In April 1993, the National Association of Securities Administrators Association ("NASAA") prepared and adopted a revised version of the Uniform Franchise Offering Circular ("UFOC") Guidelines. This was the first major overhaul of the Guidelines since 1975. Later in 1993, the Federal Trade Commission ("FTC") approved the use of the new Guidelines, effective January 1, 1994, in states which do not require registration of the offer and sale of franchises. The FTC Rule mandates disclosure without prior registration in non-registration states.

Even though the FTC has permitted use of documents in the new format since the beginning of 1994, it has not required it. Instead, it instituted a phase-in period that was to terminate on a "revocation date" six months after the date on which the last state requiring presale registration of franchise sales permits the use of the 1993 Guidelines. During the phase-in period, franchisors had the right to continue using offering circulars prepared in accordance with the 1975 Guidelines. After the revocation date, only documents conforming to the 1993 Guidelines might be initially prepared or revised.

On July 28, 1995, New York became the last registration state to approve the use of the 1993 Guidelines. This, in turn, fixed the FTC's revocation date for use of the 1975 Guidelines at:


After that date, only the 1993 version of the UFOC will be allowed for new or amended disclosure documents. Existing "old format" offering circulars may still be used until a material change triggers the franchisor's duty to amend them.