Item 19 cohort invitations

If you operate under a franchisor, your HQ periodically files a Franchise Disclosure Document (FDD) with the states that require one. Item 19 of that document is the Financial Performance Represent…

9 min read·Updated July 13, 2026
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What an Item 19 cohort invitation is

If you operate under a franchisor, your HQ periodically files a Franchise Disclosure Document (FDD) with the states that require one. Item 19 of that document is the Financial Performance Representation, the section where a franchisor can (optionally) tell prospective franchisees what existing locations actually earn. Franchisors that choose to include an Item 19 build it from real, current financial data across a cohort of their locations, not from a marketing estimate.

Verinode is how your HQ gathers that data without ever seeing, or publishing, your individual numbers. When your franchisor opens an Item 19 cohort for a given FDD year, they send a consent request to every membership in that cohort, asking for permission to fold your financial-period and jobs facts into the cohort's distribution. Nothing moves until you approve it. If you approve, your numbers are never disclosed as yours: they are combined with everyone else's in the cohort and reduced to network-wide percentiles, P10 through P90, the same anonymization pattern Verinode uses everywhere else on the platform. Read how benchmarks work for the general version of that pattern; Item 19 cohorts are a specific, regulatory-facing application of it.

This is one of five kinds of ask HQ can send through consent requests. Item 19 cohort is the only one where approving does not put your name or your individual figures next to anything. The others (named leaderboard, named view, case study, deep data) are all about HQ seeing you specifically; Item 19 cohort is about HQ seeing a distribution you are one anonymous input to.

Note

Verinode is an independent data trust. It does not decide whether you should join a cohort, and it never sells your data to carriers or anyone else. The choice to approve, decline, or revoke is entirely yours, and it is logged either way.

Where to find it

Open Consent Requests from the sidebar. The page lives at /consent-requests. It is a single page, no tabs, laid out top to bottom:

  1. A hero panel summarizing what is pending and what has resolved recently.
  2. A row titled Asks awaiting your response, one tile per pending request.
  3. A row titled Recently resolved, read-only tiles for anything closed in the last 30 days.

Clicking any tile, pending or resolved, opens the same detail view as a modal over the page.

The hero panel

At the top of the page, a hero reads From your network HQ as its eyebrow, with the count of pending requests as the large number. A pill next to it reads:

  • Nothing pending when there is nothing waiting on you
  • 1 pending when there is exactly one
  • A plain count (e.g. 3 pending) when there is more than one

Below the count, one line of context:

  • If nothing is pending and nothing has resolved in 30 days: "Your franchisor will ask here when they want to surface your data by name on a leaderboard, deep-dive into a metric, or feature you in a case study. Default visibility stays anonymous-aggregate until you approve."
  • If nothing is pending but something resolved recently: "N resolved in the last 30 days."
  • If something is pending: "Oldest pending asked [time ago]. Default visibility stays anonymous-aggregate until you respond."

Three small stats sit beside the headline:

  • Approved 30d, how many requests you approved in the last 30 days, subtitled "You shared by name"
  • Declined 30d, how many you declined, subtitled "You declined"
  • Pending kinds, the number of distinct request types currently waiting on you, subtitled "Distinct request types"

For an Item 19 cohort invitation specifically, "You shared by name" is a carryover label from the shared hero panel across all consent-request kinds. What actually happens on approval for Item 19 is narrower and anonymous: see below.

The Asks awaiting your response row

Each pending request is a tile. The tile's label combines the request kind and the group name, for example "Item 19 cohort · [your franchisor's group name]." The tile's headline shows up to two metric keys the ask covers, with a "+N more" suffix if there are more, or "No metrics specified" if the request did not scope any. The subtitle under that is HQ's rationale text, or "No rationale provided" if none was given. A meta line at the bottom reads "Asked [time ago] · expires in [time]" (or "no expiry" if the request has none).

If nothing is pending, the row shows: "Nothing waiting on you. New asks land here when HQ wants to surface your data by name."

Clicking a tile opens the detail modal, covered next.

The Recently resolved row

Anything that left pending status in the last 30 days (approved, declined, withdrawn, or expired) appears here, newest first, capped at 12 tiles. Each tile's label pairs the request kind with a capitalized status word (Approved, Declined, Withdrawn, Expired). The headline is the group name, the subtitle is the first 80 characters of HQ's rationale, and the meta line reads "Approved [time ago]," "Declined [time ago]," or "Updated [time ago]" depending on which timestamp applies.

If nothing has resolved in 30 days, the row shows: "No resolved requests in the last 30 days."

Clicking a resolved tile reopens the same detail modal, in its read-only closed state.

The detail modal, for an Item 19 cohort ask

Opening a tile for a request of kind Item 19 cohort shows a modal titled Item 19 cohort invitation (every other request kind is titled "Consent request from your network"). Directly under the title:

HQ is preparing the Item 19 Financial Performance Representation for their FDD. Approving adds your anonymized financial-period + jobs facts to the cohort's distribution. Your individual numbers are never disclosed, only network-wide P10/P25/P50/P75/P90 percentiles are computed.

Below that, a definition list of fields. For Item 19 specifically:

  • Cohort, the display label HQ gave this cohort when they set it up (for example, a state or FDD-year grouping). This tells you which filing your data is being asked to feed.
  • Methodology, the methodology version HQ is filing under. Item 19 methodology is versioned because how the percentile math is computed (what counts as a financial period, how jobs facts are aggregated) can change between FDD filing cycles, and the version tag ties your consent to a specific, fixed calculation, not a moving target.
  • Metrics, the metric keys in scope for this cohort (for example gross margin or annualized job count), comma-separated. Item 19 cohorts typically span the standard financial-performance set: revenue, gross margin, job counts, and claims volume, whichever the franchisor scoped for this filing.
  • Window, the time range the ask covers, shown as start date to end date, or "any" / "open" if either side is unbounded.
  • Asked, how long ago HQ sent the request.
  • Expires, the date the request lapses if you take no action, shown when HQ set one.

If HQ attached a rationale, it appears below the fields in its own block, labeled HQ's rationale.

Tip

The Methodology field is worth reading before you approve. It is the version of the calculation your data will be counted under. If HQ later revises methodology for a future filing, that is a new request with its own version tag, not a silent change to a consent you already gave.

Responding: Approve, Decline, or Revoke

While the request is pending, the modal shows two controls:

  • An optional Decline reason text field (placeholder: "Why declining (sent to HQ)"). Filling it in is not required.
  • Decline and Approve buttons.
  1. 1Read the Cohort, Methodology, Metrics, and Window fields, and HQ's rationale if one is given.
  2. 2If you want to record why you are saying no, type it into the Decline reason field.
  3. 3Click Approve to opt in, or Decline to opt out. Either closes the modal and refreshes the page.

Approving an Item 19 cohort ask does two things, both scoped to that cohort only:

  • Your consent record flips to approved, with a timestamp.
  • Your operator record is marked opted in for that specific cohort, which is what feeds the percentile calculation. Your financial-period and jobs facts join the pool of values HQ's Item 19 percentile engine draws from. That engine only ever prints P10, P25, P50, P75, and P90 for the cohort as a whole; there is no path in that calculation that surfaces one operator's number. Cohorts also need enough distinct, opted-in memberships before any percentile publishes at all: below that floor, the cohort shows as still gathering data rather than printing figures that would be too close to an individual number to call anonymous.

Declining simply records your answer. There is no side effect on any cohort data, the absence of your data from the cohort's opted-in set is the record that you said no.

While the request is approved, the modal instead shows: "You approved this on [date]. You can revoke at any time; HQ stops seeing your name immediately after." Below that, an optional Revoke reason field and a Revoke approval button.

Heads up

Revoking flips your consent to withdrawn and pulls your operator back out of that cohort's opt-in set for future percentile runs. It does not retroactively unpublish an FDD that has already been filed with your data folded into a past cohort calculation. If HQ has already filed using the cohort you were part of, talk to them about timing before you revoke, if the current filing cycle matters to you.

Once a request is closed (declined, withdrawn, or expired), the modal is read-only: "This request is closed. No further action needed." If you gave a decline reason, it repeats underneath: "Your reason: [reason]."

Any action that fails (a network error, a stale request that changed status between page load and your click) shows its error message in the modal instead of closing it, so you can retry.

Why the anonymity guarantee holds

Two separate protections are stacked here, and it is worth knowing both:

  • Aggregation. Approving does not hand HQ your revenue or margin. It hands the percentile engine one more input value. What HQ sees, and what ends up in the filed FDD, is P10 through P90 for the whole cohort, five numbers describing a distribution, not a list of operators and their figures.
  • A minimum-sample floor. The percentile engine will not publish figures for a cohort until enough distinct memberships have opted in. Below that floor, individual numbers would be too recoverable from the aggregate to call it anonymous, so the cohort simply shows as still building its sample instead.

Both protections exist independent of how much you trust your franchisor: even if HQ wanted to reverse-engineer your number from the aggregate, the math does not expose it.

Tip

This is the same anonymization discipline Verinode applies to peer benchmarks generally. See how benchmarks work and reading a benchmark for the platform-wide version of percentile-based, threshold-gated comparison.

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