... Further, the franchisor must provide an estimated initial investment for a franchisee to enter into the franchise and it may, at its option, provide a financial performance representation (formerly referred to as an “earnings claim”). Generally speaking, the new sophisticated investor exemptions are as follows:
” Large Investment. The “large investment” exemption exempts from disclosure those arrangements where a franchisee makes an “initial investment” of $1 million or more, excluding (1) the cost of unimproved land, and (2) any investments in which the franchisor (or an affiliate) provides financing. ...