FDD Item 11 is where the franchisor describes the support it will provide before you open and throughout the life of the franchise relationship. This includes site selection assistance, construction guidance, initial training, ongoing field support, marketing programs, and technology systems. The critical question that most prospective franchisees fail to ask is whether these support commitments are contractual obligations the franchisor must deliver, or merely descriptions of what the franchisor may provide at its discretion. At Lopes Law LLC, we analyze every word of Item 11 in our $3,000 FDD validation review, because the difference between “shall” and “may” is the difference between a binding promise and a brochure.

This guide explains what Item 11 is required to disclose, how to interpret the language, what questions to ask during franchise validation, and how to evaluate whether the support justifies the fees you will pay.

What Does Item 11 Require the Franchisor to Disclose?

The FTC Franchise Rule requires Item 11 to be divided into two main sections: the franchisor’s obligations and assistance before the franchise opens, and the franchisor’s obligations and assistance during the operation of the franchise. Each section must describe the specific services the franchisor provides and indicate whether those services are required or discretionary.

Pre-Opening Assistance

The pre-opening section typically covers the following areas. Site selection is the first major support function. Some franchisors provide extensive site selection services, including demographic analysis, traffic studies, and lease negotiation assistance. Others simply approve or reject sites the franchisee proposes. The level of site selection support varies dramatically between franchise systems and is one of the most important pre-opening services, because a poor location is the single biggest predictor of franchise failure.

Construction and buildout guidance covers the franchisor’s role in overseeing the design and construction of the franchise location. Some franchisors provide architectural plans, approved contractor lists, and project management oversight. Others provide only general specifications and leave the details to the franchisee. The level of construction support directly affects whether the project stays on budget and on schedule.

Initial training is typically the most detailed section of Item 11. The FDD must disclose the length of the training program, the subjects covered, the location where training is conducted, and the experience of the training instructors. Training durations range from 1 week for simple concepts to 18 months for complex systems. All training-related expenses (travel, lodging, meals, wages for any employees the franchisee sends to training) are almost always the franchisee’s responsibility.

Ongoing Assistance

The ongoing assistance section describes the support the franchisor provides after the franchise opens. This is where the “may” versus “shall” distinction becomes most important, because this is the support you will rely on for the 10- to 20-year term of the franchise agreement.

Field support typically involves periodic visits from franchise business consultants (FBCs) who review operations, provide coaching, and identify compliance issues. The frequency of field visits ranges from monthly for new franchisees to annually for established operators. Some franchise systems have dedicated FBCs assigned to specific territories; others have a small team covering a large number of locations.

Marketing and advertising support includes the management of the national advertising fund, coordination of local advertising cooperatives, creation of marketing materials, and digital marketing programs. The advertising fees you pay (typically 2% to 4% of gross sales, disclosed in Item 6) fund this support. However, the quality and effectiveness of the marketing programs vary enormously between franchise systems.

Technology systems include point-of-sale systems, customer relationship management platforms, online ordering, mobile apps, and data analytics tools. The franchisor typically specifies which technology platforms the franchisee must use and charges ongoing technology fees (disclosed in Item 6). The level of technology support ranges from full management by the franchisor to basic helpdesk access.

Why the Difference Between “May” and “Shall” Matters

This is the most important concept in Item 11 analysis, and it is the area where our clients at Lopes Law LLC most frequently express surprise.

When an FDD states that the franchisor “shall” provide a service, the franchisor is contractually obligated to deliver that service. If it fails to do so, the franchisee has a basis for a breach of contract claim. When the FDD states that the franchisor “may” provide a service, it is entirely at the franchisor’s discretion. The franchisor can choose to provide the service today and discontinue it tomorrow without any legal consequence.

Many franchise sales presentations describe extensive support programs that, when you read the FDD carefully, are described using “may” language. A franchisor might tell you during Discovery Day that “we provide dedicated marketing support for every new location,” but Item 11 might say “the franchisor may, at its sole discretion, provide marketing support for new franchise openings.” These are fundamentally different commitments.

A Client Scenario: When “Support” Turned Out to Be Discretionary

A client engaged our firm to review the FDD for a children’s education franchise. The franchise fee was $35,000, the total Item 7 investment was approximately $200,000, and the franchisor’s sales team emphasized the comprehensive marketing and lead generation support included in the franchise relationship. During Discovery Day, the franchisor’s marketing director presented a detailed digital marketing program that included search engine optimization, pay-per-click advertising, social media management, and a proprietary lead generation platform.

When we reviewed Item 11, we found that the marketing support was described almost entirely in “may” language. The FDD stated that the franchisor “may provide digital marketing support,” “may maintain a lead generation platform,” and “may coordinate local advertising campaigns.” The only binding marketing obligation was that the franchisor would maintain a national website featuring all franchise locations.

We advised the client to validate the marketing claims directly with existing franchisees using the contact list in Item 20. The validation calls revealed that the digital marketing program had been significantly scaled back over the previous 12 months due to cost-cutting at the franchisor level. Several franchisees reported that the lead generation platform was no longer being actively maintained, and local marketing support had been reduced from quarterly campaigns to an annual template package.

The client ultimately decided not to invest, because the marketing support that had been a primary factor in the investment decision was discretionary rather than contractual, and current franchisees confirmed it was being reduced rather than expanded.

How to Evaluate Whether the Support Justifies the Fees

The fees you pay to the franchisor, disclosed in Items 5 and 6, are the price of the franchise relationship. The support you receive, described in Item 11, is a significant part of what you get in return. Evaluating whether the support justifies the fees requires comparing what the franchisor promises against what it actually delivers and what those services would cost if you sourced them independently.

• Training value: What would comparable training cost if you purchased it independently? Industry-specific training programs from third-party providers typically cost $5,000 to $15,000. If the franchise provides $10,000 worth of training value and charges a $35,000 franchise fee, the training alone does not justify the fee. The fee is also paying for the brand, the system, and the operating model.
• Marketing value: Calculate the total advertising fees you will pay over the franchise term (typically 2% to 4% of gross sales annually for 10 to 20 years). For a franchise generating $500,000 in annual revenue with a 3% advertising fee, you will pay $15,000 per year, or $150,000 to $300,000 over the franchise term. Evaluate whether the marketing support you receive is worth that investment compared to managing your own marketing.
• Technology value: Compare the franchisor’s technology fees against the cost of equivalent systems from third-party providers. If the franchisor charges $500 per month for a POS system that costs $200 per month from an independent provider, the markup represents profit for the franchisor rather than value for the franchisee.
• Field support value: Determine how many field visits you will receive annually and what those visits cover. If the franchisor provides 2 field visits per year consisting of a brief operational review, the practical support value is limited.

At Lopes Law LLC, our $3,000 flat-fee FDD validation review includes this cost-benefit analysis, comparing the total fees against the contractual support obligations to help our clients make informed investment decisions. For more on our review process, see what to expect from an FDD review.

What Questions Should You Ask Current Franchisees About Item 11 Support?

The most reliable way to evaluate Item 11 claims is to ask current franchisees directly. During your franchise validation calls, focus on these specific questions:

1. How often does a field consultant visit your location, and what do they actually do during the visit?
2. How responsive is the franchisor’s support team when you have an operational question or problem?
3. Did the initial training adequately prepare you to operate the franchise?
4. Does the franchisor’s marketing program actually generate leads and customers for your location?
5. Have any support programs been reduced or eliminated since you joined the system?
6. If you could change one thing about the franchisor’s support, what would it be?

The answers to these questions will give you a far more accurate picture of the franchisor’s actual support than reading Item 11 alone.

Frequently Asked Questions About FDD Item 11

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Last updated: March 13, 2026