Franchise registration renewal season will be here before you know it. Maryland’s Securities Division is getting ahead of the influx of filings by introducing a pilot program, “Fast-Track”, aimed to reduce the volume of applications received between March and May while speeding up the registration process. The program will allow eligible franchisors to file their renewal FDD in two stages, enabling Maryland examiners to comment on a pending application while the franchisor completes outstanding requirements, including audited financial statements or other materials that could otherwise delay submission.

Franchisors hoping to take advantage of the Fast-Track program must: (i) have an FDD currently registered in the State of Maryland; (ii) have a fiscal year ending between December 24th and January 7th; and (iii) not be subject to any pending investigation or enforcement matter with the Securities Division. The program is not available to exempt or initial registrations.

Fast-Track Program Details:

• By February 1, the franchisor will submit their request to enter the Fast-Track program, along with the draft renewal FDD (sans Item 21, financial statements), and ancillary filing materials
• Maryland examiners will review the submission and respond within 15 business days, either granting pre-clearance or issuing comments. In the latter case, the franchisor will have 15 business days to address any deficiencies and submit updated materials to remain in the Fast-Track program.
• By April 10, the franchisor must submit a complete renewal FDD, including Item 21. Maryland examiners will then review and respond to this secondary filing within 10 business days. If there are no deficiencies to be corrected, the filing will be registered by late April.

Maryland examiners may remove a pending filing from the Fast-Track program if the secondary submission includes significant material changes from the draft filing. Removal from the program shifts the application to a standard review queue but does not result in additional filing fees. Maryland’s new Fast-Track pilot program presents an opportunity for eligible franchisors to avoid the annual bottleneck of spring filings. By allowing a two-stage submission process and early examiner review, the program is designed to reduce turnaround times and facilitate smoother renewals for compliant franchisors. Those interested in participating should contact your counsel promptly to meet the February 1 submission deadline and ensure all preliminary materials are in order to fully benefit from this expedited process.