PRIMARY SOURCE
This is the plain-language edition of the confidential sales deck that was sitting in the open. Same facts, same grade, none of the citations, nothing collapsed into the colored grade boxes. Every claim below is stated again on the cited edition with the document itself attached.
A company that sells LEGO® resale stores as franchises keeps a slide deck it calls the Brand Review, and by the company’s own rules you are not supposed to see it until you have signed a confidentiality agreement. This site saw it without signing anything. The deck was sitting on the company’s own website, no login, nothing to sign, and this site downloaded the whole thing. Here is what the confidential deck does: before a prospective owner ever receives the federal disclosure form, it hands them an outside firm to find their store and an outside company to arrange their money.
Near the end of the deck is a slide the company titles “What’s Next?” It is the company’s own map of the path from a first conversation to a signature, about two months long, laid out in eight steps. Step one is introductions, and it ends with you signing a confidentiality agreement. Step two is the Brand Review, this very deck. So the deck is built to be shown only to someone who has already promised, in writing, to keep it secret. It was not kept secret. It was publicly retrievable from the company’s own web infrastructure, and this site pulled it down with nothing to sign and no one to ask.
One slide is titled “Retail Locations.” It sets the store at 2,500 to 3,000 square feet, at about twenty dollars a square foot a year, and then it hands the buyer a real-estate firm by name: Morrow Hill. The slide says Morrow Hill will find locations, negotiate better leases, cut expenses, and push landlords to pay for the build-out themselves. Under all of that sits one line: “Morrow Hill is available to franchisees at no extra cost.” The firm’s own logo describes it as “Franchise Real Estate Strategies.” This is not a broker the buyer went out and found. It is the one the seller presents, inside the seller’s own confidential deck, to sit across the table from the buyer’s future landlord.
Another slide is titled “Funding Resources.” It lists how these stores are typically paid for: a Small Business Administration loan, a home-equity line, or a ROBS rollover, the arrangement that turns a buyer’s retirement savings into startup cash for the business. Then it names a company and a contact: Tenet Financial Group. The slide says you are welcome to find funding any way you like, and then adds, “We’ll connect you in Step 3, if you’d like.” The real estate is steered on one slide and the money on another, both inside a deck a buyer must sign a secrecy agreement to see.
Here is the part this site marks as an inference, a reading of the sequence and not a proven violation. There is a federal form every franchise company must hand a buyer before they sign, and its whole job is to put relationships exactly like these in writing: any outside firm the company steers you to, and any money the company itself collects from the arrangement. On the company’s own eight steps, that form does not arrive until step three and is not sat down and reviewed until step five. The confidential deck that names the two vendors is step two. So the introductions land first, in confidence, and the form built to account for them in the open comes after. And notice what “at no extra cost” does not settle. It tells you what the buyer pays. It says nothing about what, if anything, the company is paid, and that is the question the federal form exists to answer.
To be fair to the company: recommending a real-estate broker or a funding consultant is common in franchising and is not, by itself, improper, and asking for a confidentiality agreement before a sales presentation is ordinary practice. “At no extra cost” to the buyer may be exactly true. Nothing here shows the company is paid a cent by either firm, or that its federal disclosure form leaves either one out; that form is its own record, and the company is presumed to have acted lawfully.
Read the order the company wrote for itself. Sign the secrecy agreement first. See the deck that names your real-estate firm and your funding company second. Receive the federal form built to account for them third. The confidential document came first, the public one came after, and the confidential one was sitting on the company’s own website in plain sight the whole time.
Where this comes from. One primary source carries this piece: the company’s own recruitment deck, the Brand Review, dated April 2022, publicly retrievable from its own website and posted in full, all twenty-one slides, on the cited edition. The quotations are read straight off its “What’s Next?”, “Retail Locations,” and “Funding Resources” slides. What the federal disclosure form is required to contain comes from the Federal Trade Commission’s franchise rule. Both are linked from the cited edition.
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