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The Operations Manual, Table of Contents

CONFIRMED the registered franchise disclosure document

A prospective Bricks & Minifigs owner, handed the company’s federal disclosure document and told to read it before signing, can turn to the table of contents of the operations manual the company filed inside it. Seven of the nineteen chapters listed there, the operational half of the business, each report that they begin on page 1. None of them can be found. That is one of four ways this single filing contradicts itself, and no outside record is needed to see any of them.

Franchise sales are disclosed this way for a reason. A buyer cannot audit the seller before signing, so the disclosure document, filed with federal and state regulators, is the one instrument a prospective owner is entitled to rely on. Everything below is inside BAM Franchising’s 2025 disclosure, cross-referenced to the version published at the disclosure.

What the disclosure tells a buyer about pricing

Item 11 lists what the franchisor will do for an owner during operation. On pricing it says this, in full:

Later, in the advertising section, the filing is explicit about whether those prices bind:

Those are the disclosure’s representations on the subject. Prices are suggested. A franchisee need not follow them.

The exhibit attached to the same filing

The federal franchise rule requires a franchisor to disclose the table of contents of its operations manual, and the number of pages in it, as of the last fiscal year end (16 C.F.R. § 436.5(k)(3)). BAM complied by attaching that index as Exhibit E, seven pages, titled “Operations Manual Table of Contents.”

Exhibit E lists nineteen numbered chapters. Chapter 14 is Pricing. Beneath it the exhibit names its subsections, and one of them is:

The existence of a standardized pricing policy is therefore not an outside claim about BAM. It is BAM’s own disclosure, filed with the regulators who require it, inside the same document that tells buyers pricing is a suggestion they need not follow. The exhibit does not say what that policy contains. It says the policy exists and has a name.

The chapter as the exhibit prints it also does not number correctly:

Two different subsections carry the number 14.2, and 14.1.1 is filed beneath 14.2 rather than beneath 14.1. Whether the misnumbering originates in the exhibit or in the document it indexes is not established here. What the filed exhibit shows is a pricing chapter whose subsections are numbered twice over and nested under the wrong parent, with every entry reporting page 1.

Seven chapters, each beginning on page 1

Exhibit E carries a page number beside every entry, and for the first twelve chapters those numbers behave normally. Chapter 10 begins at page 102. Chapter 11 at page 118. Chapter 12 at page 132. Individual entries run as deep as page 136.

Then the numbering stops working. Every remaining chapter is reported as beginning on the same page:

The exhibit contradicts itself on its face. A document whose twelfth chapter starts at page 132 cannot have its thirteenth start at page 1. Nothing external is needed to see it, because the two halves of the same page disagree.

The consequence for a reader is practical. A prospective franchisee who opens the filed disclosure to find out how the system handles pricing, purchasing, store buys or inventory is told those chapters begin on page 1, and cannot locate any of them. The seven affected chapters are the operational core of a buy-sell-trade business, and they are the second half of the document. The first twelve chapters, the introductory and descriptive ones, paginate correctly.

What caused it is not established here. A table of contents regenerated without updating its page fields produces exactly this pattern, and that is the ordinary explanation.

A page count the exhibit refutes

The same Item 11 paragraph that attaches Exhibit E also reports its size:

The rule asks for the manual’s table of contents and its total page count. Read as a statement of the manual’s length, 107 pages is contradicted by the exhibit introducing it, which carries references as deep as page 136. Read literally, as a statement about the table of contents itself, it is contradicted by Exhibit E being seven pages long. The sentence does not survive either reading, and the document that refutes it is the one attached to it.

Where this sits

Four contradictions, one filing, no outside source. A pricing representation the filing’s own exhibit names a standardized policy against; a pricing chapter numbered twice over and nested under the wrong parent; a page-number sequence that breaks precisely where the operational chapters begin; and a page count the attachment disproves twice over. The disclosure framework exists because a buyer cannot audit the seller. What is on the record here is the audit the seller performed on itself, and filed. Related material is on the disclosure and the connection board.

In fairness. A table of contents whose page fields stop updating is more likely a document-generation error than a decision, and nothing here establishes otherwise. Standardized pricing on a limited set of items is ordinary in retail franchising; the point is that the filing does not disclose the policy exists. BAM Franchising has not responded to these points, and nothing here is a finding of law.

Primary sources. Every quotation is from the Bricks & Minifigs 2025 Franchise Disclosure Document as filed with state regulators, filing 33584-202504-15: Item 11 paragraphs (3) and (10), the advertising section, and Exhibit E, “Operations Manual Table of Contents,” seven pages. The table-of-contents and page-count requirement is at 16 C.F.R. § 436.5(k)(3). Every allegation referenced elsewhere on this site remains unadjudicated and every person and entity retains the presumption of innocence.

The BAM Map is independent reporting on matters of public concern. Nothing here is a finding of any person’s guilt; the criminal charges referenced are unadjudicated and every defendant is presumed innocent. Sources are linked so readers can check the record.  ·  Home · Map · The law · Bodycam