The FTC prescribes this form — the layout isn't ours to invent. Delivered at masterclass registration, ≥7 days before anyone can pay. It's the asset the competitor doesn't have, and leading with it is the single cheapest credibility play in the funnel.
1. IDENTIFYING INFORMATION
Seller: [LEGAL ENTITY NAME — pending]
Address: [address] · Phone: [phone]
Salesperson: [name] · Date: [date furnished]
2. EARNINGS CLAIMS
Has this seller made a claim about how much money you can earn?
☑ YES ☐ NO
If yes, the seller must give you a separate paper called an "Earnings Claim Statement."
3. LEGAL ACTIONS
Has this seller, its affiliates, or key personnel been the subject of a civil or criminal action for misrepresentation, fraud, securities law violations, or unfair or deceptive practices in the past 10 years?
☐ YES ☐ NO [MITCH TO ANSWER — if yes, attach the list]
4. CANCELLATION OR REFUND POLICY
Does the seller offer a refund or cancellation policy?
☑ YES ☐ NO
If yes, the terms must be attached.
5. REFERENCES
A list of the 10 purchasers nearest to your location (or all purchasers, if fewer than 10 nationally):
[LIST — see cold-start note below]
Note: If you buy a business opportunity from this seller, your contact information may be disclosed to other buyers in the future.
You cannot say "brokers earn $X" unless you can show what percentage of your actual brokers earned $X. Not what's possible — what happened. That single requirement is why the calculator's numbers are placeholders and why "pays for itself at account #1–2" got cut from email D2.
Blocks: calculator engine · webinar Secret #1 · email D2 · every ⚠️ line in the prototype. Owner: Mitch's real numbers.
A brand-new program has zero prior purchasers — so you list everyone who exists, which at launch is nobody, then a handful. Cohort 1 becomes the reference list handed to cohort 2 prospects.
Strategic consequence: the founding cohort should be people who will happily take a stranger's phone call. That's a selection criterion, not an afterthought — and it's another argument for hand-picking the first group.
Also: buyers must be told at signup they may be listed → goes in the enrollment agreement.
Ten-year lookback on the company, affiliates, and key personnel — fraud, misrepresentation, securities, deceptive practices. Worth asking plainly before the attorney does. A clean box here is a selling point; a surprise here mid-engagement is expensive.
The rule isn't triggered by "paid program + income talk." It's triggered by business-assistance representations — promising to provide locations, outlets, accounts, or customers, or to buy back output.
| Tier | Promises appointments/accounts? | Likely covered? | Cost of the 7-day gate |
|---|---|---|---|
| Silver $995 training + certification + community | No | OPEN QUESTION | High — it's the volume lane |
| Gold $4,995 | Yes — appointments | Almost certainly | Zero — already application→call |
| Platinum $9,995 | Yes — appointments + mentors | Almost certainly | Zero — already application→call |
If Silver is out of scope federally, the 7-day gate confines to Gold/Platinum and the Silver checkout runs with no waiting period for anyone. Two guardrails survive either way:
Build to full coverage now (the plan does). The attorney confirms; they don't retrofit. If the answer comes back favorable, we get speed back for free. If it comes back unfavorable, we lose nothing because we already built for it.
| Step | Implementation |
|---|---|
| Delivered at | Masterclass registration — email B1 |
| Format | Hosted PDF link, not an attachment — attachments hurt deliverability, and a tracked link gives cleaner evidence anyway |
| Evidence | Send + click both stamp disclosure_delivered_at in GHL |
| Drives | UNLOCK = max(webinar_end, disclosure + 7d) → checkout gate + all Sequence D timing + retargeting windows |
| Gold/Plat path | Disclosure re-confirmed at application; the closer call that takes payment or signature books ≥7 days after |
| Language | Must be in the language of the sale → ES version required before any ES traffic |
| Attorney confirms | Electronic delivery satisfies the rule · the calculator stays a pre-offer asset · FL registration thresholds |
This prototype is a structural draft for attorney review — not legal advice, and not a substitute for counsel. Nothing here ships without a biz-opp attorney's sign-off, per standing rule #5.