earning claims in their UFOC's. 

This lack of disclosure forces the sales department and sales people from making any references to sales, earnings, or profits related to the franchise. This is probably the most controversial and difficult regulation in franchising. Interestingly, if earnings claims are made, then they have to be made in a certain format and they have to be able to be substantiated by information which the franchisor has. The earnings claims also need to be for the general geographic area in which the franchisee would work. For a franchisor without a sufficient operating history, it is difficult to develop earnings claims. Most experienced franchisors do not provide earnings claims because of the stiff requirements associated with the development of earnings claims.