BAM’s development chief pitched 700 million-dollar stores. BAM’s own disclosure says the average store does half that.

At the same town hall where a franchisee reported stores down more than 20%, BAM’s chief development officer, Darin Hicks, delivered the growth pitch: a “top 100 brand” means “700 stores with an average unit economics of a million dollars,” the math to crack is “an average $800,000,” and BAM keeps awarding franchises. Four and a half months earlier, BAM had put its actual numbers in the disclosure document it gives every prospective buyer: the average store did $507,684 in 2025, the median store $467,539, and even the top quarter of the system averaged $786,268, under the floor he named. The whole fleet is 217 outlets; the pitch requires 700. In the middle of the pitch came one sentence about the people at the center of the crisis: they “wouldn’t have passed scrutiny this year or last year.” The process that awarded them is the process he was selling.

PRIMARY SOURCEBAM’s chief development officer told the assembled network the goal is “700 million dollar stores,” the math to crack is “an average $800,000,” and BAM continues to award franchisesPRIMARY SOURCEBAM’s 2026 FDD, Item 19, issued April 8, 2026: average full-year store revenue $507,684, median $467,539, top-quartile average $786,268; Item 20 counts 217 outlets against the 700 pitchedINFERENCEthe pitch and the admission run on the same instrument: the vetting offered as reassurance to today’s buyers is the vetting that, by his own account, approved the people at the center of the crisis

The pitch

Late in the town hall, a franchisee asked about Corporate placing new stores near existing ones. BAM’s CEO answered on territory, then the marketing lead turned to Darin Hicks, BAM’s chief development officer, for anything he wanted to add. What he added was a sales presentation:

The audience was not an abstraction. Earlier in the same meeting, BAM had told its franchisees that many “have desires to continue to build,” up to “having multiple units,” with tools in place “to enable you.” The room being pitched was the room being sold to: the network is its own expansion market. And the pitch came with a target the stores could feel:

Nobody had asked about kingdoms. The question on the floor was whether Corporate would open stores next to the ones already struggling; the answer reached Papa Murphy’s.

The numbers BAM puts its name to

BAM publishes its real unit economics once a year, in Item 19 of the franchise disclosure document it must give every prospective buyer, filed in registration states. The 2026 edition was issued April 8, four and a half months before this meeting. Its numbers, from BAM’s own reporting:

Set the pitch on top of the filing. The million-dollar store held out as the brand’s destination is roughly double what BAM’s average store actually did. The $800,000 “math” sits above the average of BAM’s own top quartile: not even the best fourth of the system, taken together, clears his floor. The single best store in the system did $1,780,727 last year; how many others reached a million, Item 19 does not say. The pitch needs seven hundred.

Then there is the tier he was careful about, “700 stores with a half million dollars in revenue” carrying a “significant profitability factor” problem, “I’m not trying to discredit anybody with half a million dollars in revenue”: by BAM’s own filing, that is not a tier beneath the system. It is the system. The average BAM store is the half-million-dollar store in the pitch, and the median store does not reach it.

A different company

The pitch’s scale is its own tell. Item 20 of the same document counts 217 franchised outlets at the end of 2025. Seven hundred million-dollar stores means more than three times the stores BAM has, each earning nearly twice what BAM’s average store earns, pitched to a room whose own stores were reporting minus 20%. The distance between the company in the speech and the company in the filing is not a gap. It is a different company.

Where numbers like these are allowed to live

Item 19 also states the rule it lives under:

The town-hall figures differ from Item 19’s. A million dollars and $800,000 appear nowhere in the tables; they were delivered as targets, to a room BAM itself had described as full of owners looking to add units. And BAM’s own document names the only two homes for numbers that differ: an outlet’s actual records, or a written supplement to Item 19. A speech to the assembled network is neither.

And the rule’s definition leaves less room than “goal” suggests. A financial performance representation is “any representation, including any oral, written, or visual representation, to a prospective franchisee… that states, expressly or by implication, a specific level or range of actual or potential sales, income, gross profits, or net profits.” Oral counts. Potential counts. “$800,000, $900,000” and a million dollars of “unit economics” are specific levels of potential sales. A “franchise seller” under the same rule “includes the franchisor and the franchisor’s employees”; a chief development officer is the person that clause describes. What remains is the audience, and the rule sets that bar low too: a “prospective franchisee” is anyone who “approaches or is approached by a franchise seller to discuss the possible establishment of a franchise relationship.” This meeting told its owners that many of them want “multiple units.” The speech closed by inviting them to “reach out” for “an individual conversation.” Whether it adds up to a violation is a finding only the FTC or a court can make, and none exists. The elements, and the words that meet them, are all above.

The admission

Inside the pitch, reassuring the room about who gets in, the development chief said this:

Read it as the room had to. “Players involved in this,” his phrase for people at the center of the crisis, came into the system through BAM’s own award process, the one with the “background check,” the “credit check,” and the selectivity he cited as its proof: “roughly four and a half percent of the people that inquire end up getting awarded franchise rights.” The 4.5% gate offered as reassurance is the gate the “players” passed. His defense of today’s screening is a verdict on the screening that built today’s system, and he kept both halves: the people “we approved four years ago or three years ago” remain, in his telling, “great,” and the ones involved in the crisis would never pass now. To sell the gate today, he had to concede what it let through yesterday.

The denominator of that boast is a form. An inquiry begins at BAM’s franchise page, under the heading “Is the Bricks & Minifigs Franchise Right For You?”: “Complete this form to schedule a time to speak with our team.” The form asks for a name, a phone number, an email, a first-choice city; its first step carries the entire financial screening: two yes-or-no buttons, “I have a net worth of $175k” and “I have $75k in liquid capital.” Nothing is verified. Nothing is uploaded. Click No on either, and the form answers on the spot:

Click Yes twice instead, and the same form moves you along toward a call with the team. That is what “financial requirements” means at the mouth of BAM’s funnel: not a bank statement, a button. The “serious business people” of the speech are, at the door, people who answered Yes twice; the scrutiny begins as an honor system. Measured against that pool, awarding 4.5% is not a bar. It is a funnel with a wide mouth, and the mouth asks you to grade yourself.

The selling has not paused for any of it:

Pass scrutiny, pass muster; the reader has just seen where that scrutiny begins. Restraint was claimed too, phrased in a way that names who holds the throttle: “Matt and Ammon could open it up and we could sign a whole lot more than we’re signing. We don’t.” The restrained pace, per the same disclosure document, went from 82 franchised outlets to 217 in two years, 67 of them opened in 2025 alone. That is the throttled version.

The selling runs through the crisis itself, “we’ve hosted discovery days,” and the buyers still coming are, in his telling, “serious business people that aren’t being duped by… what I’ll call the echo chamber.” The accusations on the public record, the lawsuits, the reviews BAM has scheduled for removal, become, in the pitch, an echo chamber that dupes. In this frame, reading the record is how a buyer gets fooled, and ignoring it is diligence.

The speech ends by naming where the risk lives: “we got to get people that can handle that, that aren’t over their heads in the current situation… Current franchisees, new franchisees, corporate office. We all have to not be over our heads in this.” The stores down more than 20%, in the framing that closes the growth pitch, are a capacity problem: people who must “rise to that occasion.”

Three numbers, one meeting

INFERENCEthe growth pitch and the loss answer are one posture seen from two sides: the number that recruits is spoken freely; the number BAM files is left out of the speech; the number BAM might owe is the one ruled impossible to trace

Hold the meeting’s three numbers side by side. The pitch ran on a million dollars a store. The filing, four months old, holds $507,684. The stores brought minus 20%, and of the three, theirs was the only number the company would not work with: its cause, the CEO said, was too hard to establish. A million for the future, half that in the filing, and the loss in the room left unattributed. The arithmetic BAM performs depends on who is owed the result.

The fair reading, and its limit. A development chief is paid to have ambitions, a target is not a claim that stores earn it today, and BAM’s Item 19 is, to its credit, a substantial disclosure: nine tables of real revenue and margin data, with the warning that “your individual results may differ.” The scrutiny remark can be read as candor about an improved process rather than an admission about the old one, continuing to sell franchises during a controversy is lawful, and self-reported qualification checkboxes are common in franchise lead forms, with verification coming later in a franchisor’s process. The narrow points are the distances: between the numbers in the speech and the numbers in the company’s own filing; and between vouching for the gate and conceding, in the same breath, who once came through it. Whether any statement crossed any rule is a question of fact and law, not decided here; every person named is presumed to have acted lawfully.

Sources. BAM’s Q3 franchise town hall, primary source: the development chief’s growth remarks, the selectivity and scrutiny statements, and the multi-unit framing earlier in the meeting. BAM’s 2026 Franchise Disclosure Document, Item 19 (issued April 8, 2026), primary source: the revenue tables and the Franchise Rule recitation quoted above. On the FTC’s financial-performance-representation rule: 16 C.F.R. § 436.9. On the same meeting’s answer to the stores’ losses: the causality piece. On the buy counter at the center of the disputes: the consignment claim. On the review-removal program: here. On the inquiry funnel and its stated financial requirements: BAM’s own franchise page.

The BAM Map is independent reporting on matters of public concern. Nothing here is a finding of any person’s guilt; every official named is presumed to have acted lawfully. Sources are linked so readers can check the record.  ·  Home · Map · The law · Bodycam