Item 11 decision memo
Option 2 (~38 classroom hours). Rationale for the FDD draft.
To: Jim Frank From: Will Frank Date: 2026-05-19 Re: FDD Item 11 — Franchisee Training Program duration commitment. Decision needed before Module 1 is finalized for delivery.
The conflict. The FDD is still in draft. Item 11 currently proposes “up to one and a half business days, featuring a minimum of 12 hours of classroom training.” The rebuilt curriculum, drafted against the Operations Manual and now 8/8 diagnostic-passed across all 15 modules, runs ~38 hours classroom + ~14 hours pre-work + ~9 hours OJT. The draft Item 11 and the program contradict each other. Because the FDD has not yet been registered, the question is not whether to amend it — it is what number to set in the first registration. Three paths.
Option 1 — Compress the program to fit 12 classroom hours. Set Item 11 to the current draft number. Cut curriculum depth to fit. Lowest franchisee travel burden, fastest path to open. Why this fails. The Voice Playbook’s core strategic claim is that HiON belongs to the “serious infrastructure” category, not QSR franchising. A 1.5-day program is the QSR signal — sophisticated multi-unit operators read a 1.5-day commitment as evidence of a thin operating model. We’d also undermine our own Manual: §8.3 makes “successful completion” of the Franchisee Training Program a precondition for opening. If the curriculum is too thin to produce a competent operator across lease addenda, fault escalation, Sinking Fund discipline, and lifecycle events, “successful completion” becomes either a rubber stamp or a friction point with franchisees who flunk a meaningful version of it.
Option 2 — Draft Item 11 to disclose ~38 classroom hours. Truthful and unambiguous. Item 11 matches what we actually deliver. No definitional risk about what counts as classroom versus self-study versus OJT. Costs. Higher disclosed Item 7 travel and lodging line. Heavier scheduling ask: roughly four consecutive days in Kansas City rather than 1.5. Because the FDD is still in draft, there is no amendment cost, no state re-registration burden, and no quiet period — we are setting Item 11 for the first time, not changing it. Where it wins. The brand-positioning benefit recurs on every Item 11 a prospect reads. The “longer training scares prospects” objection mostly cuts against the wrong audience — the right buyer reads a four-day program as evidence we know what we’re doing.
Option 3 — Keep the 12-hour classroom envelope; route the remaining ~24 hours into separately-named pre-work and OJT components, with Item 11 drafted to name them. The path the rebuild outline currently recommends. The argument: the curriculum is genuinely blended (every module already has a classroom + pre-work + OJT structure), and Item 11 has columns for each modality. Where it is fragile. It only works if 12 classroom hours reflects what genuinely needs live instructor-led delivery — decision drills, scenario discussion, case work. The outline’s current framing (“tighter live sessions on M01, M02, M04, M05, M07, M11, M13, M14, remainder to pre-work/OJT”) is envelope-driven, not pedagogy-driven. That is exactly the disclosure-minimization pattern FDD examiners in registration states look for. With the FDD in draft, Option 3 also no longer carries any “avoid an amendment” advantage over Option 2 — both options require drafting Item 11 once, the only question is what number we put in the classroom column.
Recommendation: Option 2.
The outline’s recommendation of Option 3 needs pressure on two points. First, its main advantage over Option 2 was always supposed to be a lighter regulatory footprint — but with the FDD still in draft, neither option carries any amendment cost. Both options require drafting Item 11 once, well. Second, Option 3’s remaining advantage — preserving the 12-hour classroom line — is a brand liability under the Voice Playbook’s positioning, not an asset. We do not want to advertise a 12-hour training to operators we are pitching as running serious infrastructure. The shorter number signals the category we are trying to escape.
Option 2 sets Item 11 honestly the first time and produces a disclosure that reinforces brand positioning rather than fighting it. The 4-day-in-Kansas-City logistics are real but solvable through scheduling (cohort calendar published in advance through the Partner Portal, per Manual §8.3) and are a small price for an Item 11 that doesn’t have to be defended in conversation with a sophisticated prospect.
The narrow case for Option 3 over Option 2 would be a separate pedagogical finding — that a meaningful share of the ~38 drafted classroom hours is content that does not actually need live delivery and could be moved to Partner Portal pre-work without loss of competency outcome. If that finding holds module-by-module (not as a top-down envelope decision), Option 3 with rigorously drafted Item 11 columns becomes defensible. I have not done that analysis. If you want it before deciding, I can run it next.
Recommended next step. Confirm Option 2 and brief counsel on the Item 11 language ahead of first FDD registration — or commission the module-by-module live-vs-transferable analysis before deciding between Option 2 and Option 3.