What is the Focus Cfo policy regarding Business Associate Agreements (BAA) prepared by the client?
Focus_Cfo Franchise · 2025 FDDAnswer from 2025 FDD Document
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- Business Associate Agreements (BAA). In accordance with Focus CFO policy, Franchisees are never authorized to execute a BAA as prepared by the client. Focus CFO has a standard BAA that can be provided to a client, in cases when a BAA is required by the client. Franchisees are authorized to execute a BAA only when prepared through Focus CFO's centralized preparation process only. When a BAA is required with a client, Franchisees are also asked to execute additional documentation for Focus CFO indicating the Franchisee is aware of the requirements of the BAA and will be in ongoing compliance with Focus CFO policies and procedures surrounding clients where a BAA in place.
Source: Item 23 — Receipts (FDD pages 37–126)
What This Means (2025 FDD)
According to the 2025 Focus Cfo Franchise Disclosure Document, franchisees are not authorized to execute Business Associate Agreements (BAA) prepared by the client. Focus Cfo has a standard BAA that can be provided to a client when a BAA is required. Franchisees are only authorized to execute a BAA that has been prepared through Focus CFO's centralized preparation process.
When a BAA is required with a client, franchisees must also execute additional documentation for Focus CFO. This documentation indicates that the franchisee is aware of the requirements of the BAA and will remain compliant with Focus CFO policies and procedures related to clients with a BAA in place.
This policy ensures that all BAAs meet Focus Cfo's standards and comply with applicable regulations, reducing the risk of non-compliance and protecting both the franchisee and the franchisor. It also ensures consistency in how sensitive information is handled across the Focus Cfo system.