Comment from American Association of Franchisees and Dealers (AAFD)

Summary: The American Association of Franchisees & Dealers (AAFD) supports the Department's effort to establish a clear and predictable joint employer standard. They argue that a stable rule is necessary to prevent franchisors from withdrawing essential support resources from franchisees due to fear of liability, and they advocate for a standard based on direct and immediate control over essential employment terms rather than reserved contractual rights or economic dependence.