The news headlines are shouting about the ground breaking penalty of $2.6 million imposed on the auto repair franchisor Ultra Tune Australia, by the Federal Court last month, in the case of Australian Competition and Consumer Commission v Ultra Tune Australia Pty Ltd [2019] FCA 12. Of that amount, $1.1 million was imposed for breaches of disclosure obligations under the Franchising Code of Conduct, including about $900,000 specifically arising from breaches of the obligations relating to accounting and disclosing of marketing funds.