The claim
The FTC’s own summary of what it says was represented, from the first page of the complaint, is that the defendants “misrepresented that non-martial artists could profitably operate one or multiple PMA franchises on a semi-absentee basis working less than 15 hours a week”.
Alongside that, the complaint alleges an initial franchise fee of $49,500 for a single location and a royalty of 7% of gross sales.
Against a $49,500 entry fee, the number a prospect sees for what a studio grosses is not decoration. It is the whole basis of the decision.
The evidence
Everything in this section is either a company figure reproduced in the complaint or an allegation, and each one is labelled.
What the company published
PFG’s 2022 franchise disclosure document, issued 18 May 2022, carried an Item 19 financial performance representation built from 59 franchised studios that were open the whole of the 2021 fiscal year. The complaint reproduces both of its tables at Figure 5, and Table 1 gives three gross-sales averages side by side.
The three 2021 gross-sales averages in one table of PFG's own 2022 disclosure document, and the one that went on the homepage
The complaint states plainly where the homepage figure came from, at paragraph 108: “between 2022 and until at least August 24, 2026, on the homepage of the PMA franchise website, it stated the average 2021 gross sales were $548,345.”
It is worth being precise about what is and is not in dispute here. That $548,345 is a real number from a real table, and the same table prints the all-studios figure one column away. The disclosure document also carried the admonition the Franchise Rule requires: “Some PMA Studios have earned this amount. Your individual results may differ. There is no assurance that you will earn as much.”
The allegation is not that the figure was fabricated. It is about which of three numbers in one table became the headline, and where the sentence explaining that went.
What the FTC alleges the internal records show
The second table on the same page of the complaint covers EBITDA. The disclosure document put the average across all studios at $75,950 and the median at $89,140, with the top 15 at $196,504 and the bottom 15 at negative $15,795.
The complaint then splits the 59 studios a way the disclosure document did not: 38 run by what it calls Legacy Franchisees and 21 by New Franchisees. On that split, paragraph 118 alleges:
A New Franchisee studio earned on average $17,584 in 2021. By comparison, the 2022 FDD stated that an average franchisee studio’s EBITDA was $75,950, because it included both New Franchisee and Legacy Franchisee earnings. In other words, the 2022 FDD overstated what a New Franchisee was likely to earn in EBITDA by $58,366, or by 76.8%.
What the disclosure document said an average studio earned, and what the FTC says new franchisees earned
A new franchisee is exactly the person reading the homepage. The complaint’s allegation is that the one group the disclosure figure was least likely to describe was the only group being sold to.
What the proposed settlements contain
The FTC’s press release of 5 October carries the sub-head: “Proposed settlements recover $1.85 million for injured consumers and give certain franchisees the option to cancel their franchise agreements without penalty.” The Commission vote to file was 2-0.
Read the verb tense in the FTC’s own sentence about what those documents are: “Stipulated final orders have the force of law when approved and signed by the District Court judge.”
They have not been signed. That is not a technicality, and it is the difference between a settlement reported and a settlement in force.
What the evidence supports and does not
It supports that one table in PFG’s own disclosure document contains three different 2021 gross-sales averages, $548,345, $315,850 and $151,484, and that the largest of the three is the one the FTC says appeared on the homepage as the average, with the qualifier in a footnote. Both the figures and the footnote description come from documents, not inference.
It supports that the FTC has formally alleged, in a signed federal complaint, a gap of $58,366 between what the disclosure document said an average studio earned in EBITDA and what it says new franchisees actually earned.
It does not support saying that PFG or Franchise Fastlane deceived anyone. That is the question the case exists to answer and no one has answered it. An allegation in a complaint is the government’s account of what it expects to prove.
It does not support describing $1.85 million as a penalty, a judgment or money recovered. It is a figure in two proposed orders that no judge has signed. Our reading of the docket mirror on 8 October found no entry approving them, and we did not check PACER directly, so treat even that as a mirror and not the court’s own record.
It does not support any claim about what either company says in response. We asked nobody anything, and we will not pretend otherwise. What the companies have said formally is in the proposed orders: they neither admit nor deny the allegations.
It cannot tell you whether a PMA studio is a good or bad business. Nothing in these documents measures that, and the figures stop at the 2021 fiscal year.
Cause of death
Not the number. The scope line.
Every one of those three averages is defensible on its own, and the one in the largest typeface was true of the fifteen studios it described. What the complaint alleges happened is the oldest move in financial-performance marketing: the qualifier that turns a number into a claim about fifteen studios rather than fifty-nine was moved to a footnote at the bottom of the page, while the number stayed at the top.
The lesson generalises past this case and past franchising. Any time you are shown one average, the question is not whether the figure is honest. It is which subset it describes, and whether that subset was chosen before or after somebody looked at the results. A top-15 average is a selection, and a selection made after the fact is a forecast of nothing.
The second lesson is cheaper still: when you are handed a disclosure document, read the column headers before the numbers. Both figures in this autopsy were in the same table, four centimetres apart.
What would change this verdict
- A judge signing the stipulated orders. That would turn proposed terms into orders with the force of law, and the $1.85 million from a proposed figure into an obligation. Until then this autopsy’s stamp stays OPEN.
- A contested outcome. If either company litigates and prevails on any count, the allegations in the complaint about its internal records would have been tested and rejected, and this post should say so.
- The underlying disclosure documents. We did not open PFG’s 2020, 2021 or 2022 FDDs. Every company figure above is as reproduced by the FTC in its complaint. If the originals differ, the originals win.
- A statement from either company. Neither has published one that we found, and if one appears it belongs in this post.
Sources
- FTC press release, “Premier Martial Arts Franchisor and its Former Franchise Sales Organization Settle FTC Charges that the Companies Made Deceptive Claims and Violated the Franchise Rule”, 5 October 2026: ftc.gov
- Complaint for Permanent Injunction, Monetary Judgment, and Other Relief, FTC v. Premier Franchising Group, LLC and Franchise Fastlane, LLC, No. 3:26-cv-00487 (E.D. Tenn.), filed 5 October 2026, 53 pages. Figure 5 and paragraphs 105 to 121 carry every figure used above: ftc.gov
- Stipulated Order for Permanent Injunction, Monetary Judgment, and Other Relief as to Premier Franchising Group, LLC, filed 5 October 2026, with the unsigned “SO ORDERED” block at page 13: ftc.gov
- FTC case page, “Premier Franchising Group & Franchise Fastlane”, case status “Pending”, last updated 6 October 2026: ftc.gov
Both exhibits were drawn from the figures named above, on one scale from zero, and every number in them appears in the cited documents. The bar widths are ours. No figure in this post is this site’s own arithmetic: the $58,366 gap and the 76.8% are the FTC’s, stated at paragraph 118 of its complaint.