FDD Item 11 — Training Staff Disclosure Template

Prepared by: Will Frank Date: 2026-05-19 Status: Structure + module-to-staff mapping prepared. Each row’s Time in Position and Years of relevant experience fields require human input from each named person. Cannot be fabricated — these go into a federal disclosure document.

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1. What Item 11 requires

FDD Item 11 requires the franchisor to disclose, for each individual who will lead or supervise the Franchisee Training Program, the following four data points:

• Name of the individual.
• Position / title held with the franchisor.
• Time in position. Years and months in the current position with the franchisor (or any affiliated entity that conducts training).
• Years of relevant experience. Total years of experience in the subject matter the individual teaches, including time at other employers before joining the franchisor.

Per FTC guidance, the disclosure is per-individual, not per-department, and covers each person who actually delivers or supervises training content.

2. The disclosure table (template — pending field completion)

The structure below is ready for counsel. The Position, Modules taught, and module-content mapping are derived from each module’s Section 9 facilitator notes. The Time in Position and Years of relevant experience fields are left blank — each named individual must provide their own data; these cannot be inferred or estimated.

#	Name	Position	Time in Position	Years of relevant experience	Modules / topics taught
1	Jim Frank	Chief Executive Officer, HiON Franchise Group, LLC	_____	_____	M01 §4.3 funding flow; M03 §4.2–4.4 Marks and HiON–Tesla relationship; lead on Item 11 application-demonstration role-play scenarios system-wide; co-lead on Lease Addendum and Site Acquisition modules (M04, M05); FA-side authority on lifecycle events (M15)
2	Joe Lewis	Chief Operating Officer, HiON Franchise Group, LLC	_____	_____	M02 governance and exception-process examples; M03 Marks compliance and audit posture; M03 brand audit panel; M13 Sinking Fund and reporting discipline; M14 compliance and incident-response posture; M15 lifecycle transfer / closure / renewal authority
3	Joe Frank	Operations Lead, HiON Franchise Group, LLC	_____	_____	M01 §4.6 network / NACS, §4.7 24/7/365 and False Call-Out; M03 §4.8–4.10 physical brand execution; M07 construction management and commissioning; M09 staffing and contractor conduct; M10 site-area maintenance, monitoring, fault escalation; M12 vendors and technology
4	Tony Cuomo	Customer Experience Lead, HiON Franchise Group, LLC	_____	_____	M01 §4.6 NACS technical context; M03 §4.1 customer promise; M03 §4.8–4.10 brand design rationale; M03 brand audit panel; M08 launch and local marketing; M11 customer experience, payments, driver support
5	Will Frank	Development Lead, HiON Franchise Group, LLC	_____	_____	M01 structural delivery when CEO not in room; M02 §4.1–4.4 Manual mechanics, exception process; M03 §4.5 Voice, §4.6–4.7 co-branding and creative approval; cross-module curriculum delivery support
6	[External SME — Site Acquisition advisor, TBD]	Contracted advisor	_____	_____	M04 site acquisition + feasibility deep content; M05 lease + Site Host relationship if not led by Jim
7	[External SME — Construction / Commissioning advisor, TBD]	Contracted advisor	_____	_____	M07 commissioning best practices; M06 design / permitting / utility coordination
8	[External SME — Compliance / insurance / risk advisor, TBD]	Contracted advisor	_____	_____	M14 insurance, indemnification, regulatory currency

Item 11 disclosure note — counsel should append: “From time to time, the Franchisor may engage additional individuals or external subject-matter advisors to lead or supplement specific modules. The Franchisor will update this disclosure consistent with FTC and state requirements when material changes occur.”

3. How the table was built

The Position, Modules taught, and topic-mapping columns come from:

• The 15 module files in Curriculum-Rebuild/modules/M01 through M15, specifically each module’s Section 9 · Facilitator notes → SME handoffs subsection. Each subsection identifies which HiON personnel is the right SME for which Section 4 subtopic in that module.
• The HiON leadership structure documented in project memory: Jim Frank (CEO), Joe Lewis (COO), Joe Frank (Operations), Tony Cuomo (Customer Experience), Will Frank (Development).
• The Item 11 input document’s flag (Item-11-Input-for-Counsel.md §8) that external SMEs may be engaged.

4. What must happen before this table is final

Three steps:

1. Each named individual provides their own Time in Position and Years of Relevant Experience. Will Frank circulates a one-page form asking each person to fill their two fields. Allow 1 week for response. These numbers feed directly into a regulated disclosure document; they must be accurate to each individual’s actual history.

2. HiON decides on external SME engagement before first FDD filing. Three external-SME rows (Site Acquisition, Construction/Commissioning, Compliance) are pre-positioned because (a) the rebuild modules in those areas reference depth of operating experience that none of the five HiON staff has explicitly stated, and (b) industry-typical FDD Item 11 staff tables for operator-grade franchises include external advisors. The actual decision — engage external SMEs or not, and who — is Jim’s. If external SMEs are not engaged for cohort 1, rows 6–8 are deleted before filing, and the relevant modules are taught by the named HiON staff.

3. Counsel reviews against Item 11 format conventions in the registration states. Some registration states (CA, NY) have stricter formatting expectations for the Training Staff table — full sentences vs. bullet topics, employment-history disclosure depth. Counsel finalizes column structure.

5. Outstanding question for Jim

The Voice Playbook positions HiON as an audience of sophisticated multi-unit operators who have done this before. A Training Staff table populated only by founder-leadership of an early-stage franchisor can read thin to such a buyer, even when the underlying capability is genuine. Two paths:

• (a) Keep the table to current HiON personnel. Authentic; honest about the company’s stage; vulnerable to “no operator experience on the bench” critique.
• (b) Engage one to three external SMEs with named operating history (Site Acquisition, Construction/Commissioning, Compliance). Adds disclosed operating experience; costs money (advisor retainers); takes time to arrange.

Recommendation: path (b), on the same Voice Playbook positioning logic that drove the Item 11 duration call to Option 2. A sophisticated buyer reads a thin Training Staff table the same way they read a 1.5-day disclosed program — both signal a thinner operating model than the brand is positioning toward.

If Jim chooses (a), rows 6–8 are deleted. If (b), Jim and Joe Lewis identify candidates; engagement happens before first FDD filing.