Quarterlytics / Consumer Cyclical / Restaurants / El Pollo Loco Holdings, Inc. / FY2019 Annual Report

El Pollo Loco Holdings, Inc.
Annual Report 2019

LOCO · NASDAQ Consumer Cyclical
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Ticker LOCO
Exchange NASDAQ
Sector Consumer Cyclical
Industry Restaurants
Employees 4000
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FY2019 Annual Report · El Pollo Loco Holdings, Inc.
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UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 10-K

(Mark one)

☒ ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(D) OF THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 25, 2019

or

☐ TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(D) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from             to             

Commission file number 001-36556

EL POLLO LOCO HOLDINGS, INC.

(Exact name of registrant as specified in its charter)

Delaware

State or other jurisdiction of
incorporation or organization

3535 Harbor Blvd., Suite 100, Costa Mesa, California

(Address of principal executive offices)

20-3563182

(I.R.S. Employer
Identification No.)

92626

(Zip Code)

(714) 599-5000

Registrant’s telephone number, including area code

Securities registered pursuant to Section 12(b) of the Act:

Title of each class
Common Stock, par value $0.01 per share

 Trading
Symbol(s)
LOCO

Name of each exchange on which registered
The Nasdaq Stock Market LLC

Securities registered pursuant to section 12(g) of the Act:

None

(Title of class)

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.    Yes  ☐    No  ☒

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act.    Yes  ☐    No  ☒

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding
12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90
days.    Yes  ☒    No  ☐

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§
232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).   Yes ☒    No  ☐

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or an emerging growth
company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,” and "emerging growth company" in Rule 12b-2 of the Exchange
Act.

Large accelerated filer

Non-accelerated filer

  ☐

  ☐   

Accelerated filer

Smaller reporting company

Emerging growth company

☒

☒

☐

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised
financial accounting standards provided pursuant to Section 13(a) of the Exchange Act.    ☐

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act).    Yes  ☐    No  ☒

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
As of June 26, 2019, the last business day of the registrant’s most recently completed second fiscal quarter, the aggregate market value of the registrant’s common equity
held by non-affiliates was approximately $214 million, deeming purely for purposes of this calculation all directors and executive officers and Trimaran Pollo Partners,
L.L.C. to be affiliates. The determination of affiliate status is not necessarily a conclusive determination for any other purpose.

As of February 27, 2020, there were 35,089,983 shares of the registrant’s common stock outstanding.

DOCUMENTS INCORPORATED BY REFERENCE

Part III hereof incorporates by reference certain portions of the registrant’s definitive proxy statement for its 2020 annual meeting of stockholders to be filed not later than
120 days after the end of the registrant’s 2019 fiscal year.

 TABLE OF CONTENTS

PART I

Item 1. Business

Item 1A. Risk Factors

Item 1B. Unresolved Staff Comments

Item 2. Properties

Item 3. Legal Proceedings

Item 4. Mine Safety Disclosures

PART II

Item 5. Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities

Item 6. Selected Financial Data

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations

Item 7A. Quantitative and Qualitative Disclosures About Market Risk

Item 8. Financial Statements and Supplementary Data

Item 9. Changes in and Disagreements with Accountants on Accounting and Financial Disclosure

Item 9A. Controls and Procedures

Item 9B. Other Information

Item 10. Directors, Executive Officers and Corporate Governance

Item 11. Executive Compensation

PART III

Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters

Item 13. Certain Relationships and Related Transactions, and Director Independence

Item 14. Principal Accounting Fees and Services

Item 15. Exhibits, Financial Statement Schedules

Item 16. Form 10-K Summary

Signatures

PART IV

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FORWARD-LOOKING STATEMENTS

This report contains forward-looking statements that are subject to risks and uncertainties. All statements other than statements of historical fact included in
this report are forward-looking statements. Forward-looking statements discuss our current expectations and projections relating to our financial condition,
results of operations, plans, objectives, future performance and business. You can identify forward-looking statements because they do not relate strictly to
historical or current facts. These statements may include words such as “aim,” “anticipate,” “believe,” “estimate,” “expect,” “forecast,” “outlook,”
“potential,” “project,” “projection,” “plan,” “intend,” “seek,” “may,” “could,” “would,” “will,” “should,” “can,” “can have,” “likely,” the negatives thereof
and other words and terms of similar meaning in connection with any discussion of the timing or nature of future operating or financial performance or
other events. They appear in a number of places throughout this report and include statements regarding our intentions, beliefs or current expectations
concerning, among other things, our results of operations, financial condition, liquidity, prospects, growth, strategies and the industry in which we operate.
All forward-looking statements are subject to risks and uncertainties that could cause actual results to differ materially from those that we expected.

While we believe that our assumptions are reasonable, we caution that it is very difficult to predict the impact of known factors, and it is impossible for us
to anticipate all factors that could affect our actual results. All forward-looking statements are expressly qualified in their entirety by these cautionary
statements. You should evaluate all forward-looking statements made in this report in the context of the factors that could cause outcomes to differ
materially from our expectations. These factors include, but are not limited to, those listed under “Item 1A. Risk Factors” of this report, as such risk factors
may be amended, supplemented or superseded from time to time by other reports we file with the Securities and Exchange Commission.

We caution you that the important factors included in this report may not contain all of the factors that are important to you. In addition, we cannot assure
you that we will realize the results or developments we expect or anticipate or, even if substantially realized, that they will result in the consequences we
anticipate or affect us or our operations in the ways that we expect. The forward-looking statements included in this report are made only as of the date
hereof. We undertake no obligation to publicly update or revise any forward-looking statement as a result of new information, future events or otherwise,
except as required by law. If we do update one or more forward-looking statements, no inference should be made that we will make additional updates with
respect to those or other forward-looking statements. We qualify all of our forward-looking statements by these cautionary statements.

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Unless otherwise specified in this Annual Report on Form 10-K ("Annual Report"), or the context otherwise requires, terms “El Pollo Loco,” “the
Company,” “our company,” “we,” “us,” and “our” mean El Pollo Loco Holdings, Inc. (“Holdings”), together with its subsidiaries.

PART I

ITEM 1.

BUSINESS

Our Company

El Pollo Loco is Spanish for “The Crazy Chicken.” We were organized as a Delaware corporation in 2005. We opened our first location on Alvarado Street
in Los Angeles, California, in 1980, and have grown our restaurant system to 482 restaurants, comprised of 195 company-operated and 287 franchised
restaurants as of December 25, 2019. Our restaurants are located in California, Arizona, Nevada, Texas, Utah and Louisiana. Our typical restaurant is a
free-standing building with drive-thru service that ranges in size from 2,200 to 3,000 square feet with seating for approximately 50-70 people.

El Pollo Loco is a differentiated and growing restaurant concept that specializes in fire-grilling citrus-marinated chicken and operates in the limited service
restaurant (“LSR”) segment. We strive to offer food that integrates the culinary traditions of Mexico with the healthier lifestyle of Los Angeles, a
combination that we call “LA-Mex”. Our distinctive menu features our signature product, citrus-marinated fire-grilled chicken, as well as a variety of
Mexican and LA-inspired entrees that we create from our chicken. Every day in every restaurant, we marinate and fire-grill our chicken over open flames,
and slice whole tomatoes, avocados, serrano peppers, and cilantro to make our salsas, guacamole, and cilantro dressings from scratch. The design of our
kitchens reveals our cooking process and allows our customers to watch our Grill Masters and team members fire-grill and hand-cut our signature chicken,
as well as watch team members make burritos, salads, tostadas, bowls, stuffed quesadillas, and chicken entrees.

We serve individual and family-sized chicken meals, a variety of Mexican and LA-inspired entrees, and sides, and, throughout the year, on a limited-time
basis, additional proteins like shrimp. Our entrees include favorites such as our Chicken Avocado Burrito, Under 500 Calorie entrees, chicken tostada
salads, and Pollo Bowls. Our famous Creamy Cilantro dressings and salsas are prepared fresh daily, allowing our customers to create their favorite flavor
profiles to enhance their culinary experience. Our distinctive menu with healthier alternatives appeals to consumers across a wide variety of socio-
economic backgrounds and drives our balanced composition of sales throughout the day (our “day-part mix”), including at lunch and dinner.

The Company operates in one operating segment. All significant revenues relate to retail sales of food and beverages through either company or franchised
restaurants. Financial information about our operations, including our revenues and expenses for fiscal 2019, 2018 and 2017, and our total assets as of the
end of fiscal 2019 and 2018, is included in our "Audited Consolidated Financial Statements" and accompanying "Notes to Consolidated Financial
Statements" in this Annual Report. See "Item 8. Financial Statements and Supplementary Data."

Our Industry

The restaurant industry is divided into two segments: full service and limited service. We operate within the broader LSR segment, and we strive to offer
the food and dining experience of a fast-casual restaurant and the speed, value, and convenience of a quick-service restaurant ("QSR"). We strive to offer
menu options that are made with fresh ingredients and provide a healthier alternative to typical fast food, which are also inspired by the culinary and
cultural traditions of Mexico and our hometown of Los Angeles.

Our Competitive Strengths

We believe that the following strengths differentiate us from our competitors and serve as the foundation for our continued growth:

Differentiated Restaurant Concept with Broad Appeal. We believe that our food, which combines the culinary traditions of Mexico with the healthier
lifestyle of Los Angeles, served in contemporary restaurant environments at reasonable prices, positions us well to satisfy the needs of our core Hispanic
family market and appeal to the broader general market who seek convenient and high-quality meals at reasonable prices. We provide our customers with
the opportunity to enjoy citrus-marinated, fire-grilled chicken and Mexican-inspired entrees containing distinctive ingredients such as avocados, mangos,
and serrano peppers at price points that appeal to a broad consumer base. We believe that our entree prices are typically lower than

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the fast-casual segment, and a slight premium to the QSR segment. We prepare our entrees to order in approximately four minutes and allow our customers
the option to create their favorite flavor profiles using our freshly-prepared salsas before they enjoy their meals in our dining rooms or take their meals to
go from the counter or the drive-thru. We also believe that our concept, which integrates the complexity of creating real food in real kitchens with the speed
of our service model and the skill of our trained Grill Masters, provides a layer of competitive insulation around our restaurant model. We believe that our
positioning appeals to a broad customer base, and that our brand crosses over traditional age, ethnic, and income demographics, giving consumers the best
of both the fast-casual and QSR segments. We seek to position ourselves as a differentiated restaurant concept, which we believe sources traffic from both
dining segments and, as a result, we expect it to drive transaction growth in the future.

Mexican-Inspired, Fresh-Made Fire-Grilled Chicken and Entrees. Our signature product is our chicken, marinated with a proprietary recipe of citrus juice,
garlic, and spices, which serves as the foundation of our distinctive menu of flavorful bone-in chicken meals and entrees inspired by Mexico and LA. With
menu items such as our signature individual chicken meals, family dinners, Chicken Tostada Salad, Pollo Bowl®, Chicken Avocado Burrito, and Double
Chicken Avocado Salad, we believe that we offer our customers a healthier alternative to traditional food on-the-go. Our entrees are prepared using fresh
ingredients with recipes inspired by Mexican cuisine. The majority of our menu items are prepared in-restaurant using fresh ingredients, including our
bone-in chicken and chicken breast filets, rice, salsas, and cilantro dressing. These items start with our chicken, which is marinated in our restaurants daily.
From there, our Grill Masters fire-grill and hand-chop our chicken to order. Our team members create our salsas, and cilantro dressings with fresh
tomatoes, avocados, serrano peppers, and cilantro. In addition, our rice is seasoned, and simmered in our restaurants throughout each day.

Our bone-in chicken meals and Mexican-inspired entrees accounted for 46% and 47% of our company-operated restaurant sales, respectively, in 2019. Our
individual and family-sized chicken meals appeal to customers looking to dine at the restaurant or take out during dinnertime, while our Mexican-inspired
entrees draw traffic from customers at lunchtime or for an afternoon snack, enabling us to generate sales almost equally between lunch and dinner. We
believe that our family-sized chicken meals provide a healthier and convenient alternative for families looking to solve the “dinnertime dilemma” of
providing their families with high-quality meals without investing significant time or money. In 2019, approximately 28% of our company-operated sales
were generated from family-sized meals.

Operations Infrastructure that Allows for Real-Time Control, Fast Feedback, and Innovation. We believe that satisfying our customers’ dining needs is the
foundation for our business, and we have an operations platform that allows us to measure our performance in meeting and exceeding those needs. We
utilize an operations dashboard that aggregates real-time, restaurant-level information for many aspects of our business. The dashboard provides corporate
and field management, as well as restaurant-level operators, with insight into how we are performing both from the customer’s perspective and also through
the eyes of experienced third-party auditors. In addition, all company operated restaurants utilize digital “communication boards”, which communicate
sales, cost and consumer data in real time to our restaurant managers.

Developing High Average Unit Volumes (“AUVs”) and Strong Unit Economics One Chicken at a Time. We seek to position ourselves as a differentiated
LSR business, which we believe drives restaurant operating results that are competitive with other leading restaurant concepts in both the fast-casual and
QSR industry segments. We believe that our restaurant model is designed to generate strong cash flow, consistent restaurant-level financial results, and high
returns on invested capital. In 2019, our company-operated restaurants generated average annual sales per restaurant of approximately $1.9 million and
restaurant-level contribution margins of 18.7%.

Experienced Leadership. Most of our senior management team has extensive operating experience in the restaurant industry. Members of the senior
leadership team include Bernard Acoca as our President and Chief Executive Officer ("CEO"), Larry Roberts as our Chief Financial Officer, Miguel
Lozano as our Chief Operating Officer, Hector Munoz as our Chief Marketing Officer, Jason Weintraub as our Chief Legal Officer, Jennifer Jaffe as our
Chief People Officer, and Brian Carmichall as our Chief Development Officer.

Our Growth Strategy

We believe that we are well-positioned for sales growth because of our strong appeal to our core Hispanic family market, appeal to the broader general
market, disciplined business model, and strong unit economics. Our system has experienced annual comparable restaurant sales growth for nine
consecutive years through our fiscal year ended December 25, 2019. We plan to continue to expand our business, drive restaurant sales growth and increase
company profits by executing our Transformation Agenda, which consists of the following four key strategies:

Develop a People-first Culture - Invest in and Grow our Talent. We believe that success in the restaurant industry is highly correlated with employee
engagement, which is dependent upon hiring, retaining, developing and motivating employees. We continue to build a culture centered around our mission,
which is to "Feed the Love that Makes Us All Feel Like Family" and "Heart-Centered Leadership, which is predicated on servant-led leadership, employee
recognition and community involvement.

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We believe that executing on our mission will result in a better and more meaningful work experience for our employees. For example, in 2019 we
implemented a food donation program with Food Donation Connection, agreed to donate 75,000 tacos as part of our “Buy One, Feed Many” initiative, and
celebrated Caesar Chavez Day by recruiting 500 company employees, franchisees and customers to refresh a high school located in south Los Angeles. We
also continue to invest in leadership training to ensure that our managers have the tools they need to be effective leaders and motivating coaches. We
believe that our focus on culture and leadership will result in highly engaged and motivated employees, which will lead to a better experience for our
customers.

Differentiate the Brand - Accentuate our Strengths and Build Upon Them. We believe that we are uniquely positioned within the LSR restaurant space. We
will continue to adapt our menu to create family-sized dinner options and lunch entrees that complement our signature fire-grilled chicken, and are inspired
by the culinary and cultural traditions of Mexico and our hometown of Los Angeles. We believe that we have opportunities for menu innovation as we look
to increase customer frequency and target the dinner segment. In addition, we will continue to tap into the need for healthier offerings by building on the
success of our fire-grilled chicken and “better for you” products. Our marketing and operations teams collaborate to ensure that the items developed in our
test kitchen can be executed to our high standards in our restaurants with the convenience and value that our customers have come to expect.

We engage customers through our seasonal product calendar, which features new, unique limited time offers (“LTOs”) and variations of menu items like
our Chicken Tostada Salads and Stuffed Burritos. Our key points of differentiation are communicated through our advertising campaign, which highlights
the brand's authenticity, healthier menu options and dedication to high-quality ingredients. We tailor our message from television and direct mail, which
garners broad exposure, to our Loco Rewards loyalty program and social media platform where we engage in more personalized marketing.

We believe that investing in consumer-facing technology is critical to further differentiating our brand and reaching customers for whom convenience and
value are key decision factors. During the second quarter of 2017, we introduced a new Loyalty Reward program in an effort to increase sales and loyalty
among our customers, by offering rewards that incentivize customers to visit our restaurants more each month. As of December 25, 2019, there were more
than 1.5 million members in the Loco Rewards loyalty program, whom we target with segmented, dynamic campaigns with special offers tailored to each
customer segment with the goals of increasing visit frequency and growing overall spend.

In June 2018, we implemented delivery through DoorDash, a third-party delivery provider. DoorDash delivers meals ordered directly from our restaurants
or through their market place delivery platform. For meals ordered through their market place platform, restaurants incur a fee based on a percentage of the
ticket. For those ordered directly from the restaurant, no fee is charged to the restaurant as the full delivery cost is borne by the customer. In September
2019, we added Postmates and Uber Eats as additional marketplace delivery providers. As with DoorDash, restaurants incur a fee for marketplace delivery
orders. DoorDash currently maintains exclusivity for delivery orders placed directly with our restaurants. In total, during the fourth quarter of 2019,
delivery orders constituted approximately 3% of our total sales mix. As of December 25, 2019, except for two Corporate and franchise restaurants, all
locations offered integrated delivery through a third-party service.

We plan to continue investing in our loyalty and delivery programs as well as other technology platforms to continue making it easier for customers to
access our food.

Simplify Operations - Make It Easier for Employees and Franchisees to Run Our Restaurants. We believe that simplifying our restaurant operations will
further enhance our ability to attract and retain the best employees and further improve customer service. In 2019, we implemented a number of initiatives
to make it easier for our employees to operate our restaurants. These included a reduction in menu items, a new inventory management system, new
chicken cooking procedures and simplified standard operating procedures. Additional initiatives are currently in process, including a systemized restaurant
cleaning process and a state-of-the-art human resource management system. We expect that these initiatives will allow our restaurant employees to increase
their focus on customers and speed of service. We believe that this focus, combined with renewed emphasis on providing an exceptional customer
experience, will lead to higher sales over the longer term.

Grow the Business - Responsibly and Profitably for the Long Term. We believe that execution of our first three strategies will enable us to grow our
restaurant base. Our restaurant model is designed to generate strong cash flow, attractive restaurant-level financial results and high returns on invested
capital. We are currently working on a new restaurant design that we believe will clearly differentiate and communicate our brand, both on the exterior and
interior. In addition, we are redesigning the back-of-house to make it easier for employees to operate the restaurant. We expect to complete the remodel of
several restaurants using the new design by the end of June 2020. Provided we are pleased with the results, we plan to require all remodels and new builds
to use this design starting July 1, 2020. We believe that this new design will deliver strong new unit volumes and cash on cash returns in both existing and
new markets. We also believe that our remodels using this new design will result in higher

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restaurant revenue and a strengthened brand. This new design replaces our “Vision” design, which was implemented in 2016. As of December 25, 2019,
including new builds and remodels, 119 restaurants in the system were modeled on the Vision design.

We expect future new unit development to be led by franchisees, with company development being focused on existing markets and new markets
opportunistically. In order to expand into new markets, we believe that we need to source new franchisees and, therefore, we expect to invest more
resources in sourcing and onboarding them in the future.

Site Selection and Expansion

Restaurant Development

We believe that our restaurant model is designed to generate strong cash flow, attractive restaurant-level financial results, and high returns on invested
capital, which we believe provide us with a strong foundation for unit growth over the long-term. In 2019, we opened two new company-operated
restaurants and two new franchised restaurants.

As part of a strategy to focus company-operated restaurant development on our core markets and accelerate franchise development in outer and new
markets, in 2019 we sold four company-operated restaurants in the San Francisco area, seven in Phoenix and five in Dallas to existing franchisees. Each of
these transactions included development agreements requiring the franchisees to build new restaurants in those markets over several years. Going forward,
we expect the large majority of new restaurant development outside of core markets to be completed by franchisees. During 2019, we closed four
company-operated restaurants in Texas and California. For a discussion of the impairment of these restaurants, see below in "Item 1A. Risk Factors-Risks
Related to Our Business and Industry-We have incurred, and may continue to incur, significant impairment of certain of our assets, in particular in our new
markets."

In fiscal 2020, we intend to open three to four new company-operated and five to eight new franchised restaurants. There is no guarantee that we will be
able to open new company-operated or franchised restaurants, or to increase the overall number of our restaurants. We may be unsuccessful in expanding
within existing or into new markets for a variety of reasons as described below in "Item 1A. Risk Factors," including competition for customers, sites,
franchisees, employees, licenses, and financing.

Site Selection Process

We consider the location of a restaurant to be a critical variable in its long-term success and as such, we devote significant effort to the investigation and
evaluation of potential restaurant locations. Our in-house development team has extensive experience building such brands as Taco Bell, The Habit, Carl's
Jr., Baskin Robbins, Wendy’s, Denny's and Dunkin’ Brands. We use a combination of our in-house development team and outside real estate consultants to
locate, evaluate, and negotiate new sites using various criteria, including demographic characteristics, daytime population thresholds, and traffic patterns,
along with the potential visibility of, and accessibility to, the restaurant. The process for selecting locations incorporates management’s experience and
expertise and includes extensive data collection and analysis. Additionally, we use information and intelligence gathered from managers and other
restaurant personnel that live in or near the neighborhoods that we are considering.

Based on our experience and results, we are currently focused on developing freestanding sites with drive-thrus along with select in-line locations. Our
restaurants perform well in a variety of neighborhoods, which gives us greater flexibility and lowers operating risk when selecting new restaurant locations.

We approve new restaurants only after formal review by our real estate site approval committee, which includes most of our senior management, and we
monitor restaurants’ on-going performances to inform future site selection decisions.

Restaurant Construction

After identifying a lease site, we commence our restaurant build-out. Our new restaurants are either ground-up prototypes or retail space conversions. On
average, it takes approximately 12 to 24 months from specific site identification to restaurant opening. Our restaurants are constructed in approximately 10
to 15 weeks. In order to maintain consistency of food and customer service, as well as our colorful, bright, and contemporary restaurant environment, we
have set processes and timelines to follow for all restaurant openings.

Restaurant Management and Operations

Service

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We are extremely focused on customer service. We aim to provide fast, friendly service on a solid foundation of dedicated, driven team members and
managers. Our cashiers are trained on the menu items that we offer and offer customers thoughtful suggestions to enhance the ordering process. Our team
members and managers are responsible for our service and dining room environment with a focus on hospitality. Team members seek to engage in
conversation with our customers to ensure satisfaction.  In addition, constant monitoring of the dining room occurs to ensure the fresh salsa bar and
beverage station are clean and supplied with products.

Operations

We utilize systems that are aimed at measuring our ability to deliver a “best in class” experience for our customers. These systems include customer
surveys, mystery shopper scores, social media ratings and speed-of-service performance trends. The operational results from all of these sources are then
presented on an operations dashboard that displays the measures in an easy-to-read online format that corporate and restaurant-level management and
franchisees can utilize in order to identify strengths and opportunities and to develop specific plans for continuous performance improvement. In addition,
all company operated restaurants utilize digital “communication boards”, which communicate sales, cost and consumer data in real time to our restaurant
managers.

We have food safety and quality assurance programs designed to maintain the highest standards for the food and the food preparation procedures that are
used by both company-operated and franchised restaurants. We have a quality assurance team and employ third-party auditors that perform our work place
and food safety restaurant audits.

Managers and Team Members

Each of our restaurants typically has a general manager, an assistant manager and two to three shift leaders. There are between 20 and 35 team members
per restaurant, who prepare our food fresh daily and provide customer service. To lead our restaurant management teams, we have area leaders, each of
whom is responsible for 8 to 12 restaurants. Overseeing the area leaders are two Vice Presidents of Operations who report to our Chief Operating Officer.
Franchise operations are supported by three directors of franchise who report to one of the Vice Presidents of Operations. The restaurant development team
is supported by four directors who all currently report to the Chief Development Officer.

Training

Our people are the center of the El Pollo Loco customer experience. Creating a culture of constant learning has been essential in equipping our people with
the skills to deliver our high standards and commitments to our guests and employees.  We strive to find ways to simplify our methodology and invest in
elevating our people.  In a rapidly evolving landscape, effective training is not only dependent on quality of content, but also on method of delivery. To
engage our growing base of millennial employees, we employ a Learning Management System called Pollo Zone, our tablet-based learning tool. This
platform is a central hub for all training efforts and features individual learner profiles to support engagement and accountability on our path toward
investing in our people and their growth. 

Franchise Program

We use a franchising strategy to increase new restaurant growth in certain markets, leveraging the ownership of entrepreneurs with specific local market
expertise and requiring a relatively minimal capital commitment by us. As of December 25, 2019, there were a total of 287 franchised restaurants.
Franchisees range in size from single-restaurant operators to the largest franchisee, which owned 66 restaurants as of December 25, 2019. Our existing
franchise base consists of many successful, longstanding, multi-unit restaurant operators. As of December 25, 2019, approximately 76% of franchised
restaurants were owned and operated by franchisees that had been with us for over 20 years.

We believe that the franchise revenue generated from our franchise base has historically served as an important source of stable and recurring cash flows to
us, and we accordingly plan to expand our base of franchised restaurants. In existing markets, we encourage growth from current franchisees. In our
expansion markets, we seek highly-qualified and experienced new franchisees for multi-unit development opportunities.

We believe that creating a foundation of initial and on-going support is important for future success, both for our franchisees and for our brand. Therefore,
we have structured our corporate staff, programs, and communication systems to ensure that we are delivering high-quality support to our franchisees.

Our franchise training program is a key element in ensuring our franchise owners and their managers are equipped with the knowledge and skills necessary
for success. The program introduces new franchise members to El Pollo Loco with hands-on training in the operation and management of our restaurants.
This foundational training is conducted by a general training manager who has been certified by our operations group. Training must be successfully
completed before a trainee can be assigned to a restaurant as a manager.

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Once introductory training has been completed, we offer a path toward constant learning for all crew members by providing instructional materials that
span management training, operations, new product introductions, food safety and a number of other essential restaurant functions. Many of these programs
are distributed through Pollo Zone that provides our franchise owners with real-time access to the progress of learning in their restaurants.

Marketing and Advertising

We strive to distinguish the El Pollo Loco brand by building a brand equity that we believe not only accentuates our strengths but also deepens the strong
emotional connections we have with our customers. In October 2018, we completed codifying our brand architecture in a comprehensive brand book,
which shapes our strategic brand decisions and influences how we communicate the El Pollo Loco brand to consumers. We promote our restaurants and
products by emphasizing our points of differentiation, which include our Mexican and LA heritages, our fresh ingredients and made-from-scratch
preparation, and the cooking of our citrus-marinated chicken on open fire grills in our kitchens, as well as the convenience and quality we offer for families.

We use multiple marketing channels, including television, radio, digital, and print, to broadly drive brand awareness and purchases of our featured
products. We advertise on local broadcast and cable television.

Through our public relations efforts, we engage notable food editors, influencers and bloggers on a range of topics to help promote our products. In
addition, we engage in one-on-one conversations using a portfolio of social media platforms, including Facebook, Instagram and Twitter. We also use social
media as a research and customer service tool, and apply insights gained to future marketing efforts.

Our Loco Rewards loyalty program uses points, rewards, and offers to build engagement with our customers. Customers access the program on
elpolloloco.com and the El Pollo Loco iOS Apple and Android app. We build segmented dynamic campaigns with special offers tailored to each customer
segment with the goals of increasing visit frequency and growing overall spend. To keep customers engaged with the program, unannounced offers, called
"Surprise and Delights" are awarded based on that customer’s transaction history. We communicate offers, loyalty updates and other Loco Rewards
campaigns to customers via in-app messaging, mobile phone push notifications and email.

Our online ordering program makes it easy for customers to skip the line and order ahead. Available for every location and accessible from elpolloloco.com
or the El Pollo Loco mobile app, any order can be placed and paid for before arriving at the restaurant. During 2019, we made it easier for customers to
access our food by renovating our website and adding Facebook messenger, Apple ABC chat and Alexa. For additional convenience, in September 2019
we added two third-party delivery services to our portfolio providing consumers a total of three platforms from which to order from us.

In 2004, we created El Pollo Loco Charities, a non-profit charity, to support the communities surrounding our restaurants. El Pollo Loco Charities has
provided over 15,000 meals per year to underprivileged families, through organizations like Food on Foot, Habitat for Humanity, Children’s Institute, and
Court Appointed Special Advocates. In addition, during 2019 we enhanced our community outreach through several initiatives, including: 1) the
implementation of a food donation program in which restaurants donate food that would otherwise be discarded; 2) committing to donate 75,000 tacos to
charity as part of our “Buy One, Feed Many” National Taco Day promotion; 3) recruiting 500 company, franchise and customer volunteers to refresh a high
school located in south Los Angeles; and 4) entering into a relationship with an Orange County-based organization to provide job opportunities for the
homeless.

Purchasing and Distribution

Maintaining a high degree of quality in our restaurants depends in part on our ability to acquire fresh ingredients, and other necessary supplies that meet our
specifications, from reliable suppliers. We regularly inspect our vendors to ensure that products purchased conform to our standards and that prices offered
are competitive. We have a quality assurance team and third-party accredited auditors that perform comprehensive supplier audits on a frequency schedule
based on the potential food safety risk for each product. We contract with McLane Company (our “primary distributor”), a major foodservice distributor,
for substantially all of our food and supplies, including the poultry that our restaurants receive from suppliers. Our primary distributor delivers supplies to
most of our restaurants three times per week. Our restaurants in Texas utilize regional distributors for produce. Our franchisees are required to use our
primary distributor or an approved regional distributor, and franchisees must purchase food and supplies from approved suppliers. Poultry is our largest
product cost item and represented approximately 40% of our total food and paper costs for 2019. Fluctuations in supply and in price can significantly
impact our restaurant service and profit performance. We actively manage cost volatility for poultry by negotiating with multiple suppliers and entering into
what we believe are the most favorable contract terms given existing market conditions. In the past, we have entered into contracts ranging from one to two
years depending on current and expected market conditions. We currently source

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poultry from six suppliers, with two accounting for approximately 64% of our planned purchases for fiscal 2020. We have fixed prices for 100% of our
poultry supply through the end of 2020.

Intellectual Property

We have registered El Pollo Loco ® , Pollo Bowl ® , The Crazy Chicken ® , and certain other names used by our restaurants as trademarks or service
marks with the U.S. Patent and Trademark Office (the “PTO”), and El Pollo Loco ® in approximately 42 foreign countries. In addition, the El Pollo Loco
logo, website name and address, Facebook, Twitter, Instagram and YouTube accounts are our intellectual property. Our policy is to pursue and maintain
registration of service marks and trademarks in those countries where business strategy requires us to do so, and to oppose vigorously any infringement or
dilution of the service marks or trademarks in those countries. We maintain the recipe for our chicken marinade, as well as certain proprietary standards,
specifications, and operating procedures, as trade secrets or as confidential proprietary information.

Competition

We operate in the restaurant industry, which is highly competitive and fragmented. The number, size, and strength of competitors varies by region. Our
competition includes a variety of locally-owned restaurants and national and regional chains that offer dine-in, carry-out, and delivery services. Our
competition from the broadest perspective includes restaurants, pizza parlors, convenience food stores, delicatessens, supermarkets, and club stores. There
are no significant direct competitors with respect to menus that feature marinated, fire-grilled chicken. However, we indirectly compete with fast-casual
restaurants, including Chipotle, Panera, Qdoba, and Rubio’s, among others, and with chicken-specialty QSRs and Mexican QSRs, such as Chick-fil-A,
Church’s Chicken, KFC, Popeyes Louisiana Kitchen, Del Taco and Taco Bell, among others.

We believe that competition within the fast-casual restaurant segment is based primarily on ambience, price, taste, quality, and freshness of menu items, as
well as on the convenience of drive-thru service. We also believe that QSR competition is based primarily on quality, taste, speed of service, value, brand
recognition, restaurant location, and customer service. In addition, we compete with franchisors of other restaurant concepts for prospective franchisees.

Environmental Matters

Our operations are subject to federal, state, and local laws and regulations relating to environmental protection, including regulation of discharges into the
air and water, storage and disposal of liquid and solid waste, and clean-up of contaminated soil and groundwater. Under various federal, state, and local
laws, an owner or operator of real property may be liable for the cost of removal or remediation of hazardous or toxic substances on, in, or emanating from
that property. Such liability may be imposed without regard to whether the owner or operator knew of, or was responsible for, the presence of such
hazardous or toxic substances.

Certain of our properties may be located on sites that we know or suspect have been used by prior owners or operators as retail gasoline stations. Such
properties previously contained underground storage tanks (“USTs”) for gasoline storage, and while we are not aware of any sites with USTs remaining, it
is possible that some of these properties may currently contain abandoned USTs. We are aware of contamination from a release of hazardous materials by a
previous owner or operator at two of our owned properties and one of our leased properties. We do not believe that we have contributed to the pre-existing
contamination at any of these properties. The appropriate state agencies have been notified, and these issues are being handled without disruption to our
business. It is possible that petroleum products and other contaminants may have been released at other properties into the soil or groundwater. Under
applicable federal and state environmental laws, we, as the current owner or operator of these sites, may be jointly and severally liable for the costs of
investigation and remediation for certain contamination. Although we lease most of our properties, and, when we own, we obtain certain assurances from
the prior owner or often obtain indemnity agreements from third parties, we may nonetheless be liable for environmental conditions relating to our prior,
current, or future restaurants or restaurant sites. If we were found liable for the cost of remediation of contamination at, or emanating from, any of our
properties, our operating expenses would likely increase and our operating results would likely be adversely affected and, in extraordinary circumstances,
our operating results could be materially affected.

Since 2000, we have obtained “Phase One” Environmental Site Assessments (assessing whether current or historical property uses have impacted soil or
groundwater beneath the property, posing a threat to the environment and/or human health) for new restaurants. Where warranted, we obtain updated
reports, and, if necessary, in rare cases, we obtain “Phase Two” Environmental Site Assessments (evaluating the presence or absence of petroleum products
or hazardous substances via soil and/or groundwater sampling). We have not conducted a comprehensive subsurface environmental review of all of our
properties or operations. No assurance can be given that we have identified all of the potential environmental liabilities at our properties or that such
liabilities will not have a material adverse effect on our financial condition.

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Regulation and Compliance

We are subject to extensive federal, state, and local government regulations, including those relating to, among other things, public health and safety,
zoning and fire codes, and franchising. Failures to obtain or retain food or other licenses and registrations, or exemptions thereto, would adversely affect
the operations of restaurants. Although we have not experienced, and do not anticipate, any significant problems in obtaining required licenses, permits, or
approvals, any difficulties, delays, or failures in obtaining such licenses, permits, registrations, exemptions, or approvals could delay or prevent the opening
of, or adversely impact the viability of, a restaurant in a particular area.

The development and construction of additional restaurants will be subject to compliance with applicable zoning, land use and environmental regulations.
We believe that federal and state environmental regulations have not had a material effect on operations, but more stringent and varied requirements of
local government bodies with respect to zoning, land use, and environmental factors could delay construction and increase development costs for new
restaurants.

We are also subject to the Fair Labor Standards Act, the Immigration Reform and Control Act of 1986, and various federal, state and local laws governing
such matters as minimum wages, overtime, unemployment tax rates, workers’ compensation rates, citizenship requirements, and other working
requirements and conditions. A significant portion of our hourly staff is paid at rates consistent with the applicable federal, state, or local minimum wage
and, accordingly, increases in the applicable minimum wage will increase our labor costs. We are also subject to the Americans with Disabilities Act, which
prohibits discrimination on the basis of disability in public accommodations and employment, and which may require us to design or modify our
restaurants to make reasonable accommodations for disabled individuals.

For a discussion of the various regulatory and compliance risks that we face, see below under "Item 1A. Risk Factors.”

Management Information Systems

All of our company-operated and franchised restaurants use computerized point-of-sale and back-office systems, which we believe can scale to support our
long-term growth plans. Our point-of-sale system provides a touch-screen interface and is integrated with segmented Europay, Mastercard and Visa
tokenized high speed credit and gift card processing hardware. Our point-of-sale system is used to collect daily transaction data, which provides daily sales
and product mix information that we actively analyze.

Our in-restaurant back-office computer system is designed to assist in the management of our restaurants and to provide labor and food cost management
tools. The system also provides corporate headquarters and restaurant operations management quick access to detailed business data, and reduces the time
spent by restaurant managers on administrative needs. The system further provides sales, bank deposit, and variance data to our accounting department on a
daily basis. For company-operated restaurants, we use this data to generate weekly consolidated reports regarding sales and other key measures, as well as
preliminary weekly profit and loss statements for each location, with final reports following the end of each period.

Employees

As of December 25, 2019, we had approximately 5,005 employees, of whom approximately 4,846 were hourly restaurant employees comprised of 3,980
crewmembers, 209 general managers/acting general managers, 171 assistant managers, 450 shift leaders, and 36 employees in limited-time roles as acting
managers or as managers in training. The remaining 159 employees were corporate and office personnel. None of our employees are part of a collective
bargaining agreement, and we believe that our relationships with our employees are satisfactory.

Seasonality

Seasonal factors, including weather and the timing of holidays, cause our revenue to fluctuate from quarter to quarter. Our revenue per restaurant is
typically lower in the first and fourth quarters due to reduced January and December transactions and higher in the second and third quarters. As a result of
seasonality, our quarterly and annual results of operations and key performance indicators such as company restaurant revenue and comparable restaurant
sales may fluctuate.

Available Information

We make available free of charge on our Internet website our Annual Reports, quarterly reports on Form 10-Q, current reports on Form 8-K, and
amendments to those reports filed or furnished pursuant to Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as amended (the “Exchange
Act”), as soon as reasonably practicable after we electronically file such material with, or furnish it to, the Securities and Exchange Commission (“SEC”).
Our Internet address is www.elpolloloco.com. The

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contents of our Internet website are not part of this annual report, and are not incorporated by reference. Our Internet address is provided as an inactive
textual reference only.

The SEC also maintains an Internet site that contains reports, proxy and information statements, and other information regarding issuers, including us, that
file electronically with the SEC, at http://www.sec.gov.

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ITEM 1A.

RISK FACTORS

You should carefully consider the following risk factors, as well as other information contained in this report, including our financial statements and the
notes related to those statements. The occurrence of any of the following risks could materially and adversely affect our business, prospects, financial
condition, results of operations, and cash flow.

Risks Related to Our Business and Industry

Our growth strategy depends in part on opening new restaurants in existing and new markets and expanding our franchise system. We may be
unsuccessful in opening new company-operated or franchised restaurants or in establishing new markets, which could adversely affect our growth.

One of the key means to achieving our growth strategy is and will be through opening new restaurants and operating those restaurants on a profitable basis.
We opened two new company-operated restaurants in fiscal 2019 and plan to open three to four in fiscal 2020. Our franchisees opened two new restaurants
in fiscal 2019 and plan to open five to eight in fiscal 2020. The ability to open new restaurants is dependent upon a number of factors, many of which are
beyond our control, including our and our franchisees’ abilities to:

•

•

•

•

•

•

•

•

•

•

identify available and suitable restaurant sites;

compete for restaurant sites;

reach acceptable agreements regarding the lease or purchase of locations;

obtain or have available the financing required to acquire and operate a restaurant, including construction and opening costs;

respond to unforeseen engineering or environmental problems with leased premises;

avoid the impact of inclement weather and natural and man-made disasters;

hire, train, and retain the skilled management and other employees necessary to meet staffing needs;

obtain, in a timely manner and for an acceptable cost, required licenses, permits, and regulatory approvals;

respond effectively to any changes in local, state, and federal law and regulations that adversely affect our and our franchisees’ costs or abilities to
open new restaurants; and

control construction and equipment cost increases for new restaurants.

There is no guarantee that a sufficient number of suitable restaurant sites will be available in desirable areas or on terms that are acceptable to us in order to
achieve our growth plan. If we are unable to open new restaurants or sign new franchisees, or if restaurant openings are significantly delayed, our earnings
or revenue growth and our business could be materially and adversely affected, as we expect a portion of our growth to come from new locations.

As part of our longer-term growth strategy, we may enter into geographic markets in which we have little or no prior operating or franchising experience,
through company-operated restaurant growth and franchise development agreements. The challenges of entering new markets include (i) difficulties in
hiring and training experienced personnel, (ii) unfamiliarity with local real estate markets and demographics, (iii) consumer unfamiliarity with our brand,
and (iv) competitive and economic conditions, consumer tastes, and discretionary spending patterns that are different from and more difficult to predict or
satisfy than in our existing markets. Consumer recognition of our brand has been important for our success in our existing markets. In addition, restaurants
that we open in new markets may take longer to reach expected sales and profit levels on a consistent basis, and may have higher construction, occupancy,
and operating costs, than restaurants that we open in existing markets, thereby affecting our overall profitability. Any failure on our part to recognize or
respond to these challenges may adversely affect the success of any new restaurants. Expanding our franchise system could require the implementation,
expense, and successful management of enhanced business support systems, management information systems, and financial controls, as well as additional
staffing, franchise support, and capital expenditures and working capital.

At the end of fiscal 2009, we had 21 system-wide restaurants, all originally developed by franchisees, open east of the Rocky Mountains. However, by
2012, all of these restaurants had been closed. We may encounter similar issues with our current growth strategy, which could materially and adversely
affect our business, financial condition, results of operations, and cash flow.

Due to brand recognition and logistical synergies, as part of our growth strategy, we also intend to open new restaurants in areas where we have existing
restaurants. The operating results and comparable restaurant sales for our restaurants could be adversely affected due to increasing proximity among our
restaurants and due to market saturation.

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We may not be able to compete successfully, including with other quick-service and fast casual restaurants. Intense competition in the restaurant
industry could make it more difficult to expand our business, and could also have a negative impact on our operating results, if customers favor our
competitors or if we are forced to change our pricing and other marketing strategies.

The food service industry, and particularly its QSR and fast casual segments, is intensely competitive. In addition, the greater Los Angeles area, the primary
market in which we compete, consists of what we believe to be the most competitive Mexican-inspired QSR and fast casual market in the United States.
We expect competition in this market and in each of our other markets to continue to be intense, because consumer trends are favoring limited service
restaurants that offer healthier menu items made with better-quality products, and many limited service restaurants are responding to these trends.
Competition in our industry is primarily based on price, convenience, quality of service, brand recognition, restaurant location, and type and quality of
food. If our company-operated and franchised restaurants cannot compete successfully with other QSR and fast casual restaurants in new and existing
markets, we could lose customers and our revenue could decline. Our market position is based on balancing price and quality, and drift in our competitive
position, or popular perception of or interest in our position, could harm our sales, brand, and support among customers. Our company-operated and
franchised restaurants compete with national and regional QSR and fast casual restaurant chains for customers, restaurant locations, and qualified
management and other staff. Moreover, we may also compete with companies outside the QSR and fast casual segment of the restaurant industry. For
example, competitive pressures can come from deli sections and in-store cafés of several major grocery store chains, including those targeted at consumers
who want higher-quality food, as well as from convenience stores, cafeterias and other dining outlets. Meal kit delivery companies and other eat-at-home
options also present some degree of competition for our restaurants. Compared with us, some of our competitors have substantially greater financial and
other resources, have been in business longer, have greater brand recognition, or are better-established in the markets where our restaurants are located or
are planned to be located. These competitive factors are particularly applicable in markets in which we have expanded relatively rapidly and relatively
recently, such as Texas. Any of these competitive factors may materially and adversely affect our business, financial condition, and results of operations.

A prolonged economic downturn could materially affect us in the future.

The restaurant industry is dependent upon consumer discretionary spending. A prolonged economic downturn or an economic recession could impact the
public’s ability and desire to spend discretionary dollars as a result of job losses, home foreclosures, significantly-reduced home values, investment losses,
bankruptcies, and reduced access to credit, which could result in lower levels of customer transactions and lower average check sizes in our restaurants. If
the economy experiences another significant decline, our business, results of operations, our ability to access the capital markets and our ability to comply
with the terms of our secured revolving credit facility could be materially and adversely affected, and we and our franchisees might decelerate the number
and timing of new restaurant openings. Deterioration in customer transactions or a reduction in average check size would negatively impact our revenues
and our profitability and could result in further reductions in staff levels, additional impairment charges, and potential restaurant closures.

We are vulnerable to changes in consumer preferences and economic conditions that could harm our business, financial condition, results of
operations, and cash flow.

Food service businesses depend on consumer discretionary spending and are often affected by changes in consumer tastes, national, regional, and local
economic conditions, and demographic trends. Factors such as traffic patterns, weather, fuel prices, local demographics, and the type, number, and
locations of competing restaurants may adversely affect the performances of individual locations. In addition, economic downturns, inflation, or increased
food or energy costs could harm the restaurant industry in general and our locations in particular. An outbreak of disease, epidemic or pandemic, or similar
public threat, or fear of such an event, that negatively impacts consumer spending or consumers' willingness to dine out could have a material impact on
our business, financial condition and operating results and could also adversely impact the economy generally. Adverse changes affecting consumer
preferences or economic conditions within the restaurant industry or the economy more generally could reduce consumer transactions or impose practical
limits on pricing that could harm our business, financial condition, results of operations, and cash flow. Further, there can be no assurance that consumers
will continue to regard chicken-based or Mexican-inspired food favorably or that we will be able to develop new products that appeal to consumer
preferences. Our business, financial condition, and results of operations depend in part on our ability to anticipate, identify, and respond to changing
consumer preferences and economic conditions. See also "-A prolonged downturn could materially affect us in the future" below.

Political and social factors, including regarding trade, immigration or customer preferences, could negatively impact our business.

Our success is dependent upon continued customer acceptance of our Mexican-inspired food. Increases in tariffs, restrictions on trade, or other
deterioration in American political or economic relations with Mexico, or a decrease in American consumers’

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interest in Mexican-inspired food, could harm our brand and profitability. Additionally, changes in trade, labor, or immigration policy could raise our input
prices, or reduce the supply of immigrants who are in many cases our customers or employees, diminishing our sales and increasing our labor costs.

Our business is geographically concentrated in the greater Los Angeles area, and we could be negatively affected by conditions specific to that region.

Our company-operated and franchised restaurants in the greater Los Angeles area generated, in the aggregate, approximately 70.5% of our revenue in fiscal
2019 and approximately 69.2% in fiscal 2018. Adverse changes in demographic, unemployment, economic, or regulatory conditions in the greater Los
Angeles area or in the State of California, including, but not limited to, enforcement policies for and changes in immigration law, have had and may
continue to have material adverse effects on our business. We believe that an increase in unemployment would have a negative impact on transactions in
our restaurants. As a result of our concentration in the greater Los Angeles area, we have been disproportionately affected by the above adverse economic
conditions as compared to other national chain restaurants.

Our business is vulnerable to natural disasters given its geographic concentration and real estate intensive nature.

Since our business is geographically concentrated in the greater Los Angeles area, we could be negatively affected by weather conditions specific to that
region, including fires, earthquakes, or other natural disasters. Additionally, outside of Los Angeles, many of our restaurants are clustered around major
cities in Northern California, Texas, and elsewhere, and prolonged or severe inclement weather could affect our sales at restaurants in locations that
experience such conditions. Localized disasters, especially exacerbated by climate change, including wildfires, hurricanes, and flooding, could impair our
assets and operations in those areas. For example, in the third quarter of 2017, the Houston metropolitan area was impacted by Hurricane Harvey and
resultant flooding. This caused for us, among other effects, temporary store closures and food spoilage. We may also suffer unexpected losses resulting
from natural disasters or other catastrophic events affecting our areas of operation, such as droughts, black outs, local strikes, terrorist attacks, increases in
energy prices, explosions, or other natural or man-made disasters. The incidence and severity of catastrophes are inherently unpredictable, and our losses
from catastrophes could be substantial.

Our long-term success depends in part on our ability to effectively identify and secure appropriate sites for new restaurants.

We intend to develop new restaurants in our existing markets, expand our footprint into adjacent markets and selectively enter into new markets. In order to
build new restaurants, we must first identify markets where we can enter or expand our footprint, taking into account numerous factors, including the
location of our current restaurants, local economic trends, population density, area demographics, cost of construction and real estate and geography. Then
we must secure appropriate restaurant sites, which is one of our biggest challenges. There are numerous factors involved in identifying and securing an
appropriate restaurant site, including:

•

•

•

•

•

•

•

evaluating size of the site, traffic patterns, local retail, residential and business attractions and infrastructure that will drive high levels of customer
traffic and sales;

competition in new markets, including competition for restaurant sites;

financial conditions affecting developers and potential landlords, such as the effects of macro-economic conditions and the credit market
(including the potential for rising interest rates), which could lead to these parties delaying or canceling development projects (or renovations of
existing projects), in turn reducing the number of appropriate restaurant sites available;

developers and potential landlords obtaining licenses or permits for development projects on a timely basis;

proximity of potential restaurant sites to existing restaurants;

anticipated commercial, residential and infrastructure development near the potential restaurant site; and

availability of acceptable lease terms and arrangements, including construction costs.

In addition, competition for restaurant sites in our target markets can be intense, and development and leasing costs are increasing. Given the numerous
factors involved, we may not be able to successfully identify and secure attractive restaurant sites in existing, adjacent or new markets, which could have a
material adverse effect on our business, financial condition and results of operations.

13

We have incurred, and may continue to incur, significant impairment of certain of our assets, in particular in our new markets.

During fiscal 2019, we determined that the carrying value of assets at certain restaurants may not be recoverable. As a result, we recorded a $3.6 million
impairment expense primarily related to the carrying value of the right-of-use assets ("ROU asset") of four restaurants sold to franchisees during fiscal
2019, and the long-lived assets of one restaurant in California.

In fiscal 2018, we recorded a non-cash impairment charge of $5.1 million, primarily related to the carrying value of four restaurants in Arizona, California
and Texas, including a restaurant in Texas that opened in early 2018. In fiscal 2017, we recorded a non-cash impairment charge of $32.6 million, primarily
related to the carrying value of the assets of 23 restaurants in Arizona, California and Texas. The impairment expense for fiscal 2017 included an
impairment expense of $27.7 million, representing the entire value of capitalized assets of all of the company-operated restaurants in Texas, net of
previously recorded depreciation. Factors which led to the impairment of our Texas restaurants included operating results, which indicated that the
restaurants would not achieve the sales volumes required to generate positive cash flows or improve profitability in the Texas market, along with the related
future cash flow assumptions, including comparable sales rate growth and restaurant operating costs, over the remaining lease terms and the age of the
restaurants in Texas. The restaurants in Texas began opening in late 2014, causing a higher net book value at the time of impairment testing, and increased
difficulty projecting results for newer restaurants in newer markets. Given the difficulty in projecting results for newer restaurants in newer markets, we are
also monitoring the recoverability of the carrying value of the assets of several other restaurants on an ongoing basis. For those restaurants, if expected
performance improvements are not realized, an impairment charge may be recognized in future periods, and such charge could be material. Asset
impairments to new units or future capital expenditures could present additional exposure. Closures could also require additional expenditures.
Furthermore, franchised unit closings could result in the loss of franchise revenue and have other adverse effects on us.

Changes in food and supply costs, especially for chicken, could adversely affect our business, financial condition, and results of operations.

Our profitability depends in part on our ability to anticipate and react to changes in food and supply costs. Although we try to manage the impact that
fluctuations in food costs have on our operating results, we are susceptible to increases in food costs as a result of factors beyond our control, such as
general economic conditions, seasonal economic fluctuations, weather conditions, global demand, food shortages, food safety concerns, infectious diseases,
fluctuations in the U.S. dollar, product recalls, and government regulations, including tariffs and other import restrictions on foreign produce and other
goods. At times the costs of many foods for humans and animals, including corn, wheat, corn flour and other flour, rice, and cooking oil, have increased
markedly, resulting in upward pricing pressures on almost all of our raw ingredients, including chicken and other meats, and increasing our food costs.
Environmental and weather-related issues, such as freezes, drought and climate change, may also lead to increases, temporary or permanent, or spikes in
the prices of some ingredients, such as produce and meat. Issues affecting the availability of produce, poultry, or other proteins such as shrimp, including
blight, disease, and overfishing, have in the past and may in the future also raise their prices. Any increase in the prices of the ingredients most critical to
our menu, such as chicken, corn, cheese, avocados, beans, rice, and tomatoes, could adversely compress our margins, or cause us to raise our prices,
reducing customer demand. Alternatively, in the event of cost increases with respect to one or more of our raw ingredients, we might choose to temporarily
suspend serving menu items, such as guacamole or one or more of our salsas, rather than pay the increased cost. Additionally, a substantial volume of
produce and other items are procured from Mexico, and occasionally other countries including Chile and Peru. Any new or increased import duties, tariffs
or taxes, or other changes in U.S. trade or tax policy, could result in higher food and supply costs that would adversely impact our financial results. Any
such changes to our menu prices or available menu could negatively impact our restaurant transactions, business, and comparable restaurant sales during
the shortage and thereafter.

Our principal food product is chicken. In fiscal 2019, 2018, and 2017, the cost of chicken included in our product cost was approximately 10.9%, 11.0%,
and 11.3%, respectively, of our revenue from company-operated restaurants. Material increases in the cost of chicken could materially and adversely affect
our business, operating results, and financial condition. Changes in the cost of chicken can result from a number of factors, including seasonality, increases
in the cost of grain, disease, and other factors that affect domestic and international supply of and demand for chicken products. Additionally,
environmental and animal rights regulations or voluntary programs could increase the cost or supply of chicken and other foods. We often ask our suppliers
to use fixed price contracts or other financial risk management strategies to reduce potential price fluctuations in the cost of chicken and other commodities.
We have implemented menu price increases in the past to significantly offset increased chicken prices, due to competitive pressures and compressed profit
margins. We may not be able to offset all or any portion of increased food and supply costs through higher menu prices in the future. If we implement
further menu price increases in the future to protect our margins, average check size and restaurant transactions could be materially and adversely affected,
at both company-operated and franchised restaurants.

Negative publicity could reduce sales at some or all of our restaurants.

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We are, from time to time, faced with negative publicity at one or more of our restaurants relating to (i) food quality; (ii) the safety, sanitation, and welfare
of chicken, which is our principal food product; (iii) restaurant facilities; (iv) customer complaints or litigation alleging illness or injury; (v) health
inspection scores; (vi) integrity of our or our suppliers’ food processing and other policies, practices, and procedures; (vii) employee relationships; or
(viii) other matters. Negative publicity can adversely affect us, regardless of whether an allegation is valid or whether we are held to be responsible. In
addition, the negative impact of adverse publicity relating to one restaurant may extend far beyond the restaurant involved to affect some or all of our other
restaurants, including our franchised restaurants. For example, we, or other chicken purveyors or restaurant companies generally, could come under
criticism from animal rights and welfare activists for our business practices or those of our suppliers. Such criticisms could impair our brand, our restaurant
sales, our hiring, our expansion plans, and the performance of our franchisees. If we changed our practices because of concerns about animal welfare, or in
response to such criticisms, our costs might increase, or we might have to change our suppliers or our menu. The risk of negative publicity is particularly
great with respect to our franchised restaurants, because we are limited in the manner in which we can regulate them, especially on a real-time basis. A
similar risk exists with respect to food service businesses unrelated to us, if customers mistakenly associate those unrelated businesses with our operations.

Our inability or failure to recognize, respond to and effectively manage the accelerated impact of social media could have a material adverse impact on
our business.

There has been a widespread and dramatic increase in the use of social media platforms that allow users to access a broad audience of consumers and other
interested persons.  The availability of information on social media can be virtually immediate, as can its impact, and users of many social media platforms
can post information without filters or checks on the accuracy of the content posted.  Adverse information concerning our restaurants or brand, whether
accurate or inaccurate, may be posted on such platforms at any time and can quickly reach a wide audience.  The resulting harm to our reputation may be
immediate, without affording us an opportunity to correct or otherwise respond to the information, and it is challenging to monitor and anticipate
developments on social media in order to respond in an effective and timely manner.  As a result, social media may exacerbate the risks we face related to
negative publicity.

In addition, although search engine marketing, social media and other new technological platforms offer great opportunities to increase awareness of and
engagement with our restaurants and brand, our failure to use social media effectively in our marketing efforts may further expose us to the risks associated
with the accelerated impact of social media. Many of our competitors are expanding their use of social media and the social media landscape is rapidly
evolving, potentially making more traditional social media platforms obsolete. As a result, we need to continuously innovate and develop our social media
strategies in order to maintain broad appeal with guests and brand relevance, and we may not do so effectively.  A variety of additional risks associated with
our use of social media include the possibility of improper disclosure of proprietary information, exposure of personally identifiable information of our
employees or guests, fraud, or the publication of out-of-date information, any of which may result in material liabilities or reputational damage.
Furthermore, any inappropriate use of social media platforms by our employees could also result in negative publicity that could damage our reputation, or
lead to litigation that increases our costs.

Our ability to continue to expand our digital business, delivery orders and catering is uncertain, and these new business lines are subject to risks.

For the year ended December 25, 2019, December 26, 2018 and December 27, 2017, 3.7%, 2.1% and 1.1% of our revenue was derived from digital and
delivery orders, respectively.  This growth rate may not be sustainable for even the short term, and if our digital business does not continue to expand it
may be difficult for us to achieve our planned sales growth.  We have also increased our efforts to promote delivery orders, which have also grown
considerably.  We rely on third-party providers to fulfill delivery orders, and the ordering and payment platforms used by these third parties, or our mobile
app or online ordering system, could be damaged or interrupted by technological failures, user errors, cyber-attacks or other factors, which may adversely
impact our sales through these channels and could negatively impact our brand. Additionally, our delivery partners are responsible for order fulfillment and
may make errors or fail to make timely deliveries, leading to customer disappointment that may negatively impact our brand. We also incur additional costs
associated with using third-party service providers to fulfil these digital orders.  Moreover, the third-party restaurant delivery business is intensely
competitive, with a number of players competing for market share, online traffic, capital, and delivery drivers and other people resources.  The third-party
delivery services with which we work may struggle to compete effectively, and if they were to cease or curtail operations or fail to provide timely delivery
services in a cost-effective manner, or if they give greater priority on their platforms to our competitors, our delivery business may be negatively impacted.
We have also introduced catering offerings on both a pick-up and delivery basis, and customers may choose our competitors’ catering offerings over ours,
be disappointed with their experience with our catering, or experience food safety problems if they do not serve our food in a safe manner, which may
negatively impact us. Such delivery and catering offerings also increase the risk of illnesses associated with our food because the food is transported and/or
served by third parties in conditions we cannot control.

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Because all of these offerings are relatively new, it is difficult for us to anticipate the level of sales they may generate.  That may result in operational
challenges, both in fulfilling orders made through these channels and in operating our restaurants as we balance fulfillment of these orders with service of
our traditional in-restaurant guests as well.  Any such operational challenges may negatively impact the customer experience associated with our digital,
delivery or catering orders, the guest experience for our traditional in-restaurant business, or both.  These factors may adversely impact our sales and our
brand reputation.

Food-borne illness and other food safety and quality concerns may negatively impact our business and profitability.

Incidents or reports of food- or water-borne illness or other food safety issues, food contamination or tampering, employee hygiene or cleanliness failures,
or improper employee conduct at our restaurants could lead to product liability or other claims. Such incidents or reports could negatively affect our brand
and reputation as well as our business, revenues, and profits. Similar incidents or reports occurring at QSRs unrelated to us could likewise create negative
publicity, which could negatively impact consumer behavior towards us.

We cannot guarantee that our internal controls and training will be fully effective in preventing all food-borne illnesses. Additionally, no food safety
protocols can completely eliminate the risk of food-borne illness in any restaurant, including as a result of possible failure by restaurant personnel or
suppliers to follow food safety policies and procedures. Furthermore, our reliance on third-party food processors makes it difficult to monitor food safety
compliance, and may increase the risk that a food-borne illness would affect multiple locations rather than a single restaurant. Some food-borne illness
incidents could be caused by third-party food suppliers and transporters outside of our control. New illnesses resistant to our current precautions may
develop in the future, or diseases with long incubation periods could arise that could cause claims or allegations on a retroactive basis. One or more
instances of food-borne illness in one of our company-operated or franchised restaurants could negatively affect sales at all of our restaurants if highly
publicized. This risk would exist even if it were later determined that an illness had been wrongly attributed to one of our restaurants. A number of other
restaurant chains have experienced incidents related to food-borne illnesses that have had material adverse impacts on their operations, and we cannot
guarantee that we could avoid a similar impact upon the occurrence of a similar incident at one of our restaurants. Additionally, even if food-borne illnesses
were not identified at El Pollo Loco restaurants, our restaurant sales could be adversely affected, both financially and otherwise, if instances of food-borne
illnesses at other restaurant chains were highly publicized. In addition, our restaurant sales could be adversely affected by publicity regarding other high-
profile illnesses such as avian flu that customers may associate with our food products.

We rely on only one company to distribute substantially all of our products to company-operated and franchised restaurants, and on a limited number
of companies to supply chicken. Failure to receive timely deliveries of food or other supplies could result in a loss of revenue and materially and
adversely impact our operations.

Our and our franchisees’ ability to maintain consistent quality menu items and prices significantly depends upon our ability to acquire fresh food products,
including the highest-quality chicken and related items, from reliable sources, in accordance with our specifications and on a timely basis. Shortages or
interruptions in the supply of fresh food products, caused by unanticipated demand, problems in production or distribution, contamination of food products,
an outbreak of poultry disease, inclement weather, or other conditions, could materially and adversely affect the availability, quality, and cost of
ingredients, which would adversely affect our business, financial condition, results of operations, and cash flows. We have contracts with a limited number
of suppliers for the chicken and other food and supplies for our restaurants. In addition, one company distributes substantially all of the products that we
receive from suppliers to company-operated and franchised restaurants. If that distributor or any supplier fails to perform as anticipated or seeks to
terminate agreements with us, or if there is any disruption in any of our supply or distribution relationships for any reason, including our ability to replace
any lost distributor or supplier, our business, financial condition, results of operations, and cash flows could be materially and adversely affected. If we or
our franchisees temporarily close a restaurant or remove popular items from a restaurant’s menu as a result of such a disruption, that restaurant may
experience a significant reduction in revenue if our customers change their dining habits as a result.

Our level of indebtedness, and restrictions under our credit facility, could materially and adversely affect our business, financial condition, and results
of operations.

We have substantial debt service obligations. At December 25, 2019, our total debt was $97.0 million, and we had $44.6 million of credit available under
our secured revolving credit facility, which was reduced by $8.4 million from outstanding letters of credit.

Our level of indebtedness could have significant effects on our business, such as:

•

limiting our ability to borrow additional amounts to fund working capital, capital expenditures, acquisitions, debt service requirements, execution
of our growth strategy, and other purposes;

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•

•

•

•

requiring us to dedicate a portion of our cash flow from operations to pay interest on our debt, which could reduce availability of our cash flow to
fund working capital, capital expenditures, acquisitions, execution of our growth strategy, and other general corporate purposes;

making us more vulnerable to adverse changes in general economic, industry, government regulatory, and competitive conditions in our business
by limiting our ability to plan for and react to changing conditions;

placing us at a competitive disadvantage compared with our competitors with less debt; and

exposing us to risks inherent in interest rate fluctuations, because our borrowings are at variable rates of interest, which could result in higher
interest expense in the event of increases in interest rates.

In addition, we may not be able to generate sufficient cash flow from our operations to repay our indebtedness when it becomes due and to meet our other
cash needs. If we are not able to pay our debts as they become due, we will be required to pursue one or more alternative strategies, such as selling assets,
refinancing or restructuring our indebtedness, or selling additional debt or equity securities. We may not be able to refinance our debt or sell additional debt
or equity securities or our assets on favorable terms, if at all, and if we have to sell our assets, that sale may negatively affect our ability to generate
revenue.

Our secured revolving credit facility contains a number of covenants that, among other things, restrict, subject to certain exceptions, our ability to (i) incur
additional indebtedness, (ii) issue preferred stock, (iii) create liens on assets, (iv) engage in mergers or consolidations, (v) sell assets, (vi) make investments,
loans, or advances, (vii) make certain acquisitions, (viii) engage in certain transactions with affiliates, (ix) authorize or pay dividends, and (x) change our
lines of business or fiscal year. In addition, our secured revolving credit facility requires us (i) to maintain, on a consolidated basis, a minimum
consolidated fixed charge coverage ratio and (ii) not to exceed a maximum lease adjusted consolidated leverage ratio. Our ability to borrow under our
secured revolving credit facility depends on our compliance with these tests. Events beyond our control, including changes in general economic and
business conditions, may affect our ability to meet these tests. We cannot guarantee that we will meet these tests in the future, or that our lenders will waive
any failure to meet these tests.

Further, we are a holding company with no material direct operations. Our principal assets are the equity interests that we indirectly hold in our operating
subsidiary, El Pollo Loco, Inc. (“EPL”), which owns our operating assets. As a result, we are dependent on loans, dividends, and other payments from EPL,
our operating company and indirect wholly owned subsidiary, and from EPL Intermediate, Inc. (“Intermediate”), our direct wholly owned subsidiary, to
generate the funds necessary to meet our financial obligations and to pay dividends on our common stock. Our subsidiaries are legally distinct from us and
may be prohibited or restricted from paying dividends or otherwise making funds available to us under certain conditions. Although we do not expect to
pay dividends on our common stock for the foreseeable future, if we are unable to obtain funds from our subsidiaries, we may be unable to, or our board
may exercise its discretion not to, pay dividends.

Under our secured revolving credit facility, Holdings may not make certain payments such as cash dividends, except that it may, inter alia, (i) pay up to
$1.0 million per year to repurchase or redeem qualified equity interests of Holdings held by our past or present officers, directors, or employees (or their
estates) upon death, disability, or termination of employment, (ii) pay under its TRA, and, (iii) so long as no default or event of default has occurred and is
continuing, (a) make non-cash repurchases of equity interests in connection with the exercise of stock options by directors, officers and management,
provided that those equity interests represent a portion of the consideration of the exercise price of those stock options, (b) pay up to $0.5 million in any 12
month consecutive period to redeem, repurchase or otherwise acquire equity interests of any subsidiary that is not a wholly-owned subsidiary from any
holder of equity interest in such subsidiary, (c) pay up to $2.5 million per year pursuant to stock option plans, employment agreements, or incentive plans,
(d) make up to $5.0 million in other restricted payments per year, and (e) make other restricted payments, subject to its compliance, on a pro forma basis,
with (x) a lease-adjusted consolidated leverage ratio not to exceed 4.25 times and (y) the financial covenants applicable to our secured revolving credit
facility.

Our marketing programs may not be successful, and our new menu items, advertising campaigns, and restaurant designs and remodels may not
generate increased sales or profits.

We incur costs and expend other resources in our marketing efforts on new menu items, advertising campaigns, and restaurant designs and remodels, to
raise brand awareness and to attract and retain customers. Our initiatives may not be successful, resulting in expenses incurred without the benefit of higher
revenues. Further, if our marketing and advertising strategies are not successful, we may be forced to engage in additional promotional activities to attract
and retain customers, including offers for free or discounted food, and any such additional promotional activities could adversely impact our profitability.
Additionally, some of our competitors have greater financial resources than we do, enabling them to spend significantly more on marketing, advertising,
and other initiatives. Should our competitors increase spending on marketing, advertising, and other initiatives, or our marketing funds decrease for any
reason, or should our advertising, promotions, new menu items, and restaurant designs and remodels be less effective than those of our competitors or not
resonate with our customers, there could be a material adverse effect on our results of operations and financial condition.

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The challenging economic environment may affect our franchisees, with adverse consequences to us.

We rely in part on our franchisees and the manner in which they operate their locations to develop and promote our business. As of December 25, 2019, our
top 10 franchisees operated 68.6% of our franchised restaurants and two franchisees operated 34.5% of our franchised restaurants. Due to the continuing
challenging economic environment, it is possible that some franchisees could file for bankruptcy or become delinquent in their payments to us, which could
have significant adverse impacts on our business, due to loss or delay in payments of (i) royalties, (ii) information technology (“IT”) support service fees,
(iii) contributions to our advertising funds, and (iv) other fees. Bankruptcies by our franchisees could (i) prevent us from terminating their franchise
agreements, so that we could offer their territories to other franchisees, (ii) negatively impact our market share and operating results, as we might have
fewer well-performing restaurants, and (iii) adversely impact our ability to attract new franchisees.

As of December 25, 2019, we had executed development agreements that represent commitments to open 54 franchised restaurants at various dates through
2028. Although we have developed criteria to evaluate and screen prospective developers and franchisees, we cannot be certain that the developers and
franchisees that we select will have the business acumen or financial resources necessary to open and operate successful franchises in their franchise areas,
and state franchise laws may limit our ability to terminate or modify these franchise arrangements. Moreover, franchisees may fail to operate their
restaurants in fashions consistent with our standards and requirements, or to hire and train qualified managers and other restaurant personnel. Failures of
developers and franchisees to open and operate franchises successfully could materially and adversely affect our reputation, brand, business, financial
condition, results of operations, cash flows, and ability to attract prospective franchisees.

Franchisees may not have access to the financial or management resources that they need to open the restaurants contemplated by their agreements with us,
or be able to find suitable sites on which to develop those restaurants. Franchisees may not be able to negotiate acceptable lease or purchase terms for
restaurant sites, obtain necessary permits and government approvals, or meet construction schedules. Any of these problems could slow our growth and
reduce our franchise revenue. Additionally, our franchisees typically depend on financing from banks and other financial institutions, which may not
always be available to them, in order to construct and open new restaurants. For these reasons, franchisees operating under development agreements may
not be able to meet the new restaurant opening dates required under those agreements. Also, we sublease certain restaurants to some existing California
franchisees. If any such franchisees cannot meet their financial obligations under their subleases, or otherwise fail to honor or default under the terms of
their subleases, we will be financially obligated under a master lease and could be materially and adversely affected. In the past, franchisees have entered
bankruptcy or receivership, which can lead to sale or closure of franchises, cause underperformance or underinvestment in capital expenditures, or lead to
nonpayment of us or other creditors, and these circumstances could recur in the future.

We have limited control with respect to the operations of our franchisees, which could have a negative impact on our business.

Franchisees are independent business operators. They are not our employees, and we do not exercise control over the day-to-day operations of their
restaurants. We provide training and support to franchisees, and set and monitor operational standards, but the quality of franchised restaurants may be
diminished by any number of factors beyond our control. Consequently, franchisees may fail to operate their restaurants in fashions consistent with our
standards and requirements, or to hire and train qualified managers and other restaurant personnel. If franchisees do not operate to our expectations, our
image and reputation, and the images and reputations of other franchisees, may suffer materially, and system-wide sales could decline significantly.

If our relations with existing or potential franchisees deteriorate, restaurant performance and our development pipeline could suffer.

Our growth depends on maintaining amicable relations with our franchisees, including their participation in and adherence to our restaurant operating
guidelines. Although we believe we generally enjoy a positive working relationship with our franchisees, they are independent business operators, and they
may from time to time disagree with us and our strategies regarding the business or our interpretation of our respective rights and obligations under the
franchise agreement. Because our ability to control our franchisees is limited, disagreement may lead to inaction by our franchisees with respect to our
initiatives, or even disputes with our franchisees. We expect such disputes to occur from time to time as we continue to offer franchises due to our size and
the general nature of the franchisor-franchisee relationship.  Disputes between us and our franchisees, whether in court, arbitration or otherwise, could
relate to either party’s actual or alleged violation of its contractual, statutory or common law obligations. Unfavorable judgments, awards or settlements
relating to franchisee disputes could result in monetary or injunctive relief against us, including the voiding of non-compete, territorial exclusivity, or other
development-related provisions upon which we rely to protect our brand. For example, in a recent suit where a franchisee challenged the enforceability of
the territorial exclusivity clause in its franchise agreement with us, a jury found in favor of the franchisee. Although we are vigorously appealing the
judgment, if this or similar clauses were held unenforceable, we could be negatively impacted.  To the extent that we have such disputes, the attention,
time, and financial resources of our management and our

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franchisees may be diverted from our restaurants, which could have a material adverse effect on our (and our franchisees’) business, financial condition,
results of operations, and cash flows, as well as our ability to attract new franchisees. Even our success in franchisee disputes could damage our (or our
franchisees') finances or operations, as well as our relationships with our franchisees and our ability to attract new franchisees given the negative
connotations of any franchisor-franchisee disputes.

Our self-insurance programs may expose us to significant and unexpected costs and losses.

We currently maintain employee health insurance coverage on a self-insured basis. We do maintain stop loss coverage which sets a limit on our liability for
both individual and aggregate claim costs.

We currently record a liability for our estimated cost of claims incurred and unpaid as of each balance sheet date. Our estimated liability is recorded on an
undiscounted basis and includes a number of significant assumptions and factors, including historical trends, expected costs per claim, actuarial
assumptions, and current economic conditions. Our history of claims activity for all lines of coverage is closely monitored, and liabilities are adjusted as
warranted based on changing circumstances. It is possible, however, that our actual liabilities may exceed our estimates of loss. We may also experience an
unexpectedly large number of claims that result in costs or liabilities in excess of our projections, and therefore we may be required to record additional
expenses. For these and other reasons, our self-insurance reserves could prove to be inadequate, resulting in liabilities in excess of our available insurance
and self-insurance. If a successful claim is made against us and is not covered by our insurance or exceeds our policy limits, our business may be negatively
and materially impacted.

Information technology system failures or breaches of our network security could interrupt our operations and adversely affect our business.

We rely on our computer systems and network infrastructure across our operations, including point-of-sale processing at our restaurants. Security breaches
of our networks and systems, including those caused by physical or electronic break-ins, computer viruses, malware, worms, attacks by hackers or foreign
governments, disruptions from unauthorized access and tampering, including through social engineering such as phishing attacks, coordinated denial-of-
service attacks and similar breaches, could result in, among other things, system disruptions, shutdowns, unauthorized access to or disclosure of
confidential information, misappropriation of our or our customers’ proprietary or confidential information, breach of our legal, regulatory or contractual
obligations, inability to access or rely upon critical business records or systems or other delays in our operations. In some cases, it may be difficult to
anticipate or immediately detect such incidents and the damage they cause. We may be required to expend significant financial resources to protect against
or to remediate such security breaches. In addition, our operations depend upon our ability to protect our computer equipment and systems against damage
from physical theft, fire, power loss, telecommunications failure, and other catastrophic events and disruptive problems. Any unauthorized access of our
systems or the information stored on such systems, damage or failure of our computer systems or network infrastructure that causes an interruption in our
operations could damage our reputation, subject us to litigation or to actions by regulatory authorities, harm our business relations or increase our security
and insurance costs, which could have a material adverse effect on our business, financial condition and results of operations. Moreover, these systems,
infrastructures, and operations rely upon third-party software and vendors, and we may therefore have a limited ability to guard against, learn about, or
remedy problems that could harm us, including bugs and glitches, system outages, and hacks that exploit security vulnerabilities to steal or ransom
information.

If we are unable to protect our customers’ payment method data or personal information, we could be exposed to data loss, litigation, liability, and
reputational damage.

We accept electronic payment cards from our customers in our restaurants. Customers also have the ability to pay for online orders with their mobile
phones using a stored value component built into our app. For the fiscal year ended December 25, 2019, approximately 56.3% of our sales were attributable
to credit/debit card transactions, and credit/debit card usage could continue to increase. A number of restaurant operators and retailers have experienced
actual or potential security breaches in which credit/debit card information may have been compromised or stolen. While we have taken reasonable steps to
prevent the occurrence of security breaches in this respect, it is possible that these measures may not be adequate and we may in the future become subject
to claims for purportedly fraudulent transactions arising out of the actual or alleged theft of credit/debit card information. We may also be subject to
lawsuits or other proceedings in the future relating to these types of incidents. Proceedings related to theft of credit/debit card information may be brought
by payment card providers, banks, and credit unions that issue cards, cardholders (either individually or as part of a class action lawsuit), and federal and
state regulators. Any such proceedings could distract our management team members from running our business and cause us to incur significant
unplanned losses and expenses.

We also sell and accept for payment, El Pollo Loco gift cards, and our loyalty rewards program provides points that can be redeemed for purchases. Like
credit and debit cards, gift cards and rewards points are vulnerable to theft, whether physical or electronic. We believe that our gift cards are primarily
vulnerable to physical theft, as we have implemented gift card policies such as requiring a physical card to be presented when redeeming value from a gift
card; however, there could be instances of

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non-compliance with these policies. We believe that, due to their electronic nature, rewards points and payment information stored within our app are
primarily vulnerable to hacking. Customers affected by any loss of data or funds could litigate against us, and security breaches or even unsuccessful
attempts at hacking could harm our reputation, and guarding against or responding to hacks could require significant time and resources.

We also receive and maintain certain personal information about our customers and team members. The use of this information by us is regulated at the
federal and state levels. If our security and information systems are compromised or our team members fail to comply with these laws and regulations and
this information is obtained by unauthorized persons or used inappropriately, it could adversely affect our reputation, as well as the results of operations,
and could result in litigation against us or the imposition of penalties. In addition, our ability to accept credit/debit cards as payment in our restaurants and
online depends on us maintaining our compliance status with standards set by the PCI Security Standards Council. These standards, set by a consortium of
the major credit card companies, require certain levels of system security and procedures to protect our customers’ credit/debit card information as well as
other personal information. Privacy and information security laws and regulations change over time, including the California Consumer Privacy Act
(“CCPA”) which took effect January 1, 2020. The CCPA imposes new obligations on certain companies doing business in California with respect to the
personal information of California residents. This includes new notice and privacy policy requirements, and new obligations to respond to requests to know
and access to personal information, to delete personal information and to say no to the sale of personal information, which may impose significant costs on
us.

Compliance with the CCPA and other legal and regulatory changes may result in cost increases due to necessary system and process changes. Further,
while we have implemented policies and procedures to ensure compliance with the CCPA, the California Attorney General has not yet finalized his
regulations for the CCPA and the manner in which the California Attorney General may interpret and enforce the CCPA is uncertain. Despite our diligent
efforts, we may not be successful in complying with such regulations due to both internal and external factors. Noncompliance with the CCPA and other
privacy laws could result in injunctions, fines and/or proceedings against us by governmental agencies or others. There could also be uncertainty
surrounding compliance with privacy laws in other jurisdictions such as state-specific laws which may conflict with existing legislation or future laws and
regulations.

The failure to enforce and maintain our trademarks and protect our other intellectual property could materially and adversely affect our business,
including our ability to establish and maintain brand awareness.

We have registered El Pollo Loco ®, Pollo Bowl ®, The Crazy Chicken ®, and certain other names used by our restaurants as trademarks or service marks
with the PTO and El Pollo Loco® in approximately 42 foreign countries. In addition, the El Pollo Loco logo, website name and address, and Facebook,
Twitter, Instagram and YouTube accounts are our intellectual property. The success of our business strategy depends on our continued ability to use our
existing trademarks and service marks in order to increase brand awareness and further develop our branded products. If our efforts to protect our
intellectual property are inadequate, or if any third-party misappropriates or infringes upon our intellectual property, whether in print, on the Internet, or
through other media, our brands and branded products could fail to maintain or achieve market acceptance and the value of our brands could be harmed,
materially and adversely affecting our business. There can be no assurance that all of the steps that we have taken to protect our intellectual property in the
United States and in foreign countries will be adequate. In addition, the laws of some foreign countries do not protect intellectual property rights to the
same extent as do the laws of the United States.

We maintain the recipe for our chicken marinade, as well as certain proprietary standards, specifications, and operating procedures, as trade secrets or
confidential proprietary information. We may not be able to prevent the unauthorized disclosure or use of our trade secrets or proprietary information,
despite the existence of confidentiality agreements and other measures. While we try to ensure that the quality of our brands and branded products is
maintained by all of our franchisees, we cannot be certain that these franchisees will not take actions that adversely affect the value of our intellectual
property or reputation. If any of our trade secrets or proprietary information were to be disclosed to or independently developed by a competitor, our
business, financial condition, and results of operations could be materially and adversely affected.

In addition, any litigation to enforce our intellectual property rights will likely be costly and may not be successful. Although we believe that we have
sufficient rights to all of our trademarks and service marks, we may face claims of infringement that could interfere with our ability to market our
restaurants and promote our brand. Any such litigation may be costly and could divert resources from our business. Moreover, if we are unable to
successfully defend against such claims, we may be prevented from using our trademarks or service marks in the future and may be liable for damages,
which in turn could have a material adverse effect on our business, financial condition and results of operations.

Matters relating to employment and labor law may adversely affect our business.

Various federal, state and local labor laws govern our relationships with our employees and affect operating costs. These laws include employee
classifications as exempt or non-exempt, minimum wage requirements, unemployment tax rates, workers’ compensation rates, citizenship requirements,
and other wage and benefit requirements for employees classified as non-exempt.

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Significant additional government regulations and new laws mandating increases in minimum wages or benefits such as health insurance could materially
affect our business, financial condition, operating results, and cash flow. Furthermore, the unionization of our employees and of the employees of our
franchisees could materially affect our business, financial condition, operating results, and cash flow.

Employee claims against us or our franchisees based on, among other things, wage and hour violations, discrimination, harassment, or wrongful
termination may also create not only legal and financial liability but negative publicity that could adversely affect us and divert our financial and
management resources that could otherwise be used to benefit the future performance of our operations. These types of employee claims could also be
asserted against us, on a co-employer theory, by employees of our franchisees. A significant increase in the number of these claims, or an increase in the
number of successful claims, could materially and adversely affect our business, financial condition, results of operations, and cash flows.

We are also subject in the ordinary course of business to employee claims against us based, among other things, on discrimination, harassment, wrongful
termination, or violation of wage and labor laws. Such claims could also be asserted against us by employees of our franchisees. These claims may divert
our financial and management resources that would otherwise be used to benefit our operations. The on-going expense of any resulting lawsuits, and any
substantial settlement payment or damage award against us, could adversely affect our business, brand image, employee recruitment, financial condition,
operating results, or cash flows.

Restaurant companies have been the targets of class action lawsuits and other proceedings alleging, among other things, violations of federal and state
workplace and employment laws. Proceedings of this nature are costly, divert management attention, and, if successful, can result in payment of
substantial damages or settlement costs.

Our business is subject to the risk of litigation by employees, consumers, suppliers, stockholders, and others through private actions, class actions,
administrative proceedings, regulatory actions, and other litigation. The outcome of litigations, particularly class and regulatory actions, is difficult to
assess or quantify. In recent years, restaurant companies, including us, have been subject to lawsuits, including class action lawsuits, alleging violations of
federal and state laws regarding workplace and employment conditions, discrimination, and similar matters. A number of these lawsuits have resulted in
payments of substantial damages by the defendants. Similar lawsuits have been instituted from time to time alleging violations of various federal and state
wage and hour laws regarding, among other things, employee meal deductions, overtime eligibility of managers, and failure to pay for all hours worked. In
the past, we have been a party to wage and hour class action lawsuits and are currently a party to such lawsuits on behalf of purported classes. See
additional information presented in "Note 13. Commitments and Contingencies—Legal Matters" in the accompanying "Notes to Consolidated Financial
Statements" in this Annual Report.

Occasionally, our customers file complaints or lawsuits against us alleging that we are responsible for some illnesses or injuries that they suffered at or after
a visit to one of our restaurants, including actions seeking damages resulting from food-borne illnesses or accidents in our restaurants. We are also subject
to a variety of other claims from third parties arising in the ordinary course of our business, including contract claims. The restaurant industry has also been
subject to a growing number of claims that the menus and actions of restaurant chains have led to the obesity of certain of their customers. We may also be
subject to lawsuits from our employees, the U.S. Equal Employment Opportunity Commission, or others, alleging violations of federal or state laws
regarding workplace and employment conditions, discrimination, and similar matters.

Regardless of whether any claims against us are valid and whether we are liable, claims may be expensive to defend against and divert time and money
away from operations. In addition, claims may generate negative publicity, which could reduce customer traffic and sales. Although we maintain what we
believe to be adequate levels of insurance, insurance may not be available at all or in sufficient amounts to cover any liabilities with respect to these or
other matters. A judgment or other liability in excess of our insurance coverage for any claims, or any adverse publicity resulting from claims, could
adversely affect our business and results of operations.

If we or our franchisees face labor shortages or increased labor costs, our results of operations and growth could be adversely affected.

Labor is a primary component in the cost of operating our company-operated and franchised restaurants. If we or our franchisees face labor shortages or
increased labor costs, because of increased competition for employees, a decrease in the labor supply due to changes in immigration policy including
barriers to immigrants entering, working in, or remaining in the United States, higher employee-turnover rates, unionization of restaurant workers, or
increases in federal, state, or local minimum wages or in other employee benefits costs (including costs associated with health insurance coverage or
workers’ compensation insurance), our and our franchisees’ operating expenses could increase, and our growth could be adversely affected.

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We have a substantial number of hourly employees who are paid wage rates at or based on the applicable federal, state, or local minimum wage, and
increases in the minimum wage will increase our labor costs and the labor costs of our franchisees. The California minimum wage rose to $13.00 per hour
on January 1, 2020, and is scheduled to rise to (i) $14.00 per hour on January 1, 2021, and (ii) $15.00 per hour on January 1, 2022, subject, in each case, to
the governor’s ability to pause any scheduled increase (“off-ramp” provisions) for one year if either economy or budget conditions are met. Initial
determinations are to be made by the governor by August 1 of each year prior to a January increase. The governor makes the final determination by
September 1. Thereafter, the state minimum wage is to be indexed annually for inflation.

Local minimum wages may exceed or ramp up faster than state levels. In particular, the minimum wage in the City of Los Angeles and the unincorporated
areas of the County of Los Angeles is scheduled to rise to $15.00 by July 1, 2020 in accordance with a June 2015 ordinance. On September 29, 2015, the
Board of Supervisors of the County of Los Angeles adopted an ordinance amending the Los Angeles County Code and establishing a countywide minimum
wage covering unincorporated areas of the county following the same schedule.

Other municipalities have followed and may continue to follow the trend of increasing local minimum wages exceeding state levels.

In 2019, approximately 70.5% of our revenue, excluding franchise advertising revenue, came from company-operated and franchised restaurants in the
greater Los Angeles area, including 9.6% from the City of Los Angeles, 36.4% from other incorporated cities in the County of Los Angeles, and 1.3% from
unincorporated areas of the County of Los Angeles. Those restaurants that are not directly covered by these ordinances may be covered by future
ordinances, may face competitive or political pressures to match these wage levels, or may suffer from any regional economic distress caused by these
ordinances.

Federally-mandated, state-mandated, or locally-mandated minimum wages may be further raised in the future. We may be unable to increase our menu
prices in order to pass future increased labor costs on to our customers, in which case our margins would be negatively affected. Also, reduced margins of
franchisees could make it more difficult to sell franchises. And if menu prices were increased by us and our franchisees to cover increased labor costs, the
higher prices could adversely affect sales and thereby reduce our margins and the royalties that we receive from franchisees.

In addition, our success depends in part upon our and our franchisees’ ability to attract, motivate, and retain a sufficient number of well-qualified restaurant
operators, management personnel, and other employees. Qualified individuals needed to fill these positions can be in short supply in some geographic
areas. In addition, limited service restaurants have traditionally experienced relatively high employee turnover rates. Although we have not yet experienced
any significant problems in recruiting or retaining employees, our and our franchisees’ inability to recruit and retain qualified individuals could delay
planned openings of new restaurants or result in higher employee turnover in existing restaurants, which could increase our and our franchisees’ labor costs
and have a material adverse effect on our business, financial condition, results of operations, and cash flows. If we or our franchisees are unable to recruit
and retain sufficiently qualified individuals, our business and our growth could be adversely affected. Competition for qualified employees could require us
or our franchisees to pay higher wages, which could also result in higher labor costs.

We are locked into long-term and non-cancelable leases, and may be unable to renew leases at the ends of their terms.

Many of our restaurant leases are non-cancelable and typically have initial terms of up to 20 years and up to four renewal terms of five years that we may
exercise at our option. Even if we close a restaurant, we may remain committed to perform our obligations under the applicable lease, which could include,
among other things, payment of the base rent for the balance of the lease term. In addition, in connection with leases for restaurants that we will continue to
operate, we may, at the end of the lease term and any renewal period for a restaurant, be unable to renew the lease without substantial additional cost, if at
all. As a result, we may close or relocate the restaurant, which could subject us to construction and other costs and risks. Additionally, the revenue and
profit, if any, generated at a relocated restaurant might not equal the revenue and profit generated at its prior location.

We and our franchisees are subject to extensive government regulations that could result in claims leading to increased costs and restrict our ability to
operate or sell franchises.

We and our franchisees are subject to extensive government regulations at the federal, state, and local levels, including, but not limited to, regulations
relating to preparation and sale of food, zoning and building codes, franchising, land use, and employee, health, sanitation, and safety matters. We and our
franchisees are required to obtain and maintain a wide variety of government licenses, permits, and approvals. Difficulty or failure in obtaining these in the
future could result in delaying or canceling the opening of new restaurants. Local authorities may suspend or deny renewal of our government licenses if
they determine that our operations do not meet their standards for initial grant or renewal. This risk will increase if there is a major change in the licensing
requirements affecting our types of restaurants.

22

The Patient Protection and Affordable Care Act of 2010 (the “PPACA”) requires employers such as us to provide adequate and affordable health insurance
for all qualifying employees or to pay a monthly per-employee fee or penalty for non-compliance. In past years, we experienced a marginal enrollment
increase in our health plans with newly eligible employees as a result of the PPACA. In early 2017, the PPACA was undermined through executive and
Congressional action and in March 2017, the U.S. House of Representatives introduced legislation known as the American Health Care Act (the "AHCA").
The House of Representatives recently voted to pass the AHCA and the Senate is currently expected to consider an alternative version of the AHCA. It is
expected that Congress will continue to consider this or similar legislation to amend or repeal significant provisions of the PPACA, but it remains uncertain
when or if the provisions of such legislation will become law, or the extent to which any changes may impact our business. Any future cost increases may
be material and could lead to future modifications to our business practices that may be disruptive to our operations and impact our ability to attract and
retain personnel.

We are also subject to regulation by the Federal Trade Commission and subject to state laws that govern the offer, sale, renewal, and termination of
franchises and our relationships with our franchisees. Failure to comply with these laws and regulations in any jurisdiction or to obtain required approvals
could result in a ban on or temporary suspension of franchise sales, fines, or the requirement that we make a rescission offer to our franchisees, any of
which could affect our ability to open new restaurants in the future and thus could materially and adversely affect our business and operating results. Any
such failure could also subject us to liability to our franchisees.

We are increasingly subject to environmental regulations, which may increase our cost of doing business and affect the manner in which we operate.
Environmental regulations could increase the level of our taxation and future regulations could impose restrictions or increase the costs associated with
food, food packaging, and other supplies, transportation costs, and utility costs. Complying with environmental regulations may cause our results of
operations to suffer. We cannot predict what environmental regulations or legislation will be enacted in the future, how existing or future environmental
laws will be administered or applied, or the level of costs that we may incur to comply with, or satisfy claims relating to, such laws and regulations.

Changes in health, safety, construction, labor, environmental, or other laws or regulations, including changes to or repeal of the PPACA, could impose costs
upon us, including transition costs. Such transition costs could include uncertainties about how the new laws or regulations might be interpreted, enforced,
or litigated by either regulators or private parties. Such changes could also have economic implications for our customers. For example, changes to health
insurance law could diminish our customers’ disposable incomes and thus reduce their frequency of eating or ordering out, even from QSR or fast casual
restaurants, including us.

Legislation and regulations requiring the display and provision of nutritional information for our menu offerings, new information or attitudes
regarding diet and health, or adverse opinions about the health effects of consuming our menu offerings, could affect consumer preferences and
negatively impact our results of operations.

Government regulation and consumer eating habits may impact our business as a result of changes in attitudes regarding diet and health or new information
regarding the health effects of consuming our menu offerings. These changes have resulted in, and may continue to result in, the enactment of laws and
regulations that impact the ingredients and nutritional content of our menu offerings, or laws and regulations requiring us to disclose the nutritional content
of our food offerings.

The PPACA establishes a uniform, federal requirement for certain restaurants to post certain nutritional information on their menus. Specifically, the
PPACA amended the Federal Food, Drug, and Cosmetic Act to require that chain restaurants with 20 or more locations, operating under the same name and
offering substantially the same menus, publish the total number of calories of standard menu items on menus and menu boards, along with a statement that
puts this calorie information in the context of a total daily calorie intake. The PPACA also requires covered restaurants to provide to consumers, upon
request, a written summary of detailed nutritional information for each standard menu item, and to provide a statement on menus and menu boards about
the availability of this information. The PPACA further permits the U.S. Food and Drug Administration to require covered restaurants to make additional
nutrient disclosures, such as disclosure of trans-fat content. An unfavorable report on, or reaction to, our menu ingredients, the size of our portions, or the
nutritional content of our menu items could negatively influence the demand for our offerings. Currently, it is uncertain how proposed legislative changes
will impact the PPACA or the extent to which any changes may impact our business.

Furthermore, a number of states, counties, and cities have enacted menu labeling laws requiring multi-unit restaurant operators to disclose certain
nutritional information to customers, or have enacted legislation restricting the use of certain types of ingredients in restaurants. California, our largest
market, is one of these, although its menu labeling law has been superseded by the PPACA.

While we believe that our food is generally healthier than that of our peers, customers may disagree or change their dining habits to avoid QSR-like
restaurants altogether.

Compliance with current and future laws and regulations regarding the ingredients and nutritional content of our menu items may be costly and time-
consuming. Additionally, if consumer health regulations or consumer eating habits change significantly,

23

we may be required to modify or discontinue certain menu items, and we may experience higher costs associated with the implementation of those changes.
Additionally, some government authorities are increasing regulations regarding trans-fats and sodium, which may require us to limit or eliminate trans-fats
and sodium in our menu offerings, or switch to higher-cost ingredients, or which may hinder our ability to operate in certain markets. Some jurisdictions
have proposed increasing taxes on certain products, such as sodas, which may affect sales volumes of those products. Some jurisdictions have banned
certain cooking ingredients, such as trans-fats, which a small number of our ingredients contain in trace amounts, or have discussed banning certain
products, such as large sodas. Removal of these products and ingredients from our menus could affect product tastes, customer satisfaction levels, and sales
volumes, whereas if we were to fail to comply with these laws or regulations, our business could experience a material adverse effect.

We cannot make any assurances regarding our ability to effectively respond to changes in consumer health perceptions, to successfully implement
nutritional content disclosure requirements, or to adapt our menu offerings to trends in eating habits. The imposition of additional menu labeling laws could
have an adverse effect on our results of operations and financial position, as well as on the restaurant industry in general.

We may become subject to liabilities arising from environmental laws that could likely increase our operating expenses and materially and adversely
affect our business and results of operations.

We are subject to federal, state, and local laws, regulations, and ordinances that:

•

•

govern activities or operations that may have adverse environmental effects, such as discharges into the air, water and soils, as well as waste
handling and disposal practices for solid and hazardous wastes and waste water; and

impose liability for the costs of remediating, and the damage resulting from, past spills, disposals, or other releases of petroleum products and
hazardous materials.

In particular, under applicable environmental laws, we may be responsible for remediation of environmental conditions and subject to associated liabilities,
including liabilities for cleanup costs, personal injury, or property damage, relating to our restaurants and the land on which our restaurants are located,
regardless of whether we lease or own the restaurants or land in question and regardless of whether such environmental conditions were created by us or by
a prior owner or tenant. If we are found liable for the costs of remediation of contamination at any of our properties, our operating expenses would likely
increase and our results of operations could be materially and adversely affected. See above under "Item 1. “Business—Environmental Matters.”

We are required to pay our pre-IPO owners for certain tax benefits, which amounts are expected to be material.

We entered into an income tax receivable agreement (the “TRA”) with the stockholders of the Company immediately prior to the initial public offering
("IPO"), which provides for payment by us to our pre-IPO stockholders of 85% of the amount of cash savings, if any, in federal, state, local, and foreign
income tax that we and our subsidiaries actually realize (or are deemed to realize in the case of an early termination by us or a change of control) as a result
of the utilization of our net operating losses and other tax attributes attributable to periods prior to July 2014 together with interest accrued at a rate of
LIBOR plus 200 basis points from the date the applicable tax return is due (without extension) until paid.

Our payments under the TRA may be material. As of December 25, 2019, we had an accrued payable related to this agreement of approximately $8.2
million. In fiscal 2019, we paid $5.8 million to our pre-IPO stockholders under the TRA.

TRA payment obligations are obligations of Holdings and not of its subsidiaries. The actual amounts and utilization of net operating losses and other tax
attributes, as well as the amounts and timing of any payments under the TRA, will vary depending upon a number of factors, including the amount,
character, and timing of Holdings’ and its subsidiaries’ taxable income in the future.

Our counterparties under the TRA will not reimburse us for any benefits that are subsequently disallowed, although any future payments would be adjusted
to the extent possible to reflect the result of such disallowance. As a result, in such circumstances, we could make payments under the TRA greater than our
actual cash tax savings.

If we undergo a change of control as defined in the TRA, the TRA will terminate, and we will be required to make a payment equal to the present value of
expected future payments under the TRA, which payment would be based on certain assumptions, including assumptions related to our future taxable
income. Additionally, if we or a direct or indirect subsidiary transfer any asset to a corporation with which we do not file a consolidated tax return, we will
be treated as having sold that asset for its fair market value in a taxable transaction for purposes of determining the cash savings in income tax under the
TRA. Any such payment resulting from a change of control or asset transfer could be substantial and could exceed our actual cash tax savings.

A recent court judgment includes an injunction which could have an adverse impact on our business, financial conditions and results of operations in
2020 and beyond.

24

Our growth strategy depends in part on opening new restaurants in existing and new markets and expanding our franchise system. A key part of this
expansion is our ability to enter into franchise agreements for restaurants to be located in certain desirable geographic areas. In a recent lawsuit in the Los
Angeles Superior Court, an existing franchisee challenged our right to open new restaurants within a certain distance from that franchisee’s existing
restaurant. A jury found in favor of the franchisee and, among other things, the trial court issued an injunction requiring us to revise our franchise
agreement and franchise disclosure document in a manner that limits our rights to open new restaurants within certain proximities of existing franchised
restaurants. See additional information presented in "Note 13. Commitments and Contingencies—Legal Matters" in the accompanying "Notes to
Consolidated Financial Statements" in this Annual Report. We are appealing that decision, and our motion to stay the injunctive relief was denied by the
trial and appellate courts. We therefore are now required to use an amended franchise agreement and franchise disclosure document that includes the terms
specified in the injunction, including constraints on the locations at which we can open new restaurants. Although most of the locations protected from
development by the injunction are not in markets in which we had intended to open restaurants under our current growth strategy, nevertheless, and
especially in existing markets with many franchised restaurants, the injunctive relief may adversely impact our growth, which may adversely affect our
business, financial condition and results of operations.

Risks Related to Ownership of Our Common Stock

If the ownership of our common stock continues to be highly concentrated, it may prevent minority stockholders from influencing significant corporate
decisions and may result in conflicts of interest.

Trimaran Pollo Partners, L.L.C. (“LLC”), owns approximately 47.7% of our outstanding common stock. This large position means that LLC and its
majority owners—predecessors and affiliates of, and certain funds managed by, Trimaran Capital Partners and Freeman Spogli & Co. (collectively,
“Trimaran” and “Freeman Spogli,” respectively)—possess significant influence when stockholders vote on matters such as election of directors, mergers,
consolidations and acquisitions, the sale of all or substantially all of our assets, decisions affecting our capital structure, amendments to our certificate of
incorporation or our by-laws, and our winding up and dissolution. So long as LLC maintains at least 40% ownership, (i) any member of the board of
directors may be removed at any time without cause by affirmative vote of a majority of our common stock, and (ii) stockholders representing 40% or
greater ownership may cause special stockholder meetings to be called. Currently, three of our nine directors, including our chairman, are affiliated with
Trimaran or Freeman Spogli.

This concentration of ownership may delay, deter, or prevent acts that would be favored by our other stockholders. While our board has determined that
director John Roth, a general partner of Freeman Spogli and its CEO, satisfies the criteria for an independent director under applicable rules of The Nasdaq
Stock Market LLC (the “Nasdaq"), the interests of Trimaran and Freeman Spogli may not always coincide with our interests or the interests of our other
stockholders. This concentration of ownership may also have the effect of delaying, deterring, or preventing a change in control of us. Also, Trimaran and
Freeman Spogli may seek to cause us to take courses of action that, in their judgments, could enhance their investments in us, but that might involve risks
to our other stockholders or adversely affect us or our other stockholders. As a result, the market price of our common stock could decline, or stockholders
might not receive a premium over the then-current market price of our common stock upon a change in control. In addition, this concentration of ownership
may adversely affect the trading price of our common stock, because investors may perceive disadvantages in owning shares of a company with significant
stockholders.

The interests of Trimaran and Freeman Spogli may conflict with ours or our stockholders’ in the future.

Trimaran and Freeman Spogli engage in a range of investing activities, including investments in restaurants and other consumer-related companies in
particular. While our board has determined that director John Roth, a general partner of Freeman Spogli and its CEO, satisfies the criteria for an
independent director under NASDAQ rules, in the ordinary course of their business activities, Trimaran and Freeman Spogli may engage in activities where
their interests conflict with our interests or those of our stockholders. Our amended and restated certificate of incorporation provides that none of LLC or
any of its officers, directors, employees, agents, shareholders, members, partners, principals, affiliates and managers (including, inter alia, Trimaran and
Freeman Spogli) has a duty to refrain from engaging, directly or indirectly, in the same business activities or similar business activities or lines of business
in which we operate. For example, in the third quarter of 2017, Cafe Rio, a high-growth, fast-casual Mexican restaurant company, announced that Freeman
Spogli had acquired a majority interest in it. Trimaran and Freeman Spogli also may pursue acquisition opportunities that may be complementary to our
business, and, as a result, those acquisition opportunities may not be available to us. In addition, Trimaran and Freeman Spogli may have an interest in
pursuing acquisitions, divestitures, and other transactions that, in their judgment, could enhance their investment in us, even though those transactions
might involve risks to you, such as debt-financed acquisitions.

25

We do not anticipate paying any dividends on our common stock in the foreseeable future.

We do not expect to declare or pay any cash or other dividends in the foreseeable future on our common stock, because we intend to use cash flow
generated by operations to grow our business. Our secured revolving credit facility restricts our ability to pay cash dividends on our common stock. We
may also enter into other credit agreements or other borrowing arrangements in the future that restrict or limit our ability to pay cash dividends on our
common stock. See “-Our level of indebtedness, and restrictions under our credit facility, could materially and adversely affect our business, financial
condition, and results of operations.”

Failure to maintain effective internal control over financial reporting in accordance with Section 404 of the Sarbanes-Oxley Act could materially and
adversely affect our business and the market price of our common stock.

Under the Sarbanes-Oxley Act, we must maintain effective disclosure controls and procedures and internal control over financial reporting, which require
significant resources and management oversight. Internal control over financial reporting is complex and may be revised over time to adapt to changes in
our business, or changes in applicable accounting rules. We cannot assure you that our internal control over financial reporting will be effective in the
future or that a material weakness will not be discovered with respect to a prior period for which we had previously believed that internal controls were
effective. Matters impacting our internal controls may cause us to be unable to report our financial data on a timely basis, or may cause us to restate
previously issued financial data, and thereby subject us to adverse regulatory consequences, including sanctions or investigations by the SEC, or violations
of applicable stock exchange listing rules. There could also be a negative reaction in the financial markets due to a loss of investor confidence in us and the
reliability of our financial statements. Confidence in the reliability of our financial statements is also likely to suffer if we or our independent registered
public accounting firm reports a material weakness in our internal control over financial reporting. This could materially adversely affect us by, for
example, leading to a decline in the market price for our common stock and impairing our ability to raise capital.

Additionally, as we are no longer an emerging growth company, as defined by the JOBS Act, our independent registered public accounting firm is required
pursuant to Section 404(b) of the Sarbanes-Oxley Act to attest to the effectiveness of our internal control over financial reporting on an annual basis. If we
cannot maintain effective disclosure controls and procedures or internal control over financial reporting, or our independent registered public accounting
firm cannot provide an unqualified attestation report on the effectiveness of our internal control over financial reporting, investor confidence and, in turn,
the market price of our common stock could decline.

The market price and trading volume of our common stock have been and may be volatile, which could result in rapid and substantial losses for our
stockholders.

The market price of our common stock has fluctuated and may continue to fluctuate, or may decline significantly in the future. Shares of our common stock
were sold in our IPO in July 2014 at a price of $15.00 per share, and our common stock has subsequently traded as high as $41.70 and as low as $9.05.
Some of the factors that could negatively affect our share price or result in fluctuations in the price or trading volume of our common stock include:

•

•

•

•

•

•

•

•

•

•

•

•

•

variations in our quarterly or annual operating results;

changes in our earnings estimates, if provided, or differences between our actual financial and operating results and those expected by investors
and analysts;

the contents of published research reports about us or our industry, or the failure of securities analysts to cover our common stock;

additions or departures of key management personnel;

any increased indebtedness that we may incur in the future;

announcements by us or others and developments affecting us;

actions by institutional stockholders;

litigation and governmental investigations;

legislative or regulatory changes;

judicial pronouncements interpreting laws and regulations;

changes in government programs;

changes in market valuations of similar companies;

speculation or reports by the press or investment community with respect to us or our industry in general;

26

•

•

announcements by us or our competitors of significant contracts, acquisitions, dispositions, strategic relationships, joint ventures, or capital
commitments; and

general market, political, and economic conditions, including local conditions in the markets in which we operate.

These broad market and industry factors may decrease the market price of our common stock, regardless of our actual operating performance. The stock
market in general has from time to time experienced extreme price and volume fluctuations, including recently. In addition, in the past, following periods of
volatility in the overall market and decreases in the market price of a company’s securities, securities class action litigation has often been instituted against
that company. We are currently defending against such litigation. See additional information presented in "Note 13. Commitments and Contingencies—
Legal Matters" in the accompanying "Notes to Consolidated Financial Statements" in this Annual Report. Such litigation could result in substantial costs
and a diversion of our management’s attention and resources.

Future offerings of debt or equity securities by us may adversely affect the market price of our common stock.

In the future, we may attempt to obtain financing, or to further increase our capital resources, by issuing additional shares of our common stock or by
offering other equity securities, or debt, including senior or subordinated notes, debt securities convertible into equity, or shares of preferred stock. Opening
new company-operated restaurants in existing and new markets could require substantial additional capital in excess of cash from operations. We would
expect to finance the capital required for new company-operated restaurants through a combination of additional issuances of equity, corporate
indebtedness, and cash from operations.

Issuing additional shares of our common stock or other equity securities or securities convertible into equity may dilute the economic and voting rights of
our existing stockholders, reduce the market price of our common stock, or both. In a liquidation, holders of any such debt securities or preferred stock, and
lenders with respect to other borrowings, could receive distributions of our available assets prior to the holders of our common stock. Debt securities
convertible into equity could be subject to adjustments in their conversion ratios under certain circumstances, increasing the number of equity securities
issuable upon conversion. Preferred stock, if issued, could have a preference with respect to liquidating distributions, or a preference with respect to
dividend payments that could limit our ability to pay dividends to the holders of our common stock. Our decision to issue securities in any future offering
will depend on market conditions and other factors beyond our control that may adversely affect the amount, timing, or nature of our future offerings. Thus,
holders of our common stock bear the risk that our future offerings may reduce the market price of our common stock and dilute their stockholdings in us.

The market price of our common stock could be negatively affected by sales of substantial amounts of our common stock in the public markets.

The market price of our common stock could decline as a result of sales of a large number of shares of our common stock in the market or the perception
that such sales could occur. LLC presently owns approximately 47.7% of our outstanding common stock and could sell stock publicly either if the stock
were registered or if the exemption requirements of Rule 144 were satisfied. No lock-up agreements presently are in effect.

Pursuant to our stockholders' agreement, LLC and, in certain instances, Freeman Spogli, may require us to file registration statements under the Securities
Act at our expense, covering resales of our common stock held by them or LLC or piggyback on a registration statement in certain circumstances. Any
such sales, or the prospect of any such sales, could materially impact the market price of our common stock.

Delaware law, our organizational documents, and our existing and future debt agreements may impede or discourage a takeover, depriving our
investors of the opportunity to receive a premium for their shares.

We are a Delaware corporation, and the anti-takeover provisions of Delaware law impose various impediments to the ability of a third-party to acquire
control of us, even if a change of control would be beneficial to our existing stockholders. In addition, provisions of our amended and restated certificate of
incorporation and by-laws may make it difficult for, or prevent, a third-party from acquiring control of us without the approval of our board of directors.
Among other things, these provisions:

•

•

•

•

•

provide for a classified board of directors with staggered three-year terms;

do not permit cumulative voting in the election of directors, which would allow a minority of stockholders to elect director candidates;

delegate the sole power to a majority of the board of directors to fix the number of directors;

provide the power to our board of directors to fill any vacancy on our board of directors, whether such vacancy occurs as a result of an increase in
the number of directors or otherwise;

authorize the issuance of “blank check” preferred stock without any need for action by stockholders;

27

•

•

•

eliminate the ability of stockholders to call special meetings of stockholders;

establish advance notice requirements for nominations for election to our board of directors or for proposing matters that can be acted on by
stockholders at stockholder meetings; and

provide that, on or after the date that LLC ceases to beneficially own at least 40% of the total votes eligible to be cast in the election of directors, a
75% supermajority vote will be required to amend or repeal provisions relating to, among other things, the classification of the board of directors,
the filling of vacancies on the board of directors, and the advance notice requirements for stockholder proposals and director nominations.

In addition, our secured revolving credit facility imposes, and we anticipate that documents governing our future indebtedness may impose, limitations on
our ability to enter into change of control transactions. Under our secured revolving credit facility, the occurrence of a change of control transaction can
constitute an event of default permitting acceleration of the debt, thereby impeding our ability to enter into change of control transactions.

The foregoing factors, as well as significant common stock ownership by Trimaran and Freeman Spogli, could impede a merger, takeover, or other business
combination, or discourage a potential investor from making a tender offer for our common stock, which, under certain circumstances, could reduce the
market value of our common stock.

ITEM 1B.

UNRESOLVED STAFF COMMENTS

None.

ITEM 2.

PROPERTIES

As of December 25, 2019, our restaurant system consisted of 482 restaurants, comprised of 195 company-operated restaurants and 287 franchised
restaurants, located in California, Arizona, Nevada, Texas, Louisiana and Utah. In addition, we currently license our brand to one restaurant in the
Philippines. We have not included this licensed restaurant as part of our unit count as presented in this annual report. The table below sets forth the
locations (by state) for all restaurants in operation as of December 25, 2019.

State
California

Nevada

Arizona

Texas

Utah

Louisiana

Total

Company-
Operated

Franchised

Total

163  

22  

—  

9  

1  

—  

195  

220  

5  

26  

28  

7  

1  

287  

383

27

26

37

8

1

482

Our restaurants are either free-standing facilities, typically with drive-thru capability, or in-line. A typical restaurant generally ranges from 2,200 to 3,000
square feet, with seating for approximately 50-70 people. For a majority of our company-operated restaurants, we lease land on which our restaurants are
built. Our leases generally have terms of 20 years, with two or three renewal terms of five years.

Restaurant leases provide for a specified annual rent, and some leases call for additional or contingent rent based on revenue above specified levels.
Generally, our leases are “net” leases that require us to pay a pro rata share of taxes, insurance, and maintenance costs. We own 15 properties, currently
operating 12 and licensing 3 to franchisees. In addition, we operate 183 company-operated restaurants on leased real estate, an owned operating unit with
additional parking on leased real estate, and have another 26 leased sites that are subleased or assigned to franchisees who operate El Pollo Loco
restaurants. We also have eight closed units two of which are subleased for uses other than El Pollo Loco.

We lease our headquarters, consisting of approximately 29,880 square feet in Costa Mesa, California, for a term expiring in 2023, plus one three-year
extension option. Our headquarters is located at 3535 Harbor Boulevard, Suite 100, Costa Mesa, California 92626, and our telephone number is (714) 599-
5000. We believe that our current office space is suitable and adequate for its intended purposes and our near-term expansion plans.

28

 
 
ITEM 3.

LEGAL PROCEEDINGS

For information regarding legal proceedings, see "Note 13. Commitments and Contingencies—Legal Matters" in the accompanying "Notes to Consolidated
Financial Statements" in this Annual Report, which information is incorporated herein by reference.

ITEM 4.

MINE SAFETY DISCLOSURES

None.

29

PART II

ITEM 5.

MARKET FOR REGISTRANT’S COMMON EQUITY, RELATED STOCKHOLDER MATTERS AND ISSUER PURCHASES
OF EQUITY SECURITIES

Market Information

Our common stock has been listed on The Nasdaq Stock Market LLC under the symbol “LOCO” since July 25, 2014.

As of February 27, 2020, there were approximately 50 holders of record of our common stock. The number of holders of record is based upon the actual
number of holders registered at such date and does not include holders of shares in “street name” or persons, partnerships, associates, corporations, or other
entities in security position listings maintained by depositories.

30

Issuer Purchases of Equity Securities

On April 30, 2019, as part of the Company’s focus on stockholder returns, the Board of Directors approved a new stock repurchase program. The Company
entered into a stock repurchase plan on May 17, 2019 (the “2019 Stock Repurchase Plan”), which allowed for the repurchase up to $30.0 million of the
Company’s common stock. The 2019 Stock Repurchase Plan commenced on June 27, 2019, and was exhausted on September 26, 2019.

The following table summarizes the Company's purchases of common stock under the 2019 Stock Repurchase Program and withholdings of common stock
to satisfy tax withholding obligations in connection with the vesting of restricted stock issued to employees related to awards under our compensation plans
in the quarterly period ended December 25, 2019 (in thousands, except number of shares and per share amounts):

September 26, 2019 to October 23, 2019

October 24, 2019 to November 20, 2019

November 21, 2019 to December 25, 2019

Total

Total Number of Shares
Purchased (1)

Average Price Paid
Per Share

12,346   $

11.50  

—   $

—   $

12,346    

—  

—  

Total Number of Shares
Purchased as Part of
Publicly Announced Plans
or Programs

Approximate Dollar Value of
Shares That May Be
Purchased Under the Plans or
Programs

10,872   $

—   $

—   $

10,872  

—

—

—

(1) During the quarterly period ended December 25, 2019, the Company withheld 1,474 shares of common stock surrendered to the Company to satisfy tax
withholding obligations in connection with the vesting of restricted stock issued to employees related to awards under our compensation plans for total
consideration of less than $0.1 million.

Recent Sales of Unregistered Securities

None.

Stock Performance Graph

The following graph and table illustrate the total cumulative shareholder return for (i) our common stock, (ii) the Nasdaq Composite Total Return Index and
(iii) the Standard and Poor’s Supercomposite Restaurants Index, for the five years ended December 25, 2019. The graph assumes the investment of $100 at
the beginning of the period (at the closing price on our first day of trading on July 25, 2014) of our common stock on December 31, 2014 and the
reinvestment of all dividends. Stockholder returns over the indicated period should not be considered indicative of future stockholder returns.

The stock performance graph shall not be deemed soliciting material or to be filed with the SEC or subject to Regulation 14A or 14C under the Exchange
Act or to the liabilities of Section 18 of the Exchange Act, nor shall it be incorporated by reference into any past or future filing under the Securities Act of
1933, as amended (the “Securities Act”) or the Exchange Act, except to the extent we specifically request that it be treated as soliciting material or
specifically incorporate it by reference into a filing under the Securities Act or the Exchange Act

31

 
 
 
 
 
 
 
 
 
 
32

Date
December 31, 2014

April 1, 2015

July 1, 2015

September 30, 2015

December 30, 2015

March 30, 2016

June 29, 2016

September 28, 2016

December 28, 2016

March 29, 2017

June 28, 2017

September 27, 2017

December 27, 2017

March 28, 2018

June 27, 2018

September 26, 2018

December 26, 2018

March 27, 2019

June 26, 2019

September 25, 2019

December 25, 2019

LOCO

Nasdaq
Composite

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

100.00   $

126.24   $

102.50   $

53.98   $

63.50   $

67.35   $

63.45   $

65.40   $

63.09   $

60.09   $

71.11   $

60.09   $

50.08   $

47.57   $

56.58   $

62.34   $

75.61   $

65.10   $

51.90   $

55.48   $

75.36   $

S&P Supercomposite
Restaurants Index
100.00

100.00   $

103.35   $

106.47   $

98.39   $

108.21   $

104.35   $

102.76   $

114.69   $

117.64   $

127.93   $

135.61   $

140.73   $

151.73   $

152.36   $

163.65   $

176.09   $

144.85   $

169.40   $

175.79   $

179.99   $

200.03   $

106.65

113.59

115.34

121.61

126.61

122.09

121.01

129.28

134.59

149.56

143.21

157.37

153.16

153.20

166.41

169.41

190.38

208.19

217.41

207.48

ITEM 6.

SELECTED FINANCIAL DATA

The following tables contain selected historical consolidated financial data as of and for the last five fiscal years, derived from our audited consolidated
financial statements. Not all periods shown are discussed in this Annual Report. You should read these tables in conjunction with "Item 7. Management’s
Discussion and Analysis of Financial Condition and Results of Operations,” and our "Audited Consolidated Financial Statements" and accompanying
"Notes to Consolidated Financial Statements" in this Annual Report (dollar and share amounts in thousands, except per share data).

33

 
 
Statements of Operations Data:

Revenue
Company-operated restaurant revenue(1)
Franchise revenue (1)
Franchise advertising fee revenue(1)
Total revenue

Cost of operations

Food and paper costs

Labor and related expenses

Occupancy and other operating expenses

Gain on recovery of insurance proceeds, lost profits

Company restaurant expenses

General and administrative expenses

Legal settlements

Franchise expenses

Depreciation and amortization

Loss on disposal of assets

Expenses related to fire loss

Gain on recovery of insurance proceeds, property,
   equipment and expenses

Recovery of securities lawsuits related legal expenses

Impairment and closed-store reserves

Loss on disposition of restaurants

Total expenses

Gain on disposition of restaurants

Income (loss) from operations

Interest expense, net

Expenses related to selling shareholders

Income tax receivable agreement expense (income)

Income (loss) before provision (benefit) for income taxes

Provision (benefit) for income taxes

Net income (loss)

Per Share Data:

Net income (loss) per share

Basic

Diluted

Weighted average shares used in computing net income (loss)
per share

$

$

$

2019

2018

2017

2016

2015

Fiscal Year

$

391,112   $

388,835   $

376,615   $

355,468   $

28,819  

22,399  

25,771  

21,222  

25,086  

—  

24,655  

—  

332,040

23,017

—

442,330  

435,828  

401,701  

380,123  

355,057

109,264  

116,703  

92,005  

—  

317,972  

40,389  

—  

27,612  

17,855  

266  

—  

—  

(10,000)  

4,852  

5,058  

111,142  

112,417  

91,385  

—  

314,944  

50,261  

36,258  

24,429  

17,825  

278  

—  

—  

(8,356)  

9,650  

—  

109,898  

106,584  

85,631  

—  

302,113  

38,523  

—  

3,335  

18,128  

799  

—  

—  

(1,666)  

33,645  

—  

107,218  

97,471  

78,263  

(502)  

282,450  

34,661  

—  

3,823  

16,053  

674  

48  

(741)  

—  

8,554  

—  

105,917

84,231

69,977

—

260,125

28,997

—

3,456

13,092

471

—

—

—

92

—

404,004  

445,289  

394,877  

345,522  

306,233

—  

38,326  

3,687  

—  

57  

34,582  

9,682  

—  

(9,461)  

3,502  

—  

(761)  

(12,202)  

(3,208)  

—  

6,824  

3,278  

—  

(5,570)  

9,116  

497  

28  

34,629  

3,155  

—  

352  

31,122  

12,783  

24,900   $

(8,994)   $

8,619   $

18,339   $

—

48,824

3,707

50

156

44,911

20,857

24,054

0.68   $

0.67   $

(0.23)   $

(0.23)   $

0.22   $

0.22   $

0.48   $

0.47   $

0.63

0.62

Basic

Diluted

(1)

36,739,209  

38,574,553  

38,453,347  

38,357,805  

37,949,316

37,441,503  

38,574,553  

39,086,676  

39,026,950  

39,039,558

On December 28, 2017 we adopted Accounting Standards Update (“ASU") No. 2014-09, “Revenue from Contracts with Customers (Topic 606)"
("ASU 2014-09"). Results for reporting periods beginning on or after December 28, 2017 are presented under Accounting Standards Codification
("ASC") Topic 606 ("ASC 606"). Prior period amounts were not revised and continue to be reported in accordance with ASC Topic 605 ("ASC
605"), the accounting standard then in effect. See "Note 15 Revenue from Contracts with Customers" for further information.

34

 
 
 
 
 
 
 
   
   
   
   
 
   
   
   
   
 
   
   
   
   
 
   
   
   
   
 
   
   
   
   
 
   
   
   
   
Consolidated Statements of Cash Flows Data:

Net cash provided by operating activities

Net cash used in investing activities

Net cash used in financing activities

Consolidated Balance Sheet Data—(at period end):

Cash and cash equivalents
Net property (1)
Total assets (2)
Total debt (2), (3)
Total stockholders’ equity

2019

2018

2017

2016

2015

Fiscal Year

$

$

$

$

$

$

$

$

36,135   $

45,442   $

53,671   $

49,299   $

57,971

(10,669)   $

(27,802)   $

(36,238)   $

(35,202)   $

(30,835)

(24,365)   $

(19,221)   $

(11,051)   $

(18,030)   $

(32,534)

8,070   $

6,969   $

8,550   $

2,168   $

6,101

91,778   $

104,145   $

102,794   $

118,470   $

102,421

624,752   $

450,226   $

442,711   $

471,305   $

461,028

97,000   $

74,184   $

93,316   $

104,461   $

123,638

245,566   $

265,236   $

274,950   $

265,182   $

244,633

(1)

(2)

(3)

Net property consists of property and equipment, net of accumulated depreciation and amortization.

On December 27, 2018 we adopted ASU No. 2016-02, “Leases (Topic 842)". Results for reporting periods beginning on or after December 27,
2018 are presented under Topic 842. Prior period amounts were not revised and continue to be reported in accordance with ASC Topic 840
("Topic 840"), the accounting standard then in effect. See "Note 2. Summary of Significant Accounting Policies - Change in Accounting Policies"
and "Note 5. Leases" for further information.

Total debt consists of borrowings under the 2018 Revolver and the 2014 Revolver (each, as defined below in "Item 7. Management’s Discussion
and Analysis of Financial Condition and Results of Operations—Liquidity and Capital Resources—Debt and Other Obligations”), and our capital
lease obligations in 2018 and prior.

ITEM 7.

MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF OPERATIONS

The following discussion should be read in conjunction with "Item 6. Selected Financial Data,” and our "Audited Consolidated Financial Statements" and
accompanying "Notes to Consolidated Financial Statements" included elsewhere in this Annual Report. In addition to historical information, this
discussion contains forward-looking statements that involve risks, uncertainties, and assumptions that could cause actual results to differ materially from
management’s expectations. See “Forward-Looking Statements” and "Item 1A. Risk Factors” included elsewhere in this Annual Report. We assume no
obligation to update any of these forward-looking statements.

Basis of Presentation

We use a 52- or 53-week fiscal year ending on the last Wednesday of each calendar year. Fiscal 2019, 2018, and 2017 ended on December 25, 2019,
December 26, 2018 and December 27, 2017, respectively. In a 52-week fiscal year, each quarter includes 13 weeks of operations. In a 53-week fiscal year,
the first, second and third quarters each include 13 weeks of operations, and the fourth quarter includes 14 weeks of operations. Approximately every six or
seven years a 53-week fiscal year occurs. Fiscal 2019, 2018, and 2017 were 52-week fiscal years. 53-week years may cause revenues, expenses, and other
results of operations to be higher due to the additional week of operations. Fiscal years are identified in this report according to the calendar years in which
they ended. For example, references to fiscal 2019 refer to the fiscal year ended December 25, 2019.

35

 
 
 
 
 
 
 
   
   
   
   
 
 
 
 
 
 
 
 
 
Overview

El Pollo Loco is a differentiated and growing restaurant concept that specializes in fire-grilling citrus-marinated chicken and operates in the LSR segment.
We strive to offer food that integrates the culinary traditions of Mexico with the healthier lifestyle of Los Angeles, a combination that we call “LA-Mex”.
Our distinctive menu features our signature product--citrus-marinated fire-grilled chicken--and a variety of Mexican and LA-inspired entrees that we create
from our chicken. We serve individual and family-sized chicken meals, a variety of Mexican and LA-inspired entrees, and sides, and, throughout the year,
on a limited-time basis, additional proteins like shrimp. Our entrees include favorites such as our Chicken Avocado Burrito, Under 500 Calorie entrees,
chicken tostada salads, and Pollo Bowls. Our famous Creamy Cilantro dressings and salsas are prepared fresh daily, allowing our customers to create their
favorite flavor profiles to enhance their culinary experience. Our distinctive menu with healthier alternatives appeals to consumers across a wide variety of
socio-economic backgrounds and drives our balanced composition of sales throughout the day (our “day-part mix”), including at lunch and dinner.

Growth Strategies and Outlook

We plan to continue to expand our business, drive restaurant sales growth, enhance our competitive positioning, and improve our operations by executing
our Transformation Agenda, which consists of the following four key strategies:

•

•

•

•

Develop a people-first culture - invest in and grow our talent;

Differentiate the brand - accentuate our strengths and build upon them;

Simplify operations - make it easier for employees and franchisees to run our restaurants; and

Grow the business - responsibly and profitably for the long term.

As of December 25, 2019, we had 482 locations in six states. In fiscal 2019, we opened two new company-operated restaurants and our franchisees opened
two new restaurants all in California. In fiscal 2018, we opened eight new company-operated and nine new franchised restaurants across Arizona,
California, Utah, Louisiana and Texas. In 2020, we intend to open three to four new company-operated and five to eight new franchised restaurants. To
increase comparable restaurant sales, we plan to increase customer frequency, attract new customers, and improve per-person spend.

Highlights and Trends

Comparable Restaurant Sales

In fiscal 2019, 2018, and 2017, comparable restaurant sales system-wide increased 2.0%, 1.2%, and 1.5%, respectively. Comparable restaurant sales growth
reflects the change in year-over-year sales for the comparable restaurant base. A restaurant enters our comparable restaurant base the first full week after its
15-month anniversary. System-wide comparable restaurant sales include restaurant sales at all comparable company-operated restaurants and at all
comparable franchised restaurants, as reported by franchisees. Comparable restaurant sales at company-operated restaurants increased 1.9% in fiscal 2019,
0.4% in fiscal 2018, and 1.0% in fiscal 2017. In fiscal 2019, the increase in company-operated comparable restaurant sales was primarily the result of an
increase in average check size of 2.9%, partially offset by a decrease in transactions of 1.0%. The increase in average check includes a 3.6% benefit from
gross menu price increases that were implemented during 2018 and 2019. In fiscal 2018, the increase in company-operated comparable restaurant sales was
primarily the result of an increase in average check size of 1.4%, partially offset by a decrease in transactions of 1.0%. In fiscal 2017, the increase in
company-operated comparable restaurant sales was driven by an increase in average check size of 1.9%, partially offset by a decrease in transactions of
0.9%. In fiscal 2019, 2018, and 2017, comparable restaurant sales at franchised restaurants increased 2.0%, 1.8%, and 1.8%, respectively.

Restaurant Development

In fiscal 2019, we opened two company-operated restaurants, and our franchisees opened two new restaurants. From time to time, we and our franchisees
close restaurants. In fiscal 2019, we closed four restaurants and our franchisees closed two restaurants. Additionally, we sold 16 company-operated
restaurants to franchisees. Our restaurant counts at the beginning and end of each of the last three years were as follows:

36

Company-operated restaurant activity:

Beginning of period

Openings

Restaurant sale to franchisee

Closures

Restaurants at end of period

Franchised restaurant activity:

Beginning of period

Openings

Restaurant sale to franchisee

Closures

Restaurants at end of period

Total restaurant activity:

Beginning of period

Openings

Closures

Restaurants at end of period

2019

Fiscal Year

2018

2017

213  

2  

(16)  

(4)  

195  

271  

2  

16  

(2)  

287  

484  

4  

(6)  

482  

212  

8  

—  

(7)  

213  

265  

9  

—  

(3)  

271  

477  

17  

(10)  

484  

201

16

—

(5)

212

259

7

—

(1)

265

460

23

(6)

477

As of December 25, 2019, together with our franchisees, we have remodeled 34 company-operated and 44 franchised restaurants using our newest Vision
restaurant design. The Vision design elevates the brand image with exterior and interior features that embrace the brand’s authentic roots with warm
textures, rustic elements and a focus on the signature open kitchen layout established in previous designs. As of December 25, 2019, including new builds
and remodels, we had 119 restaurants open with the "Vision" design in our system. Remodeling is a use of cash and has implications for our net property
and depreciation line items on our consolidated balance sheets and statements of operations, among others. The cost of our restaurant remodels varies
depending on the scope of work required, but on average the investment is $0.3 to $0.4 million per restaurant. We believe that our remodeling program will
result in higher restaurant revenue and a strengthened brand. In addition, we are currently working on a new asset design that we believe will clearly
differentiate and communicate our brand, both on the exterior and interior. We believe that this new design will deliver good new unit volumes and cash on
cash returns in both existing and new markets. We also believe that our remodels using this new design will result in higher restaurant revenue and a
strengthened brand. This new design replaces our “Vision” design, which was implemented in 2016.

Loco Rewards

During the second quarter of 2017, we introduced a new loyalty rewards points program in an effort to increase sales and loyalty among our customers, by
offering rewards that incentivize customers to visit our restaurants more often each month. Customers earn 1 point for each $1 spent and 100 points can be
redeemed for a $10 reward to be used for a future purchase. If a customer does not earn or use points within a one-year period, their account is deactivated
and all points expire. Additionally, if a $10 reward is not used within six months, it expires. When a customer is part of the rewards program, the obligation
to provide future discounts related to points earned is considered a separate performance obligation, to which a portion of the transaction price is allocated.
The performance obligation related to loyalty points is deemed to have been satisfied, and the amount deferred in the balance sheet is recognized as
revenue, when the points are transferred to a $10 reward and redeemed, the reward or points have expired, or the likelihood of redemption is remote. A
portion of the transaction price is allocated to loyalty points, if necessary, on a pro-rata basis, based on stand-alone selling price, as determined by menu
pricing and loyalty point's terms.

In addition, customers can earn additional points and free entrées for a variety of engagement activities. As points are available for redemption past the
quarter earned, a portion of the revenue associated with the earned points will be deferred until redemption or expiration. As of December 25, 2019, the
amount of revenue deferred related to the earned points, net of redemptions, is $1.1 million. The Company had more than 1.5 million loyalty program
members as of December 25, 2019.

Key Financial Definitions

Revenue

37

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Our revenue is derived from two primary sources: company-operated restaurant revenue and franchise related revenue. Beginning in fiscal 2018 with the
adoption of Accounting Standards Update ("ASU") ASU 2014-09, franchise related revenue includes franchise advertising fee revenue representing
advertising contributions received from franchisees and franchise revenue, which is comprised primarily of franchise royalties and, to a lesser extent,
franchise fees and sublease rental income.

Food and Paper Costs

Food and paper costs include the direct costs associated with food, beverage and packaging of our menu items. The components of food and paper costs are
variable in nature, change with sales volume, are impacted by menu mix, and are subject to increases or decreases in commodity costs.

Labor and Related Expenses

Labor and related expenses include wages, payroll taxes, workers’ compensation expense, benefits, and bonuses paid to our restaurant management teams.
Like other expense items, we expect labor costs to grow proportionately as our restaurant revenue grows. Factors that influence labor costs include
minimum wage and payroll tax legislation, the frequency and severity of workers’ compensation claims, health care costs, and the performance of our
restaurants.

Occupancy Costs and Other Operating Expenses

Occupancy costs include rent, common area maintenance, and real estate taxes. Other restaurant operating expenses include the costs of utilities,
advertising, credit card processing fees, restaurant supplies, repairs and maintenance, and other restaurant operating costs.

General and Administrative Expenses

General and administrative expenses are comprised of expenses associated with corporate and administrative functions that support the development and
operations of our restaurants, including compensation and benefits, travel expenses, stock compensation costs, legal and professional fees, and other related
corporate costs. Also included are pre-opening costs, and expenses above the restaurant level, including salaries for field management, such as area and
regional managers, and franchise field operational support.

Legal Settlements

Legal settlements include expenses such as judgments or settlements related to legal matters, legal claims and class action lawsuits.

Franchise Expenses

Franchise expenses prior to fiscal 2018 were primarily comprised of rent expenses incurred on properties leased by us and then sublet to franchisees, and
expenses incurred in support of franchisee information technology systems. Beginning in fiscal 2018 with the adoption of ASU 2014-09, franchise
expenses also include all expenses of the advertising fund representing the franchised restaurants portion of advertising expenses.

Depreciation and Amortization

Depreciation and amortization primarily consist of the depreciation of property and equipment, including leasehold improvements and equipment.

Loss on Disposal of Assets

Loss on disposal of assets includes the loss on disposal of assets related to retirements and replacement or write-off of leasehold improvements or
equipment.

Impairment and Closed-Store Reserves

We review long-lived assets such as property, equipment, and intangibles, as well as ROU assets in a net asset position, on a unit-by-unit basis for
impairment when events or circumstances indicate a carrying value of the assets that may not be

38

recoverable. We determine if there is impairment at the restaurant level by comparing undiscounted future cash flows from the related long-lived assets to
their respective carrying values, and record an impairment charge when appropriate. In determining future cash flows, significant estimates are made by us
with respect to future operating results of each restaurant over its remaining lease term, including sales trends, labor rates, commodity costs and other
operating cost assumptions. If assets are determined to be impaired, the impairment charge is measured by calculating the amount by which the asset
carrying amount exceeds its fair value. This process of assessing fair values requires the use of estimates and assumptions, including our ability to sell or
reuse the related assets and market conditions, which are subject to a high degree of judgment. If these assumptions change in the future, we may be
required to record impairment charges for these assets and these charges could be material.

Prior to the adoption of Topic 842 "Leases," closure costs include non-cash restaurant charges such as up-front expensing of the net present value of unpaid
rent remaining on the life of a lease, offset by assumed sublease income. Upon the adoption of Topic 842, the Company no longer recognizes a closed-store
reserve when the Company closes a restaurant, as a lease liability related to the future lease payments is already recognized. Rather, when a restaurant is
closed, the Company will evaluate the ROU asset for impairment, based on anticipated sublease recoveries. The remaining value of the ROU asset is
amortized on a straight-line basis, with the expense recognized in closed-store reserve expense.

Loss on Disposition of Restaurants

Loss on disposal of restaurants includes the loss on the sale of restaurants to franchisees, or other third parties, and includes the difference between carrying
value and sales price of leasehold improvements, equipment and other assets included in the sale.

Interest Expense, Net

Interest expense, net, consists primarily of interest on our outstanding revolving debt. Debt issuance costs are amortized on a straight-line basis over the life
of the related debt.

Provision (Benefit) for Income Taxes

Provision (benefit) for income taxes consists of federal and state tax expense (recoveries) on our income (loss), and changes to our deferred tax asset and
deferred tax liability.

Results of Operations

Fiscal Year 2019 Compared to Fiscal Year 2018

Our operating results for the fiscal years ended December 25, 2019 and December 26, 2018, in absolute terms and expressed as a percentage of total
revenue, with the exception of cost of operations and company restaurant expenses, which are expressed as a percentage of company-operated restaurant
revenue, are compared below:

39

2019
(52-Weeks)

Fiscal Year

2018
(52-Weeks)

Increase / (Decrease)

($ ,000)

(%)

($ ,000)

(%)

($ ,000)

(%)

Statements of Operations Data:

Revenue

Company-operated restaurant revenue

$

391,112  

88.4   $

388,835  

89.2   $

Franchise revenue

Franchise advertising fee revenue

Total revenue

Cost of operations

Food and paper costs (1)

Labor and related expenses (1)

Occupancy and other operating expenses (1)

Company restaurant expenses (1)

General and administrative expenses

Legal settlements

Franchise expenses

Depreciation and amortization

Loss on disposal of assets

Recovery of securities lawsuits related legal expenses

Impairment and closed-store reserves

Loss on disposition of restaurants

Total expenses

Income (loss) from operations

Interest expense, net

Income tax receivable agreement expense (income)

Income (loss) before provision for income taxes

Provision (benefit) for income taxes

28,819  

22,399  

6.5  

5.1  

25,771  

21,222  

5.9  

4.9  

442,330  

100.0  

435,828  

100.0  

109,264  

116,703  

92,005  

317,972  

40,389  

—  

27,612  

17,855  

266  

(10,000)  

4,852  

5,058  

27.9  

29.8  

23.5  

81.3  

9.1  

—  

6.2  

4.0  

0.1  

(2.3)  

1.1  

1.1  

111,142  

112,417  

91,385  

314,944  

50,261  

36,258  

24,429  

17,825  

278  

(8,356)  

9,650  

—  

28.6  

28.9  

23.5  

81.0  

11.5  

8.3  

5.6  

4.1  

0.1  

(1.9)  

2.2  

—  

2,277  

3,048  

1,177  

6,502  

(1,878)  

4,286  

620  

3,028  

(9,872)  

(36,258)  

3,183  

30  

(12)  

(1,644)  

(4,798)  

5,058  

185  

818  

46,784  

12,890  

0.6

11.8

5.5

1.5

(1.7)

3.8

0.7

1.0

(19.6)

(100.0)

13.0

0.2

(4.3)

19.7

(49.7)

N/A

(9.3)

5.3

(107.5)

(383.4)

(401.8)

(376.9)

404,004  

91.3  

445,289  

102.2  

(46,343)  

47,787  

(505.1)

38,326  

3,687  

57  

34,582  

9,682  

8.7  

0.8  

0.0  

7.8  

2.2  

(9,461)  

3,502  

(761)  

(12,202)  

(3,208)  

(2.2)  

0.8  

(0.2)  

(2.8)  

(0.7)  

Net income (loss)

$

24,900  

5.6   $

(8,994)  

(2.1)   $

33,894  

(1)

Percentages for line items relating to cost of operations and company restaurant expenses are calculated with company-operated restaurant revenue
as the denominator. All other percentages use total revenue.

Company-Operated Restaurant Revenue

In fiscal 2019, company-operated restaurant revenue increased $2.3 million, or 0.6%, due to $7.6 million of additional sales from restaurants opened during
or after the first quarter of the prior year. In addition, company-operated revenue was favorably impacted by an increase in company-operated comparable
restaurant sales of $7.0 million, or 1.9%, and an increase in other revenue of $0.6 million. The growth in company-operated comparable restaurant sales
was due primarily to an increase in average check size of 2.9%, partially offset by a decline in transactions of 1.0%, compared to the prior year. The
increase in average check includes a 3.6% benefit from gross menu price increases that were implemented during 2018 and 2019. The increase in company-
operated restaurant revenue was partially offset by $12.9 million of net impact of lost sales from restaurants closed in fiscal 2019 and 2018, and the 16
company-operated restaurants sold by the Company to franchisees during the 2019.

Franchise Revenue

In fiscal 2019, franchise revenue increased $3.0 million, or 11.8%. This increase was primarily due to higher fees received from franchised restaurants
related to their use of our point-of-sales system, a franchise comparable restaurant sales increase of 2.0%, the opening of 11 new franchised restaurants
during or after the first quarter of the prior year and 16 company-operated restaurants sold by the Company to franchisees during the year. This franchise
revenue increase was partially offset by the closure of five franchise locations during the same period.

40

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Franchise Advertising Fee Revenue

Franchise advertising fee revenue increased, which is paid as a percentage of the franchise restaurants' net sales, $1.2 million, or 5.5% from the comparable
period in the prior year. This increase was primarily due to an increase in the number of franchise locations and increased franchise comparable restaurant
sales.

Food and Paper Costs

Food and paper costs decreased $1.9 million, or 1.7%, in fiscal 2019, due to a $1.8 million decrease in food costs and a $0.1 million decrease in paper
costs. The decrease in food and paper costs resulted primarily from lower company transactions, partially offset by higher commodity inflation. Food and
paper costs as a percentage of company-operated restaurant revenue were 27.9% in fiscal 2019, compared to 28.6% in fiscal 2018. This percentage
decrease was due primarily to an increase in pricing, partially offset by commodity inflation.

Labor and Related Expenses

Payroll and benefit expenses increased $4.3 million, or 3.8% in fiscal 2019. This increase was due primarily to additional labor needs arising from the
opening of two new restaurants in fiscal 2019 and eight new restaurants in fiscal 2018, minimum wage increases in California and, specifically, Los
Angeles, and higher workers' compensation expense due to increased claims activity, partially offset by a reduction in labor for restaurant closures and
locations sold to franchisees in fiscal 2019 and 2018. Payroll and benefit expenses as a percentage of company-operated restaurant revenue were 29.8% in
fiscal 2019, compared to 28.9% in fiscal 2018. This increase was primarily due to the wage increases noted above, partially offset by higher restaurant
revenue from increases in pricing.

Occupancy and Other Operating Expenses

Occupancy and other operating expenses increased $0.6 million, or 0.7%, in fiscal 2019. This increase for the year-to-date period was due to a $1.1 million
increase in customer order delivery fees due to increased delivery orders, a $0.2 million increase in repair and maintenance costs and a $0.2 million
increase in utilities costs. These increases were partially offset by a $0.8 million decrease in advertising costs and a $0.1 million decrease in other operating
expenses. Occupancy and other operating expenses as a percentage of company-operated restaurant revenue was 23.5% for both fiscal 2019 and fiscal
2018, primarily due to the higher costs noted above, offset by increased pricing.

General and Administrative Expenses

General and administrative expenses decreased $9.9 million, or 19.6%, in fiscal 2019. The decrease for the year-to-date period was due primarily to (i) a
$10.2 million decrease in legal expenses related primarily to a decrease in securities class action litigation costs, (ii) a $0.5 million decrease in restaurant
pre-opening costs, (iii) a $0.3 million decrease in travel expense and (iv) a $0.3 million decrease in recruiting costs. These decreases were partially offset
by a $0.6 million increase in labor related costs, primarily related to an increase in estimated management bonus expenses, a $0.5 million increase in stock
compensation expenses and a $0.3 million increase in other general and administrative expenses. General and administrative expenses as a percentage of
total revenue were 9.1% in fiscal 2019, compared to 11.5% in fiscal 2018. This decrease is primarily due to the cost decreases noted above.

Legal Settlements

Legal settlements decreased $36.3 million in fiscal 2019. The decrease was due to (i) an accrual in 2018 of a settlement amount in fiscal 2019 related to an
agreement in principle to settle all claims and allegations for the securities class action as discussed in "Note 13. Commitments and Contingencies—Legal
Matters" in the accompanying "Notes to Consolidated Financial Statements" in this Annual Report and (ii) an accrual in 2018 of an expected settlement
amount related to an agreement in principle to settle all claims and allegations related to multiple wage and hour class action suits as discussed in "Note 13.
Commitments and Contingencies—Legal Matters" in the accompanying "Notes to Consolidated Financial Statements" in this Annual Report.

Franchise Expenses

Franchise expenses increased $3.2 million, or 13.0%, in fiscal 2019. The increase for the year-to-date period was primarily due to increase in expenses
initially paid by the Company on behalf of the franchisee, and subsequently reimbursed by the

41

franchisee. Specifically, related to advertising expenses, rent expense for locations sub-leased and the franchisee use of our point-of-sale system.

Impairment and Closed-Store Reserves

During fiscal 2019, we determined that the carrying value of ROU assets and long-lived assets at certain restaurants may not be recoverable. As a result, we
recorded a $3.6 million impairment expense primarily related to the carrying value of the ROU assets of four restaurants sold to franchisees and one
restaurant closed during fiscal 2019, and the long-lived assets of one restaurant in California.

During fiscal 2018, we determined that the carrying value of assets at certain restaurants may not be recoverable. As a result, we recorded a $5.1
million impairment expense primarily related to four restaurants, in Arizona, California and Texas, including a restaurant in Texas that opened in early
2018.

During fiscal 2018, we closed seven restaurants in Arizona, California and Texas. These closures resulted in closed-store reserve expenses of $4.5 million
during fiscal 2018.

Subsequent to the adoption of Topic 842, the Company no longer recognizes a closed-store reserve when the Company closes a restaurant, as there is
already a lease liability on its books related to the future lease payments. Rather, when a restaurant is closed, the Company will evaluate the ROU Asset for
impairment, based on anticipated sublease recoveries. The remaining value of the ROU Asset is amortized on a straight-line basis, with the expense
recognized in closed-store reserve expense.

During the fiscal 2019, the Company closed two restaurants in California and two in Texas and recognized $1.3 million of closed-store reserve expense for
fiscal 2019, primarily related to the amortization of ROU assets for the closed stores.

The Company continues to monitor the recoverability of the carrying value of the assets of several other restaurants.

Interest Expense, Net

For fiscal 2019, net interest expense, increased by $0.2 million, primarily due to higher outstanding balances on our 2018 Revolver (as defined below),
partially offset by interest income received related to the interest rate swap entered into during fiscal 2019. See "Note 6, Long-Term Debt, Interest Rate
Swap."

Income Tax Receivable Agreement

In fiscal 2019 we recognized income tax receivable agreement expense of $0.1 million as a result of changes to future forecasted results. In 2018, we
incurred income tax receivable agreement income of $0.8 million, resulting from changes to future forecasted results and timing of the deductibility of
certain temporary differences including the current year legal settlement accrual. In fiscal 2019 and 2018, we paid $5.8 million and $7.3 million,
respectively, to our pre-IPO stockholders under the TRA.

Provision for Income Taxes

In fiscal 2019, we recorded an income tax expense of $9.7 million, compared to income tax benefit of $3.2 million in fiscal 2018, reflecting an estimated
effective tax rate of 28.0% and 26.3%, respectively. The higher effective tax rate in 2019 resulted primarily from an increase in disallowed executive
compensation under section 162(m) and a decrease in benefit from Workers Opportunity Tax Credit relative to pretax book income. In addition, there was a
$1.0 million valuation allowance against our deferred tax assets recorded in each of fiscal 2018 and fiscal 2017. The valuation allowance against our
deferred tax assets resulted from certain tax credits that may not be realizable prior to the time the credits expire.

42

Fiscal Year 2018 Compared to Fiscal Year 2017

Our operating results for the fiscal years ended December 26, 2018 and December 27, 2017, in absolute terms and expressed as a percentage of total
revenue, with the exception of cost of operations and company restaurant expenses, which are expressed as a percentage of company-operated restaurant
revenue, are compared below:

2018
(52-Weeks)

Fiscal Year

2017
(52-Weeks)

Increase / (Decrease)

($ ,000)

(%)

($ ,000)

(%)

($ ,000)

(%)

Statements of Operations Data:

Revenue

Company-operated restaurant revenue

$

388,835  

89.2   $

376,615  

93.8   $

12,220  

25,771  

21,222  

5.9  

4.9  

25,086  

—  

6.2  

—  

435,828  

100.0  

401,701  

100.0  

Franchise revenue

Franchise advertising fee revenue

Total revenue

Cost of operations

Food and paper costs (1)

Labor and related expenses (1)

Occupancy and other operating expenses (1)

Company restaurant expenses (1)

General and administrative expenses

Legal settlements

Franchise expenses

Depreciation and amortization

Loss on disposal of assets

Recovery of securities lawsuits related legal expenses

Impairment and closed-store reserves

Total expenses

(Loss) income from operations

Interest expense, net

Income tax receivable agreement income

(Loss) income before provision for income taxes

(Benefit) provision for income taxes

Net (loss) income

111,142  

112,417  

91,385  

314,944  

50,261  

36,258  

24,429  

17,825  

278  

(8,356)  

9,650  

28.6  

28.9  

23.5  

81.0  

11.5  

8.3  

5.6  

4.1  

0.1  

(1.9)  

2.2  

109,898  

106,584  

85,631  

302,113  

38,523  

—  

3,335  

18,128  

799  

(1,666)  

33,645  

445,289  

102.2  

394,877  

(9,461)  

3,502  

(761)  

(12,202)  

(3,208)  

(8,994)  

$

(2.2)  

0.8  

(0.2)  

(2.8)  

(0.7)  

6,824  

3,278  

(5,570)  

9,116  

497  

685  

21,222  

34,127  

1,244  

5,833  

5,754  

12,831  

11,738  

36,258  

21,094  

(303)  

(521)  

(6,690)  

(23,995)  

50,412  

224  

4,809  

(21,318)  

(3,705)  

29.2  

28.3  

22.7  

80.2  

9.6  

—  

0.8  

4.5  

0.2  

(0.4)  

8.4  

98.3  

1.7  

0.8  

(1.4)  

2.3  

0.1  

3.2

2.7

N/A

8.5

1.1

5.5

6.7

4.2

30.5

N/A

632.5

(1.7)

(65.2)

401.6

(71.3)

12.8

6.8

(86.3)

(233.9)

(745.5)

(204.4)

(16,285)  

(238.6)

(2.1)   $

8,619  

2.1   $

(17,613)  

(1)

Percentages for line items relating to cost of operations and company restaurant expenses are calculated with company-operated restaurant revenue
as the denominator.  All other percentages use total revenue.

Company-Operated Restaurant Revenue

In fiscal 2018, company-operated restaurant revenue increased $12.2 million, or 3.2%, due to $16.3 million of additional sales from new restaurants. In
addition, company-operated revenue was favorably impacted by an increase in company-operated comparable restaurant sales of $1.6 million, or 0.4%. The
increase in average check includes a 2.1% benefit from gross menu price increases that were implemented during 2017 and 2018. The growth in company-
operated comparable restaurant sales was due primarily to an increase in average check size of 1.4%, partially offset by a decline in transactions of 1.0%,
compared to the prior year. The increase in company-operated restaurant revenue was partially offset by $5.3 million of net impact of lost sales from closed
restaurants in fiscal 2018 and 2017, and a $0.4 million decrease in other revenue.

43

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Franchise Revenue

In fiscal 2018, franchise revenue increased $0.7 million, or 2.7%. This increase was due primarily to an increase in franchised comparable restaurant sales
of 1.8%, and higher sales revenue resulting from additional franchise units. This was partially offset by a decline in franchise agreement and development
agreement fees and lower levels of rent received from franchised restaurants related to their use of our owned or leased properties.

Franchise Advertising Fee Revenue

Beginning in fiscal 2018, we implemented ASU 2014-09, which requires us to present franchise advertising contributions received from franchisees as
franchise advertising fee revenue and record all expenses of the advertising fund within franchise expenses, resulting in an increase in revenues and
expenses on our consolidated statements of operations. As such, franchise revenue increased $21.2 million, from the comparable period in the prior year, as
this was the first year of implementation. Refer to the Consolidated Financial Statements, "Note 15, Revenue from Contracts with Customers", in the
accompanying "Notes to Consolidated Financial Statements" in this Annual Report for further details.

Food and Paper Costs

Food and paper costs increased $1.2 million in fiscal 2018, due to a $0.6 million increase in food costs and a $0.6 million increase in paper costs. This
increase was due primarily to higher restaurant revenue. Food and paper costs as a percentage of company-operated restaurant revenue were 28.6% in fiscal
2018, compared to 29.2% in fiscal 2017. This percentage decrease was due primarily to higher restaurant revenues due to increases in pricing.

Labor and Related Expenses

Payroll and benefit expenses increased $5.8 million in fiscal 2018. This increase was due primarily to additional labor needs arising from the opening
of eight new restaurants in fiscal 2018 and 16 new restaurants in fiscal 2017 (partially offset by reduced labor for restaurant closures in
fiscal 2018 and 2017), minimum wage increases in California and Los Angeles, and higher group insurance costs due to increased claims activity. Payroll
and benefit expenses as a percentage of company-operated restaurant revenue were 28.9% in fiscal 2018, compared to 28.3% in fiscal 2017. This increase
was primarily due to the wage increases noted above, partially offset by higher restaurant revenue from increases in pricing.

Occupancy and Other Operating Expenses

Occupancy and other operating expenses increased $5.8 million in fiscal 2018. This increase for the year-to-date period was due to a $1.8 million increase
in occupancy costs, due primarily to additional rent and property tax, a $1.3 million increase in other controllable costs, resulting primarily from an
increase in operating supply costs and trash collection costs, a $1.0 million increase in advertising costs and a $0.8 million increase in other operating
expenses, resulting primarily from an increase in credit card fees and customer order delivery fees. The increases in fiscal 2018 were partially due to new
restaurant openings during or after the first quarter of 2017. Occupancy and other operating expenses as a percentage of company-operated restaurant
revenue was 23.5% in fiscal 2018, compared to 22.7% in fiscal 2017. This increase is primarily due to the higher costs noted above.

General and Administrative Expenses

General and administrative expenses increased $11.7 million in fiscal 2018. The increase was due primarily to (i) an $8.7 million increase in legal expense
primarily related to the securities class action as discussed in "Note 13. Commitments and Contingencies—Legal Matters" in the accompanying "Notes to
Consolidated Financial Statements" in this Annual Report, (ii) a $1.4 million increase in payroll expense due primarily to an increase in our accrual for our
annual bonus program and an increase in severance costs related to executive terminations, (iii) a $0.9 million increase in stock compensation related
expenses, primarily related to the stock modification discussed in "Note 11. Stock-Based Compensation" in the accompanying "Notes to Consolidated
Financial Statements" in this Annual Report and (iv) a $0.5 million increase in other professional fees, primarily related to general internal audit control
development and effectiveness testing as well as additional tax services during 2018. These increases were partially offset by a $1.1 million decrease in
new restaurant opening costs. General and administrative expenses as a percentage of total revenue was 11.5% in fiscal 2018, compared to 9.6% in
fiscal 2017. This increase is primarily due to the higher costs noted above.

Legal Settlements

44

Legal settlements increased $36.3 million in fiscal 2018. The increase was due to (i) an accrual of an expected settlement amount in fiscal 2018 related to
an agreement in principle to settle all claims and allegations for the securities class action as discussed in "Note 13. Commitments and Contingencies—
Legal Matters" in the accompanying "Notes to Consolidated Financial Statements" in this Annual Report and (ii) an accrual of an expected settlement
amount in fiscal 2018 related to an agreement in principle to settle all claims and allegations related to multiple wage and hour class action suits as
discussed in "Note 13. Commitments and Contingencies—Legal Matters" in the accompanying "Notes to Consolidated Financial Statements" in this
Annual Report.

Franchise Expenses

Beginning in fiscal 2018, we implemented ASU 2014-09, which requires us to present franchise advertising contributions received from franchisees as
franchise advertising fee revenue and record all expenses of the advertising fund within franchise expenses, resulting in an increase in revenues and
expenses on our consolidated statements of income. As such, franchise expenses increased by $21.1 million, from the comparable period in the prior year,
representing the presentation of advertising fund expenses within franchise expenses as this was the first year of implementation. Refer to the Consolidated
Financial Statements, "Note 15, Revenue from Contracts with Customers", in the accompanying "Notes to Consolidated Financial Statements" in this
Annual Report for further details.

Impairment and Closed-Store Reserves

During fiscal 2018, we determined that the carrying value of assets at certain restaurants may not be recoverable. As a result, we recorded a $5.1
million impairment expense primarily related to four restaurants, in Arizona, California and Texas, including a restaurant in Texas that opened in early
2018. During fiscal 2017, we determined that the carrying value of the assets of 21 restaurants, in Arizona, California and Texas, may not be recoverable.
Additionally, we made a strategic decision to close two additional restaurants in Texas. As a result, we recorded a $32.6 million impairment expense. The
impairment expense for fiscal 2017 included an impairment expense of $27.7 million, representing the entire remaining value of capitalized assets of all of
our company-operated restaurants in Texas, net of previously recorded depreciation. Factors which led to the impairment of our Texas restaurants included
operating results, which indicated that the restaurants did not achieve the sales volumes required to generate positive cash flows or improve profitability in
the Texas market, along with the related future cash flow assumptions, including comparable sales rate growth and restaurant operating costs, over the
remaining lease terms and the age of the restaurants in Texas. The restaurants in Texas began opening in late 2014, causing a higher net book value at the
time of impairment testing, and increased difficulty projecting results for newer restaurants in newer markets.

During fiscal 2018, we closed seven restaurants in Arizona, California and Texas. These closures resulted in closed-store reserve expenses of $4.5
million during fiscal 2018. During fiscal 2017, we closed four restaurants in Texas, one of which was fully impaired during the fourth quarter of 2016, one
of which was fully impaired during the third quarter of 2016 and the other two were fully impaired in fiscal 2017. Additionally, we closed one restaurant in
Arizona, which was fully impaired in the third quarter of 2016. These closures resulted in closed-store reserve expenses of $1.1 million during fiscal 2017.

The Company continues to monitor the recoverability of the carrying value of the assets of several other restaurants.

Interest Expense, Net

For fiscal 2018, interest expense, net increased by $0.2 million primarily due to an increase in the interest rate on our revolving debt during 2018.

Income Tax Receivable Agreement

In fiscal 2018, we recognized income tax receivable agreement income of $0.8 million as a result of changes to future forecasted results and the timing of
the deductibility of certain temporary differences including the current year legal settlement accruals. In 2017 we incurred income tax receivable agreement
income of $5.6 million, resulting from the amortization of interest expense related to our total expected TRA payments, changes to future forecasted
results, the reduction of the expected TRA liability as a result of the impact of the Tax Cuts and Jobs Act (the “Tax Act") on the corporate tax rate on future
years, and expected realization of various pre-IPO tax credits. In fiscal 2018 and 2017, we paid $7.3 million and $11.1 million, respectively, to our pre-IPO
stockholders under the TRA.

Provision for Income Taxes

In fiscal 2018, we recorded an income tax expense of $3.2 million, compared to income tax expense of $0.5 million in fiscal 2017, reflecting an estimated
effective tax rate of 26.3% and 5.5%, respectively. The lower effective tax rate in 2017 resulted

45

primarily from the Tax Act enacted on December 22, 2017. The Tax Act had the following effects on our income tax expense for the year ended December
27, 2017:

•

•

•

Under ASC 740, Income Taxes, we are required to revalue any deferred tax assets or liabilities in the period of enactment by the change in tax
rates. The Tax Act lowers the corporate income tax rate from 35% to 21%. We estimated the impact of the revaluation of our deferred tax assets
and liabilities, resulting in a decrease to our net deferred income tax liability by $1.4 million which is reflected as a decrease in our income tax
expense in our results for fiscal 2017.

The reduced corporate tax rate, also resulted in a TRA benefit to the provision for income tax expense for fiscal 2017 in the amount of $2.0
million.

The Tax Act is generally effective for tax years beginning after December 31, 2017. As such, the reduction in the corporate income tax rate from
35% to 21% is effective for the fiscal year ended December 26, 2018.

In addition, there was a $1.0 million valuation allowance against our deferred tax assets recorded in each of fiscal 2018 and 2017. The valuation allowance
against our deferred tax assets resulted from certain tax credits that may not be realizable prior to the time the credits expire.

Key Performance Indicators

To evaluate the performance of our business, we utilize a variety of financial and performance measures. These key measures include company-operated
restaurant revenue, system-wide sales, comparable restaurant sales, company-operated average unit volumes ("AUV"), restaurant contribution, restaurant
contribution margin, new restaurant openings, EBITDA, and Adjusted EBITDA. In fiscal 2019, our restaurants generated company-operated restaurant
revenue of $391.1 million and system-wide sales of $894.5 million, and system comparable sales increased 2.0%, consisting of company-operated
restaurant comparable sales growth of 1.9% and franchised comparable sales growth of 2.0%. The company-operated comparable sales increase consisted
of a 2.9% check growth, partially offset by a 1.0% transaction decrease. In fiscal 2019, for company-operated restaurants, our annual AUV was $1.9
million, restaurant contribution margin was 18.7%, and Adjusted EBITDA was $62.5 million.

Company-Operated Restaurant Revenue

Company-operated restaurant revenue consists of sales of food and beverages in company-operated restaurants net of promotional allowances, employee
meals, and other discounts. Company-operated restaurant revenue in any period is directly influenced by the number of operating weeks in such period, the
number of open restaurants, and comparable restaurant sales.

Seasonal factors and the timing of holidays cause our revenue to fluctuate from quarter to quarter. Our revenue per restaurant is typically lower in the first
and fourth quarters due to reduced January and December transactions and higher in the second and third quarters. As a result of seasonality, our quarterly
and annual results of operations and key performance indicators such as company-operated restaurant revenue and comparable restaurant sales may
fluctuate.

System-Wide Sales

System-wide sales are neither required by, nor presented in accordance with, accounting principles generally accepted in the United States of America
(“GAAP”). System-wide sales are the sum of company-operated restaurant revenue and sales from franchised restaurants. Our total revenue in our
consolidated statements of operations is limited to company-operated restaurant revenue and franchise revenue from our franchisees. Accordingly, system-
wide sales should not be considered in isolation or as a substitute for our results as reported under GAAP. Management believes that system-wide sales are
an important figure for investors, because they are widely used in the restaurant industry, including by our management, to evaluate brand scale and market
penetration.

The following table reconciles system-wide sales to company-operated restaurant revenue and total revenue:

46

(Dollar amounts in thousands)
Company-operated restaurant revenue

Franchise revenue

Franchise advertising fee revenue

Total Revenue

Franchise revenue

Sales from franchised restaurants

System-wide sales

Comparable Restaurant Sales

2019

Fiscal Year

2018

$

391,112   $

388,835   $

28,819  

22,399  

442,330  

(51,218)  

503,413  

25,771  

21,222  

435,828  

(46,993)  

479,574  

$

894,525   $

868,409   $

2017

376,615

25,086

—

401,701

(25,086)

465,149

841,764

Comparable restaurant sales reflect year-over-year sales changes for comparable company-operated, franchised, and system-wide restaurants. A restaurant
enters our comparable restaurant base the first full week after it has operated for fifteen months. Comparable restaurant sales exclude restaurants closed
during the applicable period. At December 25, 2019, December 26, 2018 and December 27, 2017, there were 460, 449, and 424 comparable restaurants,
195, 195, and 181 company-operated and 265, 254 and 243 franchised, respectively. Comparable restaurant sales indicate the performance of existing
restaurants, since new restaurants are excluded. Comparable restaurant sales growth can be generated by an increase in the number of meals sold and/or by
increases in the average check amount, resulting from a shift in menu mix and/or higher prices resulting from new products or price increases.

Company-Operated Average Unit Volumes

We measure company-operated AUVs on both a weekly and an annual basis. Weekly AUVs consist of comparable restaurant sales over a seven-day period
from Thursday to Wednesday. Annual AUVs are calculated using the following methodology: First, we divide our total net sales for all company-operated
restaurants for the fiscal year by the total number of restaurant operating weeks during the same period. Second, we annualize that average weekly per-
restaurant sales figure by multiplying it by 52. An operating week is defined as a restaurant open for business over a seven-day period from Thursday to
Wednesday. This measurement allows management to assess changes in consumer spending patterns at our restaurants and the overall performance of our
restaurant base.

Restaurant Contribution and Restaurant Contribution Margin

Restaurant contribution and restaurant contribution margin are neither required by, nor presented in accordance with, GAAP. Restaurant contribution is
defined as company-operated restaurant revenue less company restaurant expenses which includes food and paper cost, labor and related expenses and
occupancy and other operating expenses, where applicable. Restaurant contribution excludes certain costs, such as general and administrative expenses,
depreciation and amortization, impairment and closed-store reserve and other costs that are considered normal operating costs and accordingly, restaurant
contribution is not indicative of overall Company results and does not accrue directly to the benefit of shareholders because of the exclusion of certain
corporate-level expenses. Restaurant contribution margin is defined as restaurant contribution as a percentage of net company-operated restaurant revenue.

Restaurant contribution and restaurant contribution margin are supplemental measures of operating performance of our restaurants, and our calculations
thereof may not be comparable to those reported by other companies. Restaurant contribution and restaurant contribution margin have limitations as
analytical tools, and you should not consider them in isolation or as substitutes for analysis of our results as reported under GAAP. Management uses
restaurant contribution and restaurant contribution margin as key metrics to evaluate the profitability of incremental sales at our restaurants, to evaluate our
restaurant performance across periods, and to evaluate our restaurant financial performance compared with our competitors. Management believes that
restaurant contribution and restaurant contribution margin are important tools for investors, because they are widely-used metrics within the restaurant
industry to evaluate restaurant-level productivity, efficiency, and performance. Restaurant contribution and restaurant contribution margin may also assist
investors in evaluating our business and performance relative to industry peers and provide greater transparency with respect to the Company's financial
condition and results of operation.

A reconciliation of restaurant contribution and restaurant contribution margin to company-operated restaurant revenue is provided below:

47

 
 
 
(Dollar amounts in thousands)

Restaurant contribution:

Income (loss) from operations

Add (less):

  General and administrative expenses

  Legal settlements

  Franchise expenses

  Depreciation and amortization

  Loss on disposal of assets

  Franchise revenue

  Franchise advertising fee revenue

  Recovery of securities lawsuits related legal expenses

  Impairment and closed-store reserves

Loss on sale of restaurants

Restaurant contribution

Company-operated restaurant revenue:

Total revenue

Less:

  Franchise revenue

  Franchise advertising fee revenue

Company-operated restaurant revenue

Restaurant contribution margin (%)

New Restaurant Openings

2019

Fiscal Year

2018

2017

$

38,326

  $

(9,461)

  $

6,824

40,389

—  

27,612

17,855

266

(28,819)

(22,399)

(10,000)

4,852

5,058

50,261

36,258

24,429

17,825

278

(25,771)

(21,222)

(8,356)

9,650

—  

73,140

  $

73,891

  $

38,523

—

3,335

18,128

799

(25,086)

—

(1,666)

33,645

—

74,502

442,330

  $

435,828

  $

401,701

(28,819)

(22,399)

(25,771)

(21,222)

(25,086)

—

391,112

  $

388,835

  $

376,615

18.7%  

19.0%  

19.8%

$

$

$

The number of restaurant openings reflects the number of new restaurants opened by us and our franchisees during a particular reporting period. Before a
new restaurant opens, we and our franchisees incur pre-opening costs, as described below. New restaurants often open with an initial start-up period of
higher than normal sales volumes, which subsequently decrease to stabilized levels. New restaurants typically experience normal inefficiencies in the form
of higher food and paper, labor, and other direct operating expenses and, as a result, restaurant contribution margins are generally lower during the start-up
period of operation. The average start-up period after which our new restaurants’ revenue and expenses normalize is approximately fourteen weeks. When
we enter new markets, we may be exposed to start-up times and restaurant contribution margins that are longer and lower than reflected in our average
historical experience.

EBITDA and Adjusted EBITDA

EBITDA represents net income (loss) before interest expense, provision (benefit) for income taxes, depreciation, and amortization. Adjusted EBITDA
represents net income (loss) before interest expense, provision (benefit) for income taxes, depreciation, amortization, and items that we do not consider
representative of our on-going operating performance, as identified in the reconciliation table below.

EBITDA and Adjusted EBITDA as presented in this Annual Report are supplemental measures of our performance that are neither required by, nor
presented in accordance with, GAAP. EBITDA and Adjusted EBITDA are not measurements of our financial performance under GAAP and should not be
considered as alternatives to net income, operating income, or any other performance measures derived in accordance with GAAP, or as alternatives to cash
flow from operating activities as a measure of our liquidity. In addition, in evaluating EBITDA and Adjusted EBITDA, you should be aware that in the
future we will incur expenses or charges such as those added back to calculate EBITDA and Adjusted EBITDA. Our presentation of EBITDA and Adjusted
EBITDA should not be construed as an inference that our future results will be unaffected by unusual or nonrecurring items.

48

 
 
 
 
 
   
   
 
   
   
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
   
   
 
 
 
 
 
 
   
   
EBITDA and Adjusted EBITDA have limitations as analytical tools, and you should not consider them in isolation, or as substitutes for analysis of our
results as reported under GAAP. Some of these limitations are (i) they do not reflect our cash expenditures, or future requirements for capital expenditures
or contractual commitments, (ii) they do not reflect changes in, or cash requirements for, our working capital needs, (iii) they do not reflect interest
expense, or the cash requirements necessary to service interest or principal payments, on our debt, (iv) although depreciation and amortization are non-cash
charges, the assets being depreciated and amortized will often have to be replaced in the future, and EBITDA and Adjusted EBITDA do not reflect any
cash requirements for such replacements, (v) they do not adjust for all non-cash income or expense items that are reflected in our statements of cash flows,
(vi) they do not reflect the impact of earnings or charges resulting from matters we consider not to be indicative of our on-going operations, and (vii) other
companies in our industry may calculate these measures differently than we do, limiting their usefulness as comparative measures.

We compensate for these limitations by providing specific information regarding the GAAP amounts excluded from such non-GAAP financial measures.
We further compensate for the limitations in our use of non-GAAP financial measures by presenting comparable GAAP measures more prominently.

We believe that EBITDA and Adjusted EBITDA facilitate operating performance comparisons from period to period by isolating the effects of some items
that vary from period to period without any correlation to core operating performance or that vary widely among similar companies. These potential
differences may be caused by variations in capital structures (affecting interest expense), tax positions (such as the impact on periods or companies of
changes in effective tax rates or net operating losses) and the age and book depreciation of facilities and equipment (affecting relative depreciation
expense). We also present EBITDA and Adjusted EBITDA because (i) we believe that these measures are frequently used by securities analysts, investors
and other interested parties to evaluate companies in our industry, (ii) we believe that investors will find these measures useful in assessing our ability to
service or incur indebtedness, and (iii) we use EBITDA and Adjusted EBITDA internally as benchmarks to compare our performance to that of our
competitors.

The following table sets forth reconciliations of our net (loss) income to EBITDA and Adjusted EBITDA:

Net income (loss)

Non-GAAP adjustments:

Provision (benefit) for income taxes

Interest expense, net

Depreciation and amortization

EBITDA

Stock-based compensation expense (a)

Loss on disposal of assets (b)

Recovery of securities lawsuits related legal expense (c)

Impairment and closed-store reserves (d)

Loss on disposition of restaurants (e)

Legal settlements (f)

Income tax receivable agreement expense (income) (g)

Securities class action legal expense (h)

Pre-opening costs (i)

Executive transition costs (j)

Adjusted EBITDA

2019

Fiscal Year

2018

2017

24,900   $

(8,994)   $

8,619

$

$

9,682  

3,687  

17,855  

(3,208)  

3,502  

17,825  

56,124   $

9,125   $

2,474  

266  

(10,000)  

4,852  

5,058  

—  

57  

3,181  

366  

151  

1,278  

278  

(8,356)  

9,650  

—  

36,258  

(761)  

13,532  

837  

1,081  

$

62,529   $

62,922   $

497

3,278

18,128

30,522

1,056

799

(1,666)

33,645

—

—

(5,570)

4,236

1,981

284

65,287

(a)

(b)

(c)

Includes non-cash, stock-based compensation, excluding stock-based compensation costs associated with the transition of our former CEO.

Loss on disposal of assets includes the loss on disposal of assets related to retirements and replacement or write-off of leasehold improvements or
equipment.

In fiscal 2019, we received insurance proceeds of $10.0 million related to the settlement of the securities class action lawsuit and in fiscal 2018 we
received insurance proceeds of $8.4 million related to the reimbursement of certain legal expenses paid in prior years for the defense of securities
lawsuits. See "Note 13. Commitments and Contingencies—Legal Matters" in the accompanying "Notes to Consolidated Financial Statements" in
this Annual Report.

49

 
 
 
 
 
 
 
 
 
(d)

Includes costs related to impairment of long-lived and ROU assets and closing restaurants. During fiscal 2019, we recorded impairment charges of
$3.6 million for the year ended December 25, 2019, primarily related to the carrying value of the ROU assets of four restaurants sold to
franchisees and one restaurant closed during fiscal 2019, and the long-lived assets of one restaurant in California. Additionally, during fiscal 2019,
we closed two restaurants in California and two restaurants in Texas and recognized $1.3 million of closed-store reserve expense for the fiscal year
ended 2019, primarily related to the amortization of ROU assets for closed stores.

In fiscal 2018, we recorded a non-cash impairment charge of $5.1 million, primarily related to the carrying value of four restaurants in Arizona,
California and Texas, including a restaurant in Texas that opened in early 2018. Additionally, during fiscal 2018, we closed seven restaurants in
Texas, California and Arizona. These closures resulted in closed-store reserve expenses of $4.5 million during fiscal 2018.

In fiscal 2017, we recorded a non-cash impairment charge of $32.6 million, primarily related to the carrying value of the assets of 23 restaurants in
Arizona, California and Texas. The impairment expense for fiscal 2017 includes an impairment expense of $27.7 million, representing the entire
value of capitalized assets of all of the company-operated restaurants in Texas, net of previously recorded depreciation. Additionally, during fiscal
2017, we closed four restaurants in Texas, one of which was fully impaired during the fourth quarter of 2016, one of which was impaired during
the third quarter of 2016 and the other two were impaired in fiscal 2017. Additionally, we closed one restaurant in Arizona, which was fully
impaired in the third quarter of 2016. These closures resulted in closed-store reserve expenses of $1.1 million during fiscal 2017.

During fiscal 2019, we completed the sale of four company-operated restaurants within the San Francisco area to an existing franchisee, seven
company-operated restaurants in the Phoenix area to another existing franchisee and five company-operated restaurants in Texas to a third
franchisee, which resulted in cash proceeds of $4.8 million and a net loss on sale of restaurants of $5.1 million for the year ended December 25,
2019.

Legal settlements of $36.3 million in fiscal 2018 included (i) an accrual of an expected settlement amount in fiscal 2018 related to an agreement in
principle to settle all claims and allegations for the securities class action and (ii) an accrual of an expected settlement amount in fiscal 2018
related to an agreement in principle to settle all claims and allegations, related to multiple wage and hour class action suits. For additional
information on legal settlements, see "Note 13. Commitments and Contingencies—Legal Matters" in the accompanying "Notes to Consolidated
Financial Statements" in this Annual Report.

On July 30, 2014, we entered into the income tax receivable agreement ("TRA"). This agreement calls for us to pay to our pre-IPO stockholders
85% of the savings in cash that we realize in our taxes as a result of utilizing our net operating losses and other tax attributes attributable to
preceding periods. For the years ended December 25, 2019 and December 26, 2018, income tax receivable agreement expense (income) consisted
of the amortization of interest expense and changes to future forecasted results and the timing of deductibility of certain timing differences,
including for fiscal 2018 the legal settlement accruals, related to our total expected TRA payments. For fiscal 2017, the income tax receivable
agreement income was primarily due to the Tax Cuts and Jobs Act (the "Tax Act"), and the resulting changes to the Federal corporate income tax
rate.

Consists of costs related to the defense of securities lawsuits. See "Note 13. Commitments and Contingencies—Legal Matters" in the
accompanying "Notes to Consolidated Financial Statements" in this Annual Report.

Pre-opening costs are a component of general and administrative expenses, and consist of costs directly associated with the opening of new
restaurants and incurred prior to opening, including management labor costs, staff labor costs during training, food and supplies used during
training, marketing costs, and other related pre-opening costs. These are generally incurred over the three to five months prior to opening. Pre-
opening costs also include occupancy costs incurred between the date of possession and the opening date for a restaurant.

Includes costs associated with the transition of our CEO, such as executive recruiting costs and stock-based compensation costs associated with
the transition of our former CEO in 2018.

(e)

(f)

(g)

(h)

(i)

(j)

Liquidity and Capital Resources

Our primary sources of liquidity and capital resources have been cash provided from operations, cash and cash equivalents, and our secured revolving
credit facility. Our primary requirements for liquidity and capital are new restaurants, existing restaurant capital investments (remodels and maintenance),
legal defense costs, lease obligations, interest payments on our debt, working capital and general corporate needs. Our working capital requirements are not
significant, since our customers pay for their purchases in cash or by payment card (credit or debit) at the time of sale. Thus, we are able to sell many of our
inventory items

50

before we have to pay our suppliers. Our restaurants do not require significant inventories or receivables. We believe that these sources of liquidity and
capital are sufficient to finance our continued operations and expansion plans for at least the next 12 months from the issuance of the consolidated financial
statements.

The following table presents summary cash flow information for the years indicated:

(Amounts in thousands)
Net cash provided by (used in)

Operating activities

Investing activities

Financing activities

Net increase (decrease) in cash and cash equivalents

Operating Activities

2019

Fiscal Year

2018

2017

$

$

36,135   $

45,442   $

(10,669)  

(24,365)  

(27,802)  

(19,221)  

1,101   $

(1,581)   $

53,671

(36,238)

(11,051)

6,382

In fiscal 2019, net cash provided by operating activities decreased by $9.3 million compared to fiscal 2018. This was due primarily to unfavorable working
capital fluctuations.

In fiscal 2018, net cash provided by operating activities decreased by $8.2 million compared to fiscal 2017. This was due primarily to unfavorable working
capital fluctuations.

Investing Activities

In fiscal 2019, net cash used in investing activities decreased by $17.1 million compared to fiscal 2018. This was due to a decrease of $12.4 million in
capital expenditure spending, due primarily to opening two new company-operated restaurants in fiscal 2019, compared to eight new restaurants in fiscal
2018, and cash proceeds of $4.8 million related to the sale of four company-operated restaurants within the San Francisco area to an existing franchisee and
seven company-operated restaurants in the Phoenix area to another existing franchisee. In fiscal 2019, we incurred capital expenditures of approximately
$15.4 million, consisting of $6.6 million related to new restaurants, $2.4 million related to the remodeling of existing restaurants, and $6.4 million related
to major maintenance and other corporate capital expenditures. Capital expenditures for these periods exclude unpaid purchases of property and equipment.

In fiscal 2018, net cash used in investing activities decreased by $8.4 million compared to fiscal 2017.  This was due to a decrease in capital expenditure
spending, due primarily to opening eight new company-operated restaurants in fiscal 2018, compared to 16 new restaurants in fiscal 2017. In fiscal 2018,
we incurred capital expenditures of approximately $27.8 million, consisting of $14.6 million related to new restaurants, $6.3 million related to the
remodeling of existing restaurants, and $6.9 million related to major maintenance and other corporate capital expenditures. Capital expenditures for these
periods exclude unpaid purchases of property and equipment.

Financing Activities

In fiscal 2019, net cash used by financing activities increased by $5.1 million compared to fiscal 2018. This was due primarily to an increase in repurchases
of common stock of $47.4 million and a decrease in proceeds received from stock option exercises of $0.4 million in fiscal 2019 compared to fiscal 2018,
partially offset by an increase in net borrowings on our revolving debt of $42.7 million.

In fiscal 2018, net cash used by financing activities increased by $8.2 million compared to fiscal 2017. This was due primarily to an increase in net pre-
payments on our revolving debt of $8.7 million and an increase in repurchases of common stock of $1.0 million which were partially offset by an increase
in proceeds received from stock option exercises of $1.7 million in fiscal 2018 compared to fiscal 2017.

Debt and Other Obligations

Current Credit Agreement

On July 13, 2018, the Company refinanced its credit agreement with Bank of America, N.A., as administrative agent, swingline lender, and letter of credit
issuer, the lenders party thereto, and the other parties thereto (the "2014 Revolver") pursuant to a credit agreement (the "2018 Credit Agreement") among El
Pollo Loco, Inc. ("EPL"), our indirect wholly owned operating subsidiary, as borrower, and the Company and EPL Intermediate, Inc. ("Intermediate"),
Holdings' direct subsidiary, as guarantors, Bank of America, N.A., as administrative agent, swingline lender, and letter of credit issuer, the lenders party
thereto, and the other parties thereto, which provides for a $150.0 million five-year senior secured revolving credit facility (the

51

 
 
 
 
 
 
 
 
“2018 Revolver”). The 2018 Revolver includes a sub limit of $15.0 million for letters of credit and a sub limit of $15.0 million for swingline loans. The
obligations under the 2018 Credit Agreement and related loan documents are guaranteed by the Company and Intermediate. The obligations of the
Company, EPL and Intermediate under the 2018 Credit Agreement and related loan documents are secured by a first priority lien on substantially all of
their respective assets.

Borrowings under the 2018 Revolver (other than any swingline loans) bear interest, at the borrower’s option, at rates based upon either LIBOR or a base
rate, plus, for each rate, a margin determined in accordance with a lease-adjusted consolidated leverage ratio-based pricing grid. The base rate is calculated
as the highest of (a) the federal funds rate plus 0.50%, (b) the published Bank of America prime rate, or (c) LIBOR plus 1.00%. For LIBOR loans, the
margin is in the range of 1.25% to 2.25%, and for base rate loans the margin is in the range of 0.25% to 1.25%. For borrowings under the 2018 Revolver
during fiscal 2019, the interest rate range was 3.2% to 6.0%. For borrowings under both the 2014 Revolver and the 2018 Revolver during fiscal 2018, the
interest rate range was 3.3% to 4.0%. The interest rate under the 2018 Revolver was 3.2% at December 25, 2019 and 4.0% under the 2018 Revolver at
December 26, 2018.

The 2018 Credit Agreement contains certain financial covenants. The Company was in compliance with all such covenants at December 25, 2019. See the
"Notes to the Consolidated Financial Statements," "Note 1, Description of Business" for restrictions on the payment of dividends under the 2018 Credit
Agreement. At December 25, 2019, $8.4 million of letters of credit and $97.0 million of the revolving line of credit were outstanding. The amount
available under the revolving line of credit was $44.6 million at December 25, 2019.

During the year ended December 25, 2019, we entered into an interest rate swap with a notional amount of $40.0 million, related to the outstanding
borrowings under our 2018 Revolver. The interest rate swap was designated as a cash flow hedge and effectively converted a portion of our outstanding
borrowings to a fixed rate of 2.81%. The interest rate swap matures in June 2023.

Contractual Obligations

The following table represents our contractual commitments to make future payments pursuant to our debt and other obligations disclosed above and
pursuant to our restaurant operating leases outstanding as of December 25, 2019:

(Amounts in thousands)
Operating leases

Finance leases
Long-term debt (1)
Income tax receivable agreement

Purchasing commitments—chicken

Total

Payments Due by Period

Total
259,171   $

$

2020

2021-
2022

2023-
2024

2025 and
thereafter

26,808   $

50,849   $

42,060   $

139,454

153  

109,461  

8,236  

25,185  

54  

3,150  

4,935  

25,185  

99  

6,207  

2,292  

—  

—  

100,104  

1,009  

—  

—

—

—

—

$

402,206   $

60,132   $

59,447   $

143,173   $

139,454

(1) Includes expected interest expenses, calculated based on applicable interest rates at December 25, 2019.

Off-Balance Sheet Arrangements

At December 25, 2019, December 26, 2018, and December 27, 2017, we had $8.4 million, $8.5 million, and $8.1 million, respectively, of borrowing
capacity on the 2018 Revolver or 2014 Revolver pledged as collateral to secure outstanding letters of credit.

Critical Accounting Policies and Use of Estimates

The preparation of our consolidated financial statements in accordance with GAAP requires us to make estimates and judgments that affect our reported
amounts of assets, liabilities, revenue, and expenses, and related disclosure of contingent assets and liabilities. We base our estimates on historical
experience and on various other assumptions that we believe to be reasonable under current circumstances in making judgments about the carrying value of
assets and liabilities that are not readily available from other sources. We evaluate our estimates on an on-going basis. Actual results may differ from these
estimates under different assumptions or conditions.

Accounting policies are an integral part of our financial statements. A thorough understanding of these accounting policies is essential when reviewing our
reported results of operations and our financial position. Management believes that the critical accounting policies and estimates discussed below involve
the most difficult management judgments, due to the sensitivity of

52

 
 
 
 
 
the methods and assumptions used. Our significant accounting policies are described in "Note 2. Summary of Significant Accounting Policies" in the
accompanying "Notes to Consolidated Financial Statements" included elsewhere in this Annual Report.

Revenue Recognition

We record revenue from company-operated restaurants as food and beverage products are delivered to customers and payment is tendered at the time of
sale. We present sales net of sales-related taxes and promotional allowances. In the case of gift card sales, we record revenue when the gift card is redeemed
by the customer. We record royalties from franchised restaurant sales based on a percentage of restaurant revenues in the period that the related franchised
restaurants’ revenues are earned. Prior to the adoption of ASU 2014-09, the Company's accounting policy was to recognize initial franchise fees,
development fees, and franchise agreement renewals when all material obligations had been performed and conditions were satisfied, typically when
operations of the franchised restaurant commenced. In accordance with the terms of the new guidance in ASU 2014-09 adopted for fiscal 2018, the initial
franchise services, or exclusivity of the development agreements, are not distinct from the continuing rights or services offered during the term of the
franchise agreement and will, therefore, be treated as a single performance obligation. As such, initial franchise and development fees received, and
subsequent renewal fees, will be recognized over the franchise, or renewal, term, which is typically 20 years. For additional information regarding the
adoption of ASU 2014-09, see "Note 2. Summary of Significant Accounting Policies" and "Note 15. Revenue from Contracts with Customers" in our
accompanying "Notes to Consolidated Financial Statements" included in "Item 8. Financial Statements and Supplementary Data" in this Annual Report.

Goodwill and Indefinite-Lived Intangible Assets, Net

Intangible assets consist primarily of goodwill and trademarks.

We do not amortize our goodwill and indefinite-lived intangible assets. We perform an annual impairment test for goodwill during the fourth fiscal quarter
of each year, or more frequently if impairment indicators arise. For our annual goodwill impairment assessment at December 25, 2019, we performed a
qualitative assessment and concluded that the fair value of the reporting unit to which goodwill was assigned exceeded our book equity. Accordingly, we
did not identify any goodwill impairment.

We perform an annual impairment test for indefinite-lived intangible assets during the fourth fiscal quarter of each year, or more frequently if impairment
indicators arise. For our impairment test for indefinite-lived intangible assets at December 25, 2019, we performed a qualitative assessment and concluded
that the fair value of the indefinite-lived intangible assets exceeded their carrying value and that there was no impairment.

These assumptions used in our estimates of fair value are generally consistent with past performance and are also consistent with the projections and
assumptions that we use in our forward-looking operating plans. These assumptions are subject to change as a result of changing economic and competitive
conditions. Changes in these estimates and assumptions could materially affect our determinations of fair value and impairment.

Long-Lived Assets

We state the value of our property and equipment, including primarily leasehold improvements and restaurant equipment, furniture, and fixtures, at cost,
minus accumulated depreciation and amortization. We calculate depreciation using the straight-line method of accounting over the estimated useful lives of
the related assets. We amortize our leasehold improvements using the straight-line method of accounting over the shorter of the lease term (including
reasonably assured renewal periods) or the estimated useful lives of the related assets. We expense repairs and maintenance as incurred, but capitalize
major improvements and betterments. We make judgments and estimates related to the expected useful lives of those assets that are affected by factors such
as changes in economic conditions and changes in operating performance. If we change our assumptions in the future, we may be required to record
impairment charges for these assets.

The Company reviews its long-lived assets for impairment on a restaurant-by-restaurant basis whenever events or changes in circumstances indicate that
the carrying value of certain assets may not be recoverable. The Company considers a triggering event to have occurred related to a specific restaurant if
the restaurant’s cash flows for the last twelve months are less than a minimum threshold or if consistent levels of undiscounted cash flows for the remaining
lease period are less than the carrying value of the restaurant’s assets. If the Company concludes that the carrying value of certain assets will not be
recovered based on expected undiscounted future cash flows, an impairment write-down is recorded to reduce the assets to their estimated fair value. The
fair value is measured on a nonrecurring basis using unobservable (Level 3) inputs. There is uncertainty in the

53

projected undiscounted future cash flows used in our impairment review analysis. If actual performance does not achieve the projections, we may recognize
impairment charges in future periods, and such charges could be material.

Insurance Reserves

We are responsible for workers’ compensation, general, and health insurance claims up to a specified amount. We maintain a reserve for estimated claims
both reported and incurred but not reported, based on historical claims experience and other assumptions. In estimating our insurance accruals, we utilize
independent actuarial estimates of expected losses, which are based on statistical analyses of historical data. Our actuarial assumptions are closely
monitored and adjusted when warranted by changing circumstances. Should claims occur or medical costs increase in greater amounts than we have
expected, accruals may not be sufficient, and we may record additional expenses.

Accounting for Lease Obligations

We lease a substantial number of our restaurant properties. At the inception of each lease, we evaluate the property and the lease to determine whether the
lease is an operating lease or a capital lease. This lease accounting evaluation may require significant judgment in determining the fair value and useful life
of the leased property and the appropriate lease term. The lease term used for the evaluation includes renewal option periods only in instances in which the
exercise of the renewal option can be reasonably assured because failure to exercise such an option would result in an economic penalty. Such an economic
penalty would typically result from our having to abandon a building or fixture with remaining economic value upon vacating a property.

In the first quarter of fiscal 2019, we adopted Topic 842. In applying the requirements of Topic 842 we made significant assumptions and judgments related
to determination of whether a contract contains a lease and the discount rate used for the lease. In determining if any of our contracts contain a lease, we
made assumptions and judgments related to our ability to direct the use of any assets stated in the contract and the likelihood of renewing any short-term
contracts for a period extending past twelve months. We also made significant assumptions and judgments in determining an appropriate discount rate for
property leases. These included using a consistent discount rate for a portfolio of leases entered into at varying dates, using the full 20-year term of the
lease, excluding any options, and using the total minimum lease payments. We utilized a third-party valuation firm to assist in determining the discount
rate, based on the above assumptions. For all other leases, we used the discount rate implicit in the lease, or the Company’s incremental borrowing rate.

Franchise Operations

We sublease a number of restaurant properties to our franchisees. As such, we remain principally liable for the underlying leases. If sales trends or
economic conditions worsen for our franchisees, their financial health may worsen, our collection rates may decline, and we may be required to assume the
responsibility for additional lease payments on what are presently franchised restaurants.

Income Taxes

We use the asset and liability method of accounting for income taxes. Deferred tax assets and liabilities are determined based on temporary differences
between the financial carrying amounts and the tax basis of assets and liabilities using enacted tax rates in effect in the years in which the temporary
differences are expected to reverse. As of December 25, 2019, we had federal and state net operating loss (“NOL”) carryforwards of $8.6 million and less
than $0.1 million, respectively. These Federal and State NOLs expire beginning in 2033 and 2028, respectively.

A valuation allowance is required when there is significant uncertainty as to whether certain deferred tax assets can be realized. The ability to realize
deferred tax assets is dependent upon our ability to generate sufficient taxable income within the carryforward periods provided for in the tax law for each
tax jurisdiction. We have considered the following possible sources of taxable income when assessing the realization of our deferred tax assets:

•

•

•

•

future reversals of existing taxable temporary differences;

future taxable income or loss, exclusive of reversing temporary differences and carryforwards;

tax-planning strategies; and

taxable income in prior carryback years.

54

We will continue to reevaluate the continued need for either a valuation allowance. Relevant factors include:

•

•

•

•

current financial performance;

our ability to meet short-term and long-term financial and taxable income projections;

the overall market environment; and

the volatility and trends in the industry in which we operate.

All of the factors that we consider in evaluating treatment of a deferred tax asset valuation allowance involve significant judgment. For example, there are
many different interpretations of “cumulative losses in recent years” that can be used. Also, significant judgment is involved in making projections of
future financial and taxable income, especially because our financial results are significantly dependent upon industry trends. Any change in our valuation
allowance will significantly impact our financial results in the period of that change.

When there are uncertainties related to potential income tax benefits, in order to qualify for recognition, the position we take has to have at least a “more
likely than not” chance of being sustained (based on the position’s technical merits) upon challenge by the responsible authorities. The term “more likely
than not” means a likelihood of more than 50%. Otherwise, we may not recognize any of the potential tax benefits associated with that position. We
recognize a benefit for a tax position that meets the “more likely than not” criterion as the largest amount of tax benefit that is greater than 50% likely to be
realized upon its effective resolution. Unrecognized tax benefits involve our judgment regarding the likelihood of a benefit being sustained. The final
resolutions of uncertain tax positions could result in adjustments to recorded amounts and affect our results of operations, financial position, and cash
flows. However, we anticipate that any such adjustments would not materially impact our financial statements.

On July 30, 2014, we entered into the TRA. The TRA calls for us to pay to our pre-IPO stockholders 85% of the savings in cash that we realize in our taxes
as a result of utilizing our net operating losses and other tax attributes attributable to preceding periods. We are permitted to make TRA payments under the
2018 Revolver. In fiscal 2019, we recognized an expense of $0.1 million as a result of changes to future forecasted results. In fiscal 2018, we recognized a
benefit of $0.8 million, as a result of changes to future forecasted results and the timing of the deductibility of certain temporary differences including the
current year legal settlement accruals. In fiscal 2017, we recognized a benefit of $5.6 million, related to the amortization of the present value of the TRA
obligation, the impact of the Tax Act on the corporate tax rate on future years, and an adjustment to the expected TRA liability, due to the expected
realization of various pre-IPO tax credits.

In addition, in fiscal 2014, we applied for various tax credits that resulted in $6.7 million of additional deferred tax assets and tax benefits. As of fiscal
2019, the deferred asset balance related to these various tax credits, net of valuation allowance was $3.3 million. The fiscal 2019 provision includes a $6.0
million valuation allowance against our deferred tax asset, resulting from certain tax credits that may not be realizable prior to the time the credits expire.
Also, in fiscal 2019, federal work opportunity tax credits (“WOTC”) of approximately $0.3 million were generated.

Stock-Based Compensation

We measure and recognize compensation expense for the estimated fair value of equity instruments for employees and non-employee directors based on the
grant-date fair value of the award. For awards that are based on a service requirement, the cost is recognized on a straight-line basis over the requisite
service period, usually the vesting period. In fiscal 2019, the Company granted 323,900 stock options and 299,052 restricted stock awards, with an exercise
price equal to the fair market value of the common stock on the date of grant. The awards granted in fiscal 2019, 2018 and 2017 had a four-year vesting
period for employees and three-year vesting period for directors. Included in the fiscal 2018 restricted stock award grants were 72,116 performance share
units which have a five-year term. Performance share units are granted at fair market value on the date of grant and are subject to service-based and market-
based vesting conditions. For stock options that were based on performance requirements, costs were recognized over the periods to which the performance
criteria related. As of December 25, 2019, there were no remaining performance-based stock options outstanding. In order to calculate our stock options’
fair values and the associated compensation costs for share-based awards, we utilize the Black–Scholes option pricing model.

Recent Accounting Pronouncements

Recent accounting pronouncements are described in "Note 2. Summary of Significant Accounting Policies" in our accompanying "Notes to Consolidated
Financial Statements" included in this Annual Report.

55

ITEM 7A.

QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK

Interest Rate Risk

We are exposed to market risk from changes in interest rates on our debt, which bears interest at USD LIBOR plus a margin between 1.25% and 2.25%. As
of December 25, 2019, we had outstanding borrowings of $97.0 million related to our 2018 Revolver and another $8.4 million of letters of credit in support
of our insurance programs and the applicable margin on outstanding borrowings under 2018 Revolver was 1.5%. In addition, there is currently uncertainty
around whether LIBOR will continue to exist after 2021. If LIBOR ceases to exist, we may need to enter into an amendment to the 2018 Credit Agreement
and we cannot predict what alternative index would be negotiated with our lenders. If our lenders have increased costs due to changes in LIBOR, we may
experience potential increases in interest rates on our variable rate debt, which could adversely impact our interest expense, results of operations and cash
flows. After giving effect to the $40.0 million of interest rate swaps, we effectively had $57.0 million of long-term debt subject to variations in interest rates
and a one percent increase in the variable rate of interest would increase annual interest expense by $0.6 million.

We manage our interest rate risk through normal operating and financing activities and, when determined appropriate, through the use of derivative
financial instruments. To balance our portfolio, we entered into an interest rate swap during the year ended December 25, 2019 with a notional amount of
$40.0 million, related to the outstanding borrowings under our 2018 Revolver. The interest rate swap was designated as a cash flow hedge and effectively
converted a portion of our outstanding borrowings to a fixed rate of 2.81%. The interest rate swap matures in June 2023.

Inflation

Inflation has an impact on food, paper, construction, utility, labor and benefits, general and administrative, and other costs, all of which can materially
impact our operations. We have a substantial number of hourly employees who are paid wage rates at or based on the applicable federal, state, or local
minimum wage, and increases in the minimum wage will increase our labor costs. On January 1, 2018, the State of California (where most of our
restaurants are located) minimum wage rose to $11.00 per hour, and on January 1, 2019 and on January 1, 2020, it was increased to $12.00 per hour and
$13.00 per hour, respectively. We also do substantial business in locales such as the City of Los Angeles and the County of Los Angeles. On July 1, 2018
and July 1, 2019, the minimum wage in the City of Los Angeles increased to $13.25 per hour and $14.25 per hour, respectively. Starting July 1, 2020, the
minimum wage in the City of Los Angeles will increase to $15.00 per hour. For details, see "Item 1A. Risk Factors—Risks Related to Our Business and
Industry—If we or our franchisees face labor shortages or increased labor costs, our results of operations and growth could be adversely affected.” In
general, we have been able to substantially offset cost increases resulting from inflation by increasing menu prices, managing menu mix, improving
productivity, or making other adjustments. We may not be able to offset cost increases in the future.

Commodity Price Risk

We are exposed to market price fluctuation in food product prices. Given the historical volatility of certain of our food product prices, including chicken,
other proteins, grains, produce, dairy products, and cooking oil, these fluctuations can materially impact our food and beverage costs. While our purchasing
commitments partially mitigate the risk of such fluctuations, there is no assurance that supply and demand factors such as disease or inclement weather will
not cause the prices of the commodities used in our restaurant operations to fluctuate. In periods where the prices of commodities drop, we may pay higher
prices under our purchasing commitments. In rapidly-fluctuating commodities markets, it may prove difficult for us to adjust our menu prices in
accordance with input price fluctuations. Therefore, to the extent that we do not pass along cost increases to our customers, our results of operations may be
adversely affected. At this time, we do not use financial instruments to hedge our commodity risk. See "Item 1A. Risk Factors—Risks Related to Our
Business and Industry—Changes in food and supply costs, especially for chicken, could adversely affect our business, financial condition and results of
operations,” and "Note 13. Commitments and Contingencies—Purchase Commitments" in our accompanying "Notes to Consolidated Financial
Statements" included in this Annual Report.

ITEM 8.

FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA

EL POLLO LOCO HOLDINGS, INC. AND SUBSIDIARIES

INDEX TO THE CONSOLIDATED FINANCIAL STATEMENTS

56

Audited Consolidated Financial Statements

Report of Independent Registered Public Accounting Firm

Consolidated Balance Sheets—December 25, 2019 and December 26, 2018

Consolidated Statements of Operations—For the years ended December 25, 2019, December 26, 2018, and December 27, 2017

Consolidated Statements of Comprehensive Income (Loss)—For the years ended December 25, 2019, December 26, 2018, and December 27, 2017

Consolidated Statements of Changes in Stockholders’ Equity—For the years ended December 25, 2019, December 26, 2018, and December 27,
2017

Consolidated Statements of Cash Flows—For the years ended December 25, 2019, December 26, 2018, and December 27, 2017

Notes to Consolidated Financial Statements

58

59

61

62

63

64

65

57

 
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

Shareholders and Board of Directors
El Pollo Loco Holdings, Inc.
Costa Mesa, California

Opinion on the Consolidated Financial Statements

We  have  audited  the  accompanying  consolidated  balance  sheets  of  El  Pollo  Loco  Holdings,  Inc.  (the  “Company”)  as  of  December  25,  2019  and
December 26, 2018, the related consolidated statements of operations, comprehensive income (loss), changes in stockholders’ equity, and cash flows for
each of the three years in the period ended December 25, 2019, and the related notes (collectively referred to as the "consolidated financial statements"). In
our opinion, the consolidated financial statements present fairly, in all material respects, the financial position of the Company at December 25, 2019 and
December 26, 2018, and the results of its operations and its cash flows for each of the three years in the period ended December 25, 2019, in conformity
with accounting principles generally accepted in the United States of America.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (“PCAOB”), the Company’s
internal control over financial reporting as of December 25, 2019, based on criteria established in Internal Control - Integrated Framework (2013) issued
by  the  Committee  of  Sponsoring  Organizations  of  the  Treadway  Commission  (“COSO”)  and  our  report  dated  March  6,  2020,  expressed  an  unqualified
opinion thereon.

Change in Accounting Method Related to Leases and Revenue

As discussed in Notes 2 and 5 to the consolidated financial statements, the Company has changed its method of accounting for leases in 2019 due to the
adoption of Accounting Standards Codification (“ASC”) 842 - Leases.

As discussed in Notes 2 and 15 to the consolidated financial statements, the Company has changed its method of accounting for revenues in 2018 due to the
adoption of ASC 606 - Revenue from Contracts with Customers.

Basis for Opinion

These consolidated financial statements are the responsibility of the Company’s management. Our responsibility is to express an opinion on the Company’s
consolidated financial statements based on our audits. We are a public accounting firm registered with the PCAOB and are required to be independent with
respect  to  the  Company  in  accordance  with  the  U.S.  federal  securities  laws  and  the  applicable  rules  and  regulations  of  the  Securities  and  Exchange
Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable
assurance about whether the consolidated financial statements are free of material misstatement, whether due to error or fraud.

Our audits included performing procedures to assess the risks of material misstatement of the consolidated financial statements, whether due to error or
fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and
disclosures in the consolidated financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by
management, as well as evaluating the overall presentation of the consolidated financial statements. We believe that our audits provide a reasonable basis
for our opinion.

/s/ BDO USA, LLP

We have served as the Company’s auditor since 2011.

Costa Mesa, California

March 6, 2020

58

EL POLLO LOCO HOLDINGS, INC.

CONSOLIDATED BALANCE SHEETS

(Amounts in thousands, except share data)

December 25, 2019

  December 26, 2018

Assets

Current assets:

Cash and cash equivalents

Accounts and other receivables, net

Inventories

Prepaid expenses and other current assets

Income tax receivable

Total current assets

Property and equipment, net

Property held under finance lease, net

Property held under operating leases, net (ROU Asset)

Goodwill

Trademarks, net

Other intangible assets, net

Deferred tax assets

Other assets

Total assets

Liabilities and Stockholders’ Equity

Current liabilities:

Current portion of obligations under finance leases

Current portion of obligations under operating leases

Accounts payable

Accrued salaries and benefits

Accrued insurance

Accrued income taxes payable

Accrued interest

Current portion of income tax receivable agreement payable

Other accrued expenses and current liabilities

Total current liabilities

Revolver loan

Obligations under finance leases, net of current portion

Obligations under operating leases, net of current portion

Deferred taxes

Other intangible liabilities, net

Income tax receivable agreement payable, net of current portion

Other noncurrent liabilities

Total liabilities

Commitments and contingencies (Note 13)

Stockholders’ Equity

Preferred stock, $0.01 par value—100,000,000 shares authorized; none issued or
   outstanding

Common stock, $0.01 par value—200,000,000 shares authorized; 35,126,582 and
  39,009,451 shares issued and outstanding as of December 25, 2019 and December 26, 2018, respectively

Additional paid-in capital

Accumulated deficit

59

$

8,070   $

$

$

8,505  

2,009  

5,718  

376  

24,678  

91,778  

—  

192,395  

248,674  

61,888  

—  

3,709  

1,630  

624,752   $

34   $

16,406  

5,627  

8,618  

9,440  

—  

302  

4,935  

28,597  

73,959  

97,000  

83  

197,492  

1,672  

—  

3,301  

5,679  

379,186  

—  

351  

330,950  

(85,988)  

6,969

9,599

2,479

2,998

—

22,045

104,145

16

—

248,674

61,888

280

11,709

1,469

450,226

68

—

9,564

7,574

7,076

71

149

6,637

51,764

82,903

74,000

116

—

—

642

7,305

20,024

184,990

—

390

375,734

(110,888)

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Accumulated other comprehensive income

Total stockholders’ equity

Total liabilities and stockholders’ equity

253  

245,566  

624,752   $

—

265,236

450,226

$

See notes to consolidated financial statements.

60

EL POLLO LOCO HOLDINGS, INC.

CONSOLIDATED STATEMENTS OF OPERATIONS

(Amounts in thousands, except share data)

For the Years Ended
Revenue

Company-operated restaurant revenue

Franchise revenue

Franchise advertising fee revenue

Total revenue

Cost of operations

Food and paper costs

Labor and related expenses

Occupancy and other operating expenses

Company restaurant expenses

General and administrative expenses

Legal settlements

Franchise expenses

Depreciation and amortization

Loss on disposal of assets

Recovery of securities lawsuits related legal expenses

Impairment and closed-store reserves

Loss on disposition of restaurants

Total expenses

Income (loss) from operations

Interest expense, net

Income tax receivable agreement expense (income)

Income (loss) before provision (benefit) for income
   taxes

Provision (benefit) for income taxes

Net income (loss)

Net income (loss) per share:

Basic

Diluted

December 25, 2019

  December 26, 2018

  December 27, 2017

$

391,112   $

388,835   $

28,819  

22,399  

442,330  

109,264  

116,703  

92,005  

317,972  

40,389  

—  

27,612  

17,855  

266  

(10,000)  

4,852  

5,058  

404,004  

38,326  

3,687  

57  

34,582  

9,682  

25,771  

21,222  

435,828  

111,142  

112,417  

91,385  

314,944  

50,261  

36,258  

24,429  

17,825  

278  

(8,356)  

9,650  

—  

(9,461)  

3,502  

(761)  

(12,202)  

(3,208)  

$

$

$

24,900   $

(8,994)   $

0.68   $

0.67   $

(0.23)   $

(0.23)   $

376,615

25,086

—

401,701

109,898

106,584

85,631

302,113

38,523

—

3,335

18,128

799

(1,666)

33,645

—

6,824

3,278

(5,570)

9,116

497

8,619

0.22

0.22

445,289  

394,877

Weighted average shares used in computing net income (loss) per share:

Basic

Diluted

36,739,209  

37,441,503  

38,574,553  

38,574,553  

38,453,347

39,086,676

See notes to consolidated financial statements.

61

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EL POLLO LOCO HOLDINGS, INC.

CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME (LOSS)

(Amounts in thousands)

December 25, 2019

  December 26, 2018

$

24,900   $

  December 27, 2017
8,619

(8,994)   $

Net income (loss)

Other comprehensive income (loss)

Changes in derivative instruments

Unrealized gains arising during the period from interest rate swap

Reclassifications of gains into net income

Income tax

Other comprehensive income, net of taxes

Comprehensive income (loss)

430  

(84)  

(93)  

253  

—  

—  

—  

—  

—

—

—

—

$

25,153   $

(8,994)   $

8,619

See notes to consolidated financial statements.

62

 
 
   
   
 
   
   
  Accumulated Other
Comprehensive
Income

Total
Stockholders’
Equity

Accumulated
Deficit
(107,046)   $

—   $

—  

265,182

1,056

EL POLLO LOCO HOLDINGS, INC.

CONSOLIDATED STATEMENTS OF CHANGES IN STOCKHOLDERS’ EQUITY

(Amounts in thousands, except share data)

Balance, December 28, 2016

Stock-based compensation

Issuance of common stock related to restricted
shares, net

Issuance of common stock upon exercise of
stock options

Net income

Common Stock

Shares

  Amount

Additional
Paid-in Capital

38,473,772   $

385   $

371,843   $

—  

—  

1,056  

170,417  

2  

17,661  

—  

—  

—  

(2)  

93  

—  

—  

—  

—  

8,619  

Balance, December 27, 2017

38,661,850  

387  

372,990  

(98,427)  

Cumulative effect of accounting change (see
Note 2)

Stock-based compensation

Issuance of common stock related to restricted
shares, net

Issuance of common stock upon exercise of
stock options

Shares repurchased for employee tax
withholdings

Repurchase of common stock

Net loss

Balance, December 26, 2018

Stock-based compensation

Issuance of common stock related to restricted
shares, net

Issuance of common stock upon exercise of
stock options

Shares repurchased for employee tax
withholdings

Repurchase of common stock

Other comprehensive income, net of income tax

Net income

—  

—  

155,229  

269,549  

(10,768)  

(66,409)  

—  

39,009,451  

—  

309,404  

234,728  

(31,397)  

(4,395,604)  

—  

—  

—  

—  

1  

3  

—  

(1)  

—  

390  

—  

2  

2  

—  

(43)  

—  

—  

—  

2,005  

(1)  

1,834  

(114)  

(980)  

—  

(3,467)  

—  

—  

—  

—  

—  

(8,994)  

375,734  

(110,888)  

2,474  

(2)  

1,448  

(365)  

(48,339)  

—  

—  

—  

—  

—  

—  

—  

—  

24,900  

Balance, December 25, 2019

35,126,582   $

351   $

330,950   $

(85,988)   $

253   $

See notes to consolidated financial statements.

63

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

—  

253  

—  

—

93

8,619

274,950

(3,467)

2,005

—

1,837

(114)

(981)

(8,994)

265,236

2,474

—

1,450

(365)

(48,382)

253

24,900

245,566

 
 
 
 
 
 
 
 
 
EL POLLO LOCO HOLDINGS, INC.

CONSOLIDATED STATEMENTS OF CASH FLOWS

(Amounts in thousands)

December 25, 2019

December 26, 2018

December 27, 2017

$

24,900

  $

(8,994)   $

For the Years Ended
Cash flows from operating activities

Net income (loss)

Adjustments to reconcile changes in net income (loss) to net cash provided by operating activities:

Depreciation and amortization

Stock-based compensation expense

Income tax receivable agreement expense (income)

Loss on disposition of restaurants

Loss on disposal of assets

Impairment of property, equipment and ROU Asset

Closed-store reserves

Amortization of deferred financing costs

Amortization of other intangible assets, net

Deferred income taxes, net

Changes in operating assets and liabilities:

Accounts and other receivables, net

Inventories

Prepaid expenses and other current assets

Income taxes receivable/payable

Other assets

Accounts payable

Accrued salaries and benefits

Accrued insurance

Payment related to tax receivable agreement

Other accrued expenses and liabilities

Restricted cash

Net cash flows provided by operating activities

Cash flows from investing activities

Proceeds from disposition of restaurants

Purchase of property and equipment

Net cash flows used in investing activities

Cash flows from financing activities

Proceeds from borrowings on revolver and swingline loans

Payments on revolver and swingline loan

Minimum tax withholdings related to net share settlements

Proceeds from issuance of common stock upon exercise of stock options, net of expenses

Payment of obligations under finance leases

Deferred financing costs for revolver loan

Repurchases of common stock

Net cash flows used in financing activities

Increase (decrease) in cash and cash equivalents

Cash and cash equivalents, beginning of year

Cash and cash equivalents, end of year

Supplemental cash flow information

Cash paid for interest, net of capitalized interest

Cash paid during the year for income taxes, net

Non-cash investing and financing activity

Unpaid purchases of property and equipment

Schedule of non-cash transactions

Borrowing on revolver for financing fees

$

$

$

$

$

See notes to consolidated financial statements.

64

17,855

2,474

57

5,058

266

3,559

—  

251
—  

9,578

1,094

338

(2,727)

(448)

(412)

(3,192)

1,044

2,364

(5,764)

(20,160)

—  

36,135

4,770

(15,439)

(10,669)

42,000

(19,000)

(365)

1,450

(68)
—  

(48,382)

(24,365)

1,101

6,969

8,070

  $

17,825  
2,005  
(761)  
—  
278  
5,147  
4,503  
280  
(47)  
(3,428)  

(2,387)  
(190)  
(319)  
37  
122  
482  
235  
1,225  
(7,272)  
36,701  
—  
45,442  

—  
(27,802)  
(27,802)  

13,307  
(33,000)  
(114)  
1,837  
(132)  
(138)  
(981)  
(19,221)  
(1,581)  
8,550  
6,969   $

8,619

18,128

1,056

(5,570)

—

799

32,594

1,051

304

(119)

250

(294)

(177)

425

(85)

47

1,088

1,585

407

(11,109)

4,547

125

53,671

—

(36,238)

(36,238)

8,000

(19,000)

—

93

(144)

—

—

(11,051)

6,382

2,168

8,550

December 25, 2019

December 26, 2018

December 27, 2017

3,649

558

  $
  $

3,393   $
183   $

746

  $

1,543   $

—   $

693   $

3,314

336

4,741

—

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
   
   
EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

1. DESCRIPTION OF BUSINESS

El Pollo Loco Holdings, Inc. (“Holdings”) is a Delaware corporation headquartered in Costa Mesa, California. Holdings and its direct and indirect
subsidiaries are collectively known as “we,” “us” or the “Company.” The Company’s activities are conducted principally through its indirect wholly-owned
subsidiary, El Pollo Loco, Inc. (“EPL”), which develops, franchises, licenses and operates quick-service restaurants under the name El Pollo Loco ®. The
restaurants, which are located principally in California but also in Arizona, Nevada, Texas, Utah and Louisiana, specialize in fire-grilling citrus-marinated
chicken in a wide variety of contemporary Mexican and LA-inspired entrees, including specialty chicken burritos, chicken quesadillas, chicken tostada
salads, chicken tortilla soup, variations on our Pollo Bowl®, Pollo Salads and our Under 500 Calorie entrees. At December 25, 2019, the Company
operated 195 (143 in the greater Los Angeles area) and franchised 287 (136 in the greater Los Angeles area) El Pollo Loco restaurants. In addition, the
Company currently licenses one restaurant in the Philippines. The Company’s largest stockholder is Trimaran Pollo Partners, L.L.C. (“LLC”), which is
controlled by affiliates of Trimaran Capital, L.L.C. LLC acquired Chicken Acquisition Corp. (“CAC”), a predecessor of Holdings, on November 17, 2005
(the “Acquisition”) and has a 47.7% ownership interest as of December 25, 2019. LLC’s only material asset is its investment in Holdings.

On April 22, 2014, CAC, its wholly owned subsidiary, Chicken Subsidiary Corp (“CSC”) and CSC’s wholly owned subsidiary, the former El Pollo Loco
Holdings, Inc. (“Old Holdings”) entered into the following reorganization transactions: (i) Old Holdings merged with and into CSC with CSC continuing as
the surviving corporation; (ii) CSC merged with and into CAC with CAC continuing as the surviving corporation and (iii) CAC renamed itself El Pollo
Loco Holdings, Inc.

Holdings has no material assets or operations. Holdings and Holdings’ direct subsidiary, EPL Intermediate, Inc. (“Intermediate”), guarantee EPL’s 2018
Revolver (see Note 6) on a full and unconditional basis and Intermediate has no subsidiaries other than EPL. EPL is a separate and distinct legal entity, and
has no obligation to make funds available to Intermediate. EPL and Intermediate may pay dividends to Intermediate and to Holdings, respectively.

The Company operates in one operating segment. All significant revenues relate to retail sales of food and beverages through either company or franchised
restaurants.

On August 2, 2018, the Company announced that the Board of Directors had authorized a stock repurchase program. The Company entered into a stock
repurchase plan on August 28, 2018 (the “2018 Stock Repurchase Plan”), which allowed for the repurchase of up to $20.0 million of the Company's
common stock. The 2018 Stock Repurchase Plan commenced on November 6, 2018 and terminated on June 26, 2019.

On April 30, 2019, as part of the Company’s focus on stockholder returns, the Board of Directors approved a new stock repurchase program. The Company
entered into a stock repurchase plan on May 17, 2019 (the “2019 Stock Repurchase Plan”), which allowed for the repurchase up to $30.0 million of the
Company's common stock. The 2019 Stock Repurchase Plan commenced on June 27, 2019, and was exhausted on September 26, 2019.

Under the 2019 Stock Repurchase Plan, the Company was permitted to repurchase its common stock from time to time, in amounts and at prices that the
Company deemed appropriate, subject to market conditions and other considerations. The Company’s repurchases were executed using open market
purchases, including pursuant to Rule 10b5-1 trading plans, and/or through privately negotiated transactions.

For the year ended December 25, 2019, the Company repurchased 1,558,836 and 2,836,768 shares of common stock under the 2018 Stock Repurchase Plan
and the 2019 Stock Repurchase Plan, respectively, executed using open market purchases, for total consideration of approximately $18.4 million and $30.0
million, respectively. The common stock repurchased under both the 2018 Stock Repurchase Plan and the 2019 Stock Repurchase Plan was retired upon
repurchase. For the year ended December 26, 2018, the Company repurchased 66,409 shares of common stock under the 2018 Stock Repurchase Plan for
total considerations of approximately $1.0 million.

2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

Liquidity

The Company’s principal liquidity and capital requirements are new restaurants, existing restaurant capital investments (remodel and maintenance), interest
payments on our debt, lease obligations and working capital and general corporate needs.

65

EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

At December 25, 2019, the Company’s total debt was $97.0 million. The Company’s ability to make payments on its indebtedness and to fund planned
capital expenditures depends on available cash and its ability to generate adequate cash flows in the future, which, to a certain extent, is subject to general
economic, financial, competitive, legislative, regulatory and other factors that are beyond the Company’s control. Based on current operations, the
Company believes that its cash flows from operations, available cash of $8.1 million at December 25, 2019, and available borrowings under the 2018
Revolver (See "Note 6. Long-Term Debt") will be adequate to meet the Company’s liquidity needs for the next twelve months from the issuance of the
consolidated financial statements.

Basis of Presentation

The Company uses a 52- or 53-week fiscal year ending on the last Wednesday of each calendar year. Fiscal 2019, 2018, and 2017 ended on December 25,
2019, December 26, 2018 and December 27, 2017, respectively. In a 52-week fiscal year, each quarter includes 13 weeks of operations. In a 53-week fiscal
year, the first, second and third quarters each include 13 weeks of operations and the fourth quarter includes 14 weeks of operations. Approximately every
six or seven years a 53-week fiscal year occurs. Fiscal 2019, 2018 and 2017 were 52-week fiscal years. 53-week years may cause revenues, expenses, and
other results of operations to be higher due to the additional week of operations. 2020 will be a 53-week fiscal year.

Principles of Consolidation

The accompanying consolidated financial statements include the accounts of Holdings and its wholly owned subsidiaries. All intercompany balances and
transactions have been eliminated in consolidation.

Use of Estimates

The preparation of consolidated financial statements in conformity with accounting principles generally accepted in the United States of America
(“GAAP”) requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosures of contingent
assets and liabilities at the date of the consolidated financial statements and revenue and expenses during the period reported. Actual results could
materially differ from those estimates. The Company’s significant estimates include estimates for impairment of goodwill, intangible assets and property
and equipment, insurance reserves, lease accounting matters, stock-based compensation, TRA liability, contingent liabilities and income tax valuation
allowances.

Cash and Cash Equivalents

The Company considers all highly-liquid instruments with a maturity of three months or less at the date of purchase to be cash equivalents.

Subsequent Events

Subsequent to December 25, 2019, the Company made a $10.0 million borrowing, net, on the 2018 Revolver, primarily to fund payment of a $16.3 million
legal settlement, which was made on February 28, 2020 and previously accrued for during fiscal 2018. See Note 13 for further details regarding the
settlement payments.

The Company evaluated subsequent events that have occurred after December 25, 2019, and determined that there were no other events or transactions
occurring during this reporting period that require recognition or disclosure in the consolidated financial statements.

Concentration of Risk

Cash and cash equivalents are maintained at financial institutions and, at times, balances may exceed federally-insured limits. The Company has never
experienced any losses related to these balances.

The Company had one supplier for which amounts due at December 25, 2019 totaled 11.7% of the Company’s accounts payable. As of December 26, 2018,
the Company had one supplier for which amounts due totaled 36.0% of the Company’s accounts payable. Purchases from the Company’s largest supplier
totaled 29.0% of the Company’s purchases for fiscal 2019, 28.8% for fiscal 2018 and 29.3% for fiscal 2017 with no amounts payable at December 25, 2019
or December 26, 2018. In fiscal 2019, 2018 and 2017, Company-operated and franchised restaurants in the greater Los Angeles area generated, in the
aggregate, approximately 70.5%, 69.2%, and 72.9%, respectively, of total revenue. one franchisee accounted for 10% of total

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accounts receivable as of December 25, 2019, and two franchisees accounted for 40% of total accounts receivable as of December 26, 2018.

Management believes the loss of the significant supplier or franchisee could have a material adverse effect on the Company's consolidated results of
operations and financial condition.

Accounts and Other Receivables, Net

Accounts and other receivables consist primarily of royalties, advertising and sublease rent and related amounts receivable from franchisees. Such
receivables are due on a monthly basis, which may differ from the Company’s fiscal month-end dates. Accounts and other receivables also include
credit/debit card receivables. The need for an allowance for doubtful accounts is reviewed on a specific identification basis and takes into consideration
past due balances and the financial strength of the obligor. Bad debt expense was immaterial for the years ended December 25, 2019, December 26,
2018, and December 27, 2017.

Inventories

Inventories consist principally of food, beverages and supplies and are valued at the lower of average cost or net realizable value.

Property and Equipment, Net

Property and equipment are recorded at cost and are depreciated using the straight-line method over the estimated useful lives of the assets. Expenditures
for reimbursements and improvements that significantly add to the productivity capacity or extend the useful life are capitalized, while expenditures for
maintenance and repairs are expensed as incurred. Leasehold improvements and property held under finance leases are amortized over the shorter of their
estimated useful lives or the remaining lease terms. For leases with renewal periods at the Company’s option, the Company generally uses the original lease
term, excluding the option periods, to determine estimated useful lives; if failure to exercise a renewal option imposes an economic penalty on the
Company, such that management determines at the inception of the lease that renewal is reasonably assured, the Company may include the renewal option
period in the determination of appropriate estimated useful lives.

The estimated useful service lives are as follows:

Buildings

Land improvements

Building improvements

Restaurant equipment

Other equipment

Leasehold improvements

20 years

3—30 years

3—10 years

3—10 years

2—10 years

Shorter of useful life or lease term

The Company capitalizes certain directly attributable internal costs in conjunction with the acquisition, development and construction of future restaurants.
The Company also capitalizes certain directly attributable costs, including interest, in conjunction with constructing new restaurants. These costs are
included in property and amortized over the shorter of the life of the related buildings and leasehold improvements or the lease term. Costs related to
abandoned sites and other site selection costs that cannot be identified with specific restaurants are charged to general and administrative expenses in the
accompanying consolidated statements of operations, and were $0.1 million, $0.3 million and $0.5 million for the years ended December 25, 2019,
December 26, 2018, and December 27, 2017, respectively. The Company capitalized internal costs related to site selection and construction activities of
$1.1 million, $1.3 million and $1.9 million for the years ended December 25, 2019, December 26, 2018, and December 27, 2017, respectively. Capitalized
internal interest costs related to site selection and construction activities were $0.1 million, $0.2 million and $0.2 million for the years ended December 25,
2019, December 26, 2018, and December 27, 2017, respectively.

Impairment of Long-Lived and ROU Assets

The Company reviews its long-lived and right-of-use assets ("ROU assets") for impairment on a restaurant-by-restaurant basis whenever events or changes
in circumstances indicate that the carrying value of certain long-lived and ROU assets may not be recoverable. The Company considers a triggering event,
related to long-lived assets or ROU assets in a net asset position, to have occurred related to a specific restaurant if the restaurant’s cash flows for the last
twelve months are less than a minimum

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threshold or if consistent levels of undiscounted cash flows for the remaining lease period are less than the carrying value of the restaurant’s assets.
Additionally, the Company considers a triggering event related to ROU assets, to have occurred related to a specific lease if the location has been subleased
and future estimated sublease income is less than current lease payments. If the Company concludes that the carrying value of certain long-lived and ROU
assets will not be recovered based on expected undiscounted future cash flows, an impairment loss is recorded to reduce the long-lived or ROU assets to
their estimated fair value. The fair value is measured on a nonrecurring basis using unobservable (Level 3) inputs. There is uncertainty in the projected
undiscounted future cash flows used in the Company's impairment review analysis, which requires the use of estimates and assumptions. If actual
performance does not achieve the projections, or if the assumptions used change in the future, the Company may be required to recognize impairment
charges in future periods, and such charges could be material. Based on the results of this analysis, the Company recorded non-cash impairment charges of
$3.6 million for the year ended December 25, 2019, primarily related to the carrying value of the ROU assets of four restaurants sold to franchisees and one
restaurant closed during fiscal 2019, and the long-lived assets of one restaurant in California.

In fiscal 2018, the Company recorded a non-cash impairment charge of $5.1 million, primarily related to the carrying value of four restaurants in Arizona,
California and Texas, including a restaurant in Texas that opened in early 2018. In fiscal 2017, the Company recorded a non-cash impairment charge of
$32.6 million, primarily related to the carrying value of the assets of 23 restaurants in Arizona, California and Texas. The impairment expense for fiscal
2017 includes an impairment expense of $27.7 million, representing the entire value of capitalized assets of all of the company-operated restaurants in
Texas, net of previously recorded depreciation. Factors which led to the impairment of the Texas restaurants included operating results, which indicated that
the restaurants did not achieve the sales volumes required to generate positive cash flows or improve profitability in the Texas market, along with the
related future cash flow assumptions, including comparable sales rate growth and restaurant operating costs, over the remaining lease terms and the age of
the restaurants in Texas. The restaurants in Texas began opening in late 2014, causing a higher net book value at the time of impairment testing, and
increased difficulty projecting results for newer restaurants in newer markets. Given the difficulty in projecting results for newer restaurants in newer
markets, we are also monitoring the recoverability of the carrying value of the assets of several other restaurants on an ongoing basis. For these restaurants,
if expected performance improvements are not realized, an impairment charge may be recognized in future periods, and such charge could be material.

Closed-Store Reserves

Prior to the adoption of Topic 842 “Leases,” when the Company closed a restaurant, it reviewed the future minimum lease payments and related ancillary
costs from the date of the restaurant closure to the end of the remaining lease term and recorded a lease charge for the lease liabilities to be incurred, net of
any estimated sublease recoveries. The estimates of future closed-store reserves were re-evaluated and adjusted each period based on information available
as of the period. In addition, an impairment charge was recognized for any remaining carrying value of certain restaurant assets. During fiscal 2018, the
Company closed seven restaurants in Arizona, California and Texas. These closures resulted in closed-store reserve expenses of $4.5 million during fiscal
2018. During fiscal 2017, the Company closed four restaurants in Texas, one of which was fully impaired during the fourth quarter of 2016, one of which
was impaired during the third quarter of 2016 and the other two were impaired in fiscal 2017. Additionally, the Company closed one restaurant in Arizona,
which was fully impaired in the third quarter of 2016. These closures resulted in closed-store reserve expenses of $1.1 million during fiscal 2017.

Subsequent to the adoption of Topic 842, the Company no longer recognizes a closed-store reserve when the Company closes a restaurant, as there is
already a lease liability on its books related to the future lease payments. Rather, when a restaurant is closed, the Company will evaluate the ROU Asset for
impairment, based on anticipated sublease recoveries. The remaining value of the ROU Asset is amortized on a straight-line basis, with the expense
recognized in closed-store reserve expense.

During fiscal 2019, the Company closed two restaurants in California and two in Texas and recognized $1.3 million of closed-store reserve expense for the
fiscal year ended 2019.

Goodwill and Indefinite-Lived Intangible Assets

In January 2017, the Financial Accounting Standards Board ("FASB") issued Accounting Standards Update ("ASU") No. 2017-04, "Intangibles—Goodwill
and Other (Topic 350): Simplifying the Test for Goodwill Impairment," ("ASU 2017-04"), simplifying the manner in which an entity is required to test for
goodwill impairment by eliminating Step 2 from the goodwill impairment test. The Company adopted ASU 2017-04 in the fourth quarter of 2018.

The Company’s indefinite-lived intangible assets consist of trademarks. Goodwill represents the excess of cost over fair value of net identified assets
acquired in business combinations accounted for under the purchase method. The Company does not amortize its goodwill and indefinite-lived intangible
assets. Goodwill resulted from the Acquisition and from the acquisition of certain franchise locations.

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Upon the sale of a restaurant, the Company evaluates whether there is a decrement of goodwill. The amount of goodwill included in the cost basis of the
asset sold is determined based on the relative fair value of the portion of the reporting unit disposed of compared to the fair value of the reporting unit
retained. The Company determined there was no decrement of goodwill related to the disposition of restaurants in fiscal 2019.

The Company performs annual impairment tests for goodwill during the fourth fiscal quarter of each year, or more frequently if impairment indicators
arise.

The Company reviews goodwill for impairment utilizing either a qualitative assessment or by comparing the fair value of a reporting unit with its carrying
amount. If the Company decides that it is appropriate to perform a qualitative assessment and concludes that the fair value of a reporting unit more likely
than not exceeds its carrying value, no further evaluation is necessary. If an impairment test is performed which determines the carrying amount of a
reporting unit is greater than its fair value, an impairment charge will be recognized for the amount by which the carrying amount of a reporting unit is
greater than its fair value, up to the amount of its allocated goodwill.

The Company performs annual impairment tests for indefinite-lived intangible assets during the fourth fiscal quarter of each year, or more frequently if
impairment indicators arise. An impairment test consists of either a qualitative assessment or a comparison of the fair value of an intangible asset with its
carrying amount. The excess of the carrying amount of an intangible asset over its fair value is its impairment loss.

The assumptions used in the estimate of fair value are generally consistent with the past performance of the Company’s reporting segment and are also
consistent with the projections and assumptions that are used in current operating plans. These assumptions are subject to change as a result of changing
economic and competitive conditions.

Although the Company recognized expense related to the impairment of assets of one restaurant and ROU assets of four restaurants during the year ended
December 25, 2019, upon completion of the qualitative assessment, the Company did not identify any indicators of potential impairment for its goodwill or
indefinite-lived intangible assets. Furthermore, the Company did not identify any indicators of potential impairment during the years ended December 26,
2018 or December 27, 2017, and thus no impairment was recorded.

Other Intangibles, Net—Definite Lived

Definite lived intangible assets and liabilities consist of the value allocated to the Company’s favorable and unfavorable leasehold interests that resulted
from the Acquisition.

Favorable leasehold interest represents the asset in excess of the approximate fair market value of the leases assumed as of November 17, 2005, the date of
the Acquisition. The amount is being reduced over the remaining life of the leases. This amount is shown as other intangible assets, net, on the
accompanying consolidated balance sheets.

Unfavorable leasehold interest liability represents the liability in excess of the approximate fair market value of the leases assumed as of November 17,
2005, the date of the Acquisition. The amount is being reduced over the remaining life of the leases. This amount is shown as other intangible liabilities,
net, on the accompanying consolidated balance sheets.

Upon the Company's adoption of the new lease guidance in the first quarter of 2019, the Company's favorable and unfavorable leasehold improvements are
now included as part of the ROU asset. See "Note 5. Leases" for more information.

Deferred Financing Costs

Deferred financing costs are capitalized and amortized over the period of the loan on a straight-line basis, which approximates the effective interest method.
Transaction costs of $0.8 million were incurred in connection with the July 13, 2018 refinancing and were capitalized during fiscal 2018. Included in other
assets are deferred financing costs (net of accumulated amortization), related to the revolver, of $0.8 million and $1.1 million as of December 25, 2019 and
December 26, 2018, respectively. Amortization expense for deferred financing costs was approximately $0.3 million for each of the three years ended
December 25, 2019, December 26, 2018, and December 27, 2017, and is reflected as a component of interest expense in the accompanying consolidated
statements of operations.

Insurance Reserves

The Company is responsible for workers’ compensation, general and health insurance claims up to a specified aggregate stop loss amount. The Company
maintains a reserve for estimated claims both reported and incurred but not reported, based on historical claims experience and other assumptions. At
December 25, 2019 and December 26, 2018, the Company had accrued $9.4 million and $7.1 million, respectively, and such amounts are reflected as
accrued insurance in the accompanying consolidated balance sheets. The expense for such reserves for the years ended December 25, 2019, December 26,
2018

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and December 27, 2017, totaled $9.6 million, $8.0 million, and $6.8 million, respectively. These amounts are included in labor and related expenses and
general and administrative expenses on the accompanying consolidated statements of operations.

Restaurant Revenue

Revenues from the operation of company-operated restaurants are recognized as food and beverage products are delivered to customers and payment is
tendered at the time of sale. The Company presents sales net of sales-related taxes and promotional allowances. Promotional allowances amounted to
approximately $8.0 million, $8.8 million and $8.9 million during the years ended December 25, 2019, December 26, 2018, and December 27, 2017,
respectively.

The Company offers a loyalty rewards program, which awards a customer one point for every $1 spent. When 100 points are accumulated a $10 reward to
be used on future purchases is earned. If a customer does not earn or use points within a one-year period, their account is deactivated and all points expire.
Additionally, if a $10 reward is not used within six months it expires. When a customer is part of the rewards program, the obligation to provide future
discounts related to points earned is considered a separate performance obligation, to which a portion of the transaction price is allocated. The performance
obligation related to loyalty points is deemed to have been satisfied, and the amount deferred in the balance sheet is recognized as revenue, when the points
are transferred to a $10 reward and redeemed, the points or reward expire, or the likelihood of redemption is remote. A portion of the transaction price is
allocated to loyalty points, if necessary, on a pro-rata basis, based on stand-alone selling price, as determined by menu pricing and loyalty point terms. As
of December 25, 2019 and December 26, 2018, the revenue allocated to loyalty points that have not been redeemed are $1.1 million and $1.0 million,
respectively, which are reflected in the Company's accompanying consolidated balance sheets within other accrued expenses and current liabilities. The
Company expects the loyalty points to be redeemed and recognized over a one year period.

The Company sells gift cards to its customers in the restaurants and through selected third parties. The gift cards sold to customers have no stated
expiration dates and are subject to actual and/or potential escheatment rights in several of the jurisdictions in which the Company operates. Furthermore,
due to these escheatment rights, the Company does not recognize breakage related to the sale of gift cards due to the immateriality of the amount remaining
after escheatment. The Company recognizes income from gift cards when redeemed by the customer. Unredeemed gift card balances are deferred and
recorded as other accrued expenses on the accompanying consolidated balance sheets.

The Company adopted Accounting Standards Codification ("ASC") Topic 606 - Revenue from Contracts with Customers ("Topic 606") on December 28,
2017. As a result, the Company has changed its accounting policy for revenue recognition as detailed below. The Company generates a substantial amount
of its revenues from company-operated restaurants. This revenue stream was not impacted by the adoption of Topic 606.

The Company applied Topic 606 using the modified retrospective method by recognizing the cumulative effect of initially applying Topic 606 as an
adjustment to the opening balance of equity at December 28, 2017. The cumulative catch-up adjustment recorded to accumulated deficit was approximately
$3.5 million, net of taxes, related to franchise and development fees. The adoption of this guidance did not have a material change on revenue from
Company-operated restaurant revenue, gift cards or the Company's loyalty program. The fiscal year 2017 comparative information has not been adjusted
and continues to be reported under Topic 605. The details of the significant changes and quantitative impact of the changes are set out below and in "Note
15. Revenue from Contracts with Customers."

Franchise Revenue

Franchise revenue consists of franchise royalties, initial franchise fees, license fees due from franchisees and IT support services. Rental income for
subleases to franchisees are outside of the scope of the revenue standard and are within the scope of lease guidance. Under Topic 842, sublease income is
recorded on a gross basis within the consolidated statements of operations. Franchise royalties are based upon a percentage of net sales of the franchisee
and were previously recorded as income as such sales are earned by the franchisees, which does not change with the adoption of Topic 606.

For franchise and development agreement fees, the Company's previous accounting policy was to recognize initial franchise fees, development fees, and
franchise agreement renewals when all material obligations had been performed and conditions had been satisfied, typically when operations of the
franchised restaurant had commenced. In accordance with the new guidance, the initial franchise services, or exclusivity of the development agreements,
are not distinct from the continuing rights or services offered during the term of the franchise agreement and are, therefore, treated as a single performance
obligation. As such, initial franchise and development fees received, and subsequent renewal fees, are recognized over the franchise or renewal term, which
is typically twenty years. As of December 25, 2019, the Company had executed development agreements that represent commitments to open 44 franchised
restaurants at various dates through 2022.

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This revenue stream is made up of the following performance obligations:

•

•

•

Franchise License - inclusive of advertising services, development agreements, training, access to plans and help desk services;

Discounted renewal option; and

Hardware services.

The Company satisfies the performance obligation related to the franchise license over the term of the franchise agreement, which is typically 20 years.
Payment for the franchise license consists of three components, a fixed-fee related to the franchise/development agreement, a sales-based royalty fee and a
sales-based advertising fee. The fixed fee, as determined by the signed development and/or franchise agreement, is due at the time the development
agreement is entered into, and/or when the franchise agreement is signed, and does not include a finance component.

The sales-based royalty fee and sales-based advertising fee are considered variable consideration and will continue to be recognized as revenue as such
sales are earned by the franchisees. Both sales-based fees qualify under the royalty constraint exception, and do not require an estimate of future transaction
price. Additionally, the Company is utilizing the practical expedient regarding disclosure of the aggregate amount of the transaction price allocated to the
performance obligations that are unsatisfied for sales-based royalties.

In certain franchise agreements, the Company offers a discounted renewal to incentivize future renewals after the end of the initial franchise term. As this is
considered a separate performance obligation, the Company allocated a portion of the initial franchise fee to this discounted renewal, on a pro-rata basis,
assuming a 20-year renewal. This performance obligation is satisfied over the renewal term, which is typically 10 or 20 years, while payment is fixed and
due at the time the renewal is signed.

The Company purchases hardware, such as scanners, printers, cash registers and tablets, from third-party vendors, which it then sells to franchisees. As the
Company is considered the principal in this relationship, payment received for the hardware is considered revenue, and is received upon transfer of the
goods from the Company to the Franchisee. As of December 25, 2019, there were no performance obligations, related to hardware services that were
unsatisfied or partially satisfied.

Franchise Advertising Fee Revenue

The Company's previous accounting policy was to recognize advertising funded by franchisees on a net basis in the consolidated statements of operations,
and as a liability within the consolidated balance sheets. Under the new guidance, the Company presents advertising contributions received from
franchisees as franchise advertising fee revenue and records all expenses of the advertising fund within franchise expenses, resulting in an increase in
revenues and expenses on the consolidated statements of operations, with no change to the consolidated balance sheets.

Advertising Costs

Advertising expense is recorded as the obligation to contribute to the advertising fund is accrued, generally when the associated revenue is recognized.
Advertising expense, which is a component of occupancy and other operating expenses, was $16.1 million for both years ended December 25, 2019
and December 26, 2018 and $15.5 million for the year ended December 27, 2017, and is in addition to $22.4 million, $21.2 million and $20.5 million,
respectively, funded by the franchisees’ advertising fees.

Franchisees pay a monthly fee to the Company that ranges from 4% to 5% of their restaurants’ net sales as reimbursement for advertising, public relations
and promotional services the Company provides, which is included within franchise advertising fee revenue. Fees received in advance of provided services
are included in other accrued expenses and current liabilities and were $0.5 million and $0.3 million at December 25, 2019 and December 26, 2018,
respectively. Pursuant to the Company’s Franchise Disclosure Document, company-operated restaurants contribute to the advertising fund on the same
basis as franchised restaurants. At December 25, 2019, the Company was obligated to spend $0.5 million more in future periods to comply with this
requirement.

Production costs of commercials, programming and other marketing activities are charged to the advertising funds when the advertising is first used for its
intended purpose. Total contributions and other marketing expenses are included in general and administrative expenses in the accompanying consolidated
statements of operations.

Preopening Costs

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Preopening costs incurred in connection with the opening of new restaurants are expensed as incurred. Preopening costs, which are included in general and
administrative expenses on the accompanying consolidated statements of operations, were $0.4 million, $0.8 million and $2.0 million for the years ended
December 25, 2019, December 26, 2018, and December 27, 2017, respectively.

Leases

The Company’s operations utilize property, facilities, equipment and vehicles. Buildings and facilities leased from others are primarily for restaurants and
support facilities. Restaurants are operated under lease arrangements that generally provide for a fixed base rent and, in some instances, contingent rent
based on a percentage of gross operating profit or net revenues in excess of a defined amount. Initial terms of land and restaurant building leases generally
have terms of 20 years, exclusive of options to renew. Leases of equipment primarily consist of restaurant equipment, computer systems and vehicles. The
Company subleases facilities to certain franchisees and other non-related parties which are recorded on a straight-line basis. Refer to "Changes in
Accounting Policy" below for more details on treatment of operating leases under Topic 842 that was adopted on December 27, 2018.

For periods prior to the adoption of Topic 842, leases are accounted for under Topic 840. Under Topic 840, rent expense for the Company’s operating
leases, which generally have escalating rents over the term of the lease, is recorded on a straight-line basis over the expected lease term. The lease term
begins when the Company has the right to control the use of the leased property, which is typically before rent payments are due under the terms of the
lease. Rent expense is included in occupancy and other operating expenses on the consolidated statements of operations. The difference between rent
expense and rent paid is recorded as deferred rent, which is included in current liabilities and other noncurrent liabilities in the accompanying consolidated
balance sheets. Percentage rent expenses are recorded based on estimated sales or gross margin for respective restaurants over the contingency period.

Any leasehold improvements that are funded by lessor incentives under operating leases are recorded as leasehold improvements and amortized over the
expected lease term. Such incentives are also recorded as deferred rent and amortized as reductions to rent expense over the expected lease term.

Loss on Disposition of Restaurants

During fiscal 2019, the Company completed the sale of four company-operated restaurants within the San Francisco area to an existing franchisee, seven
company-operated restaurants in the Phoenix area to another existing franchisee and five company-operated restaurants in Texas to a third franchisee. The
Company has determined that these restaurant dispositions represent multiple element arrangements, and as a result, the cash consideration received was
allocated to the separate elements based on their relative standalone selling price. Cash proceeds included upfront consideration for the sale of the
restaurants and franchise fees, as well as future cash consideration for royalties and lease payments. The Company considered the future lease payments in
allocating the initial cash consideration received. The cash consideration per restaurant for franchise fees is consistent with the amounts stated in the related
franchise agreements, which are charged for separate standalone arrangements. The Company initially defers and subsequently recognizes the franchise
fees over the term of the franchise agreement. Future royalty income is also recognized in revenue as earned.

These sales resulted in cash proceeds of $4.8 million and a net loss on sale of restaurants of $5.1 million for the year ended December 25, 2019. These
restaurants are now included in the total number of franchised El Pollo Loco restaurants.

Recovery of Securities Class Action Legal Expense

During fiscal 2019, 2018 and 2017, the Company received insurance proceeds of $10.0 million, $8.4 million and $1.7 million, respectively, related to the
reimbursement of certain legal expenses paid in prior years for the defense of securities lawsuits. See "Note 13. Commitments and Contingencies—Legal
Matters."

Derivative Financial Instruments

The Company uses an interest rate swap, a derivative instrument, to hedge interest rate risk and are not used for trading purposes. The derivative contract is
entered into with financial institutions.

The Company records the derivative instrument at fair value within other assets on its consolidated balance sheet. The derivative instrument qualifies as a
hedging instrument in a qualifying cash flow hedge relationship, the gain or loss on the derivative instrument is reported as a component of accumulated
other comprehensive income ("AOCI") and reclassified into earnings in the same period or periods during which the hedged transaction affects
earnings. For any derivative instruments not

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designated as hedging instruments, the gain or loss will be recognized in earnings immediately. If a derivative previously designated as a hedge is
terminated, or no longer meets the qualifications for hedge accounting, any balances in AOCI will be reclassified into earnings immediately.

As a result of the use of an interest rate swap, the Company is exposed to risk that the counterparty will fail to meet their contractual obligations. To
mitigate the counterparty credit risk, the Company will only enter into contracts with major financial institutions, based upon their credit ratings and other
factors, and will continue to assess the creditworthiness of the counterparty. As of December 25, 2019, the counterparty to the Company's interest rate swap
has performed in accordance with their contractual obligation.

Income Taxes

The provision for income taxes, income taxes payable and deferred income taxes is determined using the asset and liability method. Deferred tax assets and
liabilities are determined based on temporary differences between the financial carrying amounts and the tax basis of assets and liabilities using enacted tax
rates in effect in the years in which the temporary differences are expected to reverse. On a periodic basis, the Company assesses the probability that its net
deferred tax assets, if any, will be recovered. If after evaluating all of the positive and negative evidence, a conclusion is made that it is more likely than not
that some portion or all of the net deferred tax assets will not be recovered, a valuation allowance is provided by a charge to tax expense to reserve the
portion of the deferred tax assets which are not expected to be realized.

The Company reviews its filing positions for all open tax years in all U.S. federal and state jurisdictions where it is required to file.

When there are uncertainties related to potential income tax benefits, in order to qualify for recognition, the position the Company takes has to have at least
a “more likely than not” chance of being sustained (based on the position’s technical merits) upon challenge by the respective authorities. The term “more
likely than not” means a likelihood of more than 50%. Otherwise, the Company may not recognize any of the potential tax benefit associated with the
position. The Company recognizes a benefit for a tax position that meets the “more likely than not” criterion as the largest amount of tax benefit that is
greater than 50% likely of being realized upon its effective resolution. Unrecognized tax benefits involve management’s judgment regarding the likelihood
of the benefit being sustained. The final resolution of uncertain tax positions could result in adjustments to recorded amounts and may affect our results of
operations, financial position and cash flows.

The Company’s policy is to recognize interest or penalties related to income tax matters in income tax expense. The Company had no accrual for interest or
penalties at December 25, 2019 or December 26, 2018, and did not recognize interest or penalties during the years ended December 25, 2019,
December 26, 2018, and December 27, 2017, since there were no material unrecognized tax benefits. Management believes no significant change to the
amount of unrecognized tax benefits will occur within the next twelve months.

On July 30, 2014, the Company entered into an income tax receivable agreement ("TRA"). The TRA calls for the Company to pay to its pre-IPO
stockholders 85% of the savings in cash that the Company realizes in its taxes as a result of utilizing its net operating losses and other tax attributes
attributable to preceding periods. In fiscal 2015, the Company incurred a charge of approximately $41.4 million relating to the present value of its total
expected TRA payments. As of December 25, 2019 and December 26, 2018, the Company had accrued $8.2 million and $13.9 million, respectively
relating to expected TRA payments. In fiscal 2019, 2018 and 2017, we paid $5.8 million, $7.3 million and $11.1 million, respectively, to our pre-IPO
stockholders under the TRA.

Fair Value Measurements

Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the
measurement date. Financial assets and liabilities carried at fair value are classified and disclosed in one of the following three categories:

•

•

•

Level 1: Quoted prices for identical instruments in active markets.

Level 2: Observable prices for similar instruments in active markets; quoted prices for identical or similar instruments in markets that are not
active; and model-derived valuations whose inputs or significant value drivers are observable.

Level 3: Unobservable inputs used when little or no market data is available.

During the year ended December 25, 2019, the Company entered into an interest rate swap, which is required to be measured at fair value on a recurring
basis. The fair value was determined based on Level 2 inputs, which include valuation models, as

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EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

reported by the Company's counterparty. These valuation models use a discounted cash flow analysis on the cash flows of the derivative based on the terms
of the contract and the forward yield curves adjusted for our credit risk. The key inputs for the valuation models are observable market prices, discount
rates, and forward yield curves. See "Note 6. Long-Term Debt" for further discussion regarding our interest rate swaps. The following table presents fair
value for the interest rate swap at December 25, 2019 (in thousands):

Other assets - Interest rate swap

Fair Value

Level 1

Level 2

Level 3

$

360   $

—   $

360   $

—

Fair Value Measurements Using

The Company had no assets or liabilities required to be measured at fair value on a recurring basis as of December 26, 2018.

Certain assets and liabilities are measured at fair value on a nonrecurring basis. In other words, the instruments are not measured at fair value on an ongoing
basis but are subject to fair value adjustments only in certain circumstances (for example, when there is evidence of impairment).

The following non-financial instruments were measured at fair value, on a nonrecurring basis, as of and for the year ended December 25, 2019 (in
thousands):

Certain ROU assets, net

Certain property and equipment, net

Fair Value Measurements Using

Total

Level 1

Level 2

Level 3

Impairment
Losses

$

$

6,196   $

—   $

—   $

—   $

—   $

—   $

6,196   $

—   $

3,220

339

The following non-financial instruments were measured at fair value, on a nonrecurring basis, as of and for the year ended December 26, 2018 (in
thousands):

Certain property and equipment, net

$

449   $

—   $

—   $

449   $

5,147

The following non-financial instruments were measured at fair value, on a nonrecurring basis, as of and for the year ended December 27, 2017 (in
thousands):

Total

Level 1

Level 2

Level 3

Impairment
Losses

Fair Value Measurements Using

Total

Level 1

Level 2

Level 3

Impairment
Losses

Fair Value Measurements Using

Certain property and equipment, net

$

—   $

—   $

—   $

—   $

32,594

During fiscal 2019, the Company recorded $3.6 million of expenses related to the impairment of assets primarily related to the carrying value of the ROU
assets of four restaurants sold to franchisees and the long-lived assets of one restaurant in California. In fiscal 2018, the Company recorded $5.1 million in
impairment charges primarily related to the carrying value of the long-lived assets of four restaurants in Arizona, California and Texas, as well as the
strategic decision to close two restaurants in Texas. In fiscal 2017, the Company recorded $32.6 million in impairment charges that was primarily related to
the carrying value of the long-lived assets of 23 restaurants in Arizona, California and Texas. The fair value measurements used in these impairment
evaluations were based on discounted cash flow estimates using unobservable Level 3 inputs, based on market assumptions. 

Fair Value of Financial Instruments

The carrying amounts of cash and cash equivalents, accounts receivable, accounts payable and certain accrued expenses approximate fair value due to their
short-term maturities. The recorded value of the TRA approximates fair value, based on borrowing rates currently available to the Company for debts with
similar terms and remaining maturities (Level 3 measurement).

Stock-Based Compensation

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EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

Accounting literature requires the recognition of compensation expense using a fair-value based method for costs related to all share-based payments
including stock options and restricted stock issued under the Company’s employee stock plans. The guidance also requires companies to estimate the fair
value of stock option awards on the date of grant using an option pricing model, which require the input of subjective assumptions. The Company is
required to use judgment in estimating the amount of stock-based awards that are expected to be forfeited. If actual forfeitures differ significantly from the
original estimate, stock-based compensation expense and the results of operations could be affected. The cost is recognized on a straight-line basis over the
period during which an employee is required to provide service, usually the vesting period. For options or restricted shares that are based on a performance
requirement, the cost is recognized on an accelerated basis over the period to which the performance criteria relate.

Earnings per Share

Earnings per share (“EPS”) is calculated using the weighted average number of common shares outstanding during each period. Diluted EPS assumes the
conversion, exercise or issuance of all potential common stock equivalents unless the effect is to reduce a loss or increase the income per share. For
purposes of this calculation, options and restricted stock awards are considered to be common stock equivalents and are only included in the calculation of
diluted earnings per share when their effect is dilutive. The shares used to compute basic and diluted net income per share represent the weighted-average
common shares outstanding.

Recently Adopted Accounting Pronouncements

In August 2018, the SEC adopted the final rule under SEC Release No. 33-10532, “Disclosure Update and Simplification,” amending certain disclosure
requirements that were redundant, duplicative, overlapping, outdated or superseded.  In addition, the amendments expanded the disclosure requirements on
the analysis of stockholders' equity for interim financial statements.  Under the amendments, an analysis of changes in each caption of stockholders' equity
presented in the balance sheet must be provided in a note or separate statement.  The analysis should present a reconciliation of the beginning balance to the
ending balance of each period for which a statement of comprehensive income is required to be filed.  The Company adopted SEC Release No. 33-10532
as of December 27, 2018.

In June 2018, the Financial Accounting Standards Board (“FASB”) issued Accounting Standards Update (“ASU”) No. 2018-07, “Compensation—Stock
Compensation (Topic 718): Improvements to Nonemployee Share-Based Payment Accounting”, (“ASU 2018-07”) which expands the scope of Topic 718
to include share-based payment transactions for acquiring goods and services from non-employees. ASU 2018-07 is effective for financial statements
issued for annual periods beginning after December 15, 2018, and for the interim periods therein. The Company adopted ASU 2018-07 as of December 27,
2018 and it did not have a significant impact on the Company’s consolidated financial position or results of operations.

In August 2017, the FASB issued ASU 2017-12, "Derivatives and Hedging," which refines and expands existing hedge accounting guidance. The Company
adopted ASU 2017-12 as of December 27, 2018. The adoption of this standard did not have a material impact on the consolidated financial statements.

In February 2016, the FASB issued ASU No. 2016-02, “Leases,” (“Topic 842”). Topic 842 establishes a right-of-use model that requires a lessee to record a
ROU Asset and a lease liability on the balance sheet for all leases with terms longer than 12 months. Leases will be classified as either finance or operating,
with classification affecting the pattern of expense recognition in the income statement. The new standard was effective for fiscal years beginning after
December 15, 2018, including interim periods therein. In July 2018, the FASB issued ASU No. 2018-11, which provides an alternative transition method
that allows entities to apply the new leases standard at the adoption date and recognize a cumulative-effect adjustment to the opening balance of retained
earnings in the period of adoption. The Company adopted Topic 842, and all related ASU’s as of December 27, 2018. See “Changes in Accounting
Policies” below for further details.

Recent Accounting Pronouncements Not Yet Adopted

In December 2019, the FASB issued ASU No. 2019-12, "Income Taxes (Topic 740): Simplifying the Accounting for Income Taxes", which modifies Topic
740 to simplify the accounting for income taxes. ASU 2019-12 is effective for financial statements issued for annual periods beginning after December 15,
2020, and for the interim periods therein. The adoption of ASU 2019-12 is not expected to have a significant impact on the Company’s consolidated
financial position or results of operations.

Changes in Accounting Policies

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EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

Except for the changes below, the Company has consistently applied the accounting policies to all periods presented in these consolidated financial
statements.

The Company adopted Topic 842 with a date of initial application of December 27, 2018. As a result, the Company has changed its accounting policy for
leases as detailed below.

The Company’s operations utilize property, facilities, equipment and vehicles, the majority of which are operating leases. Additionally, the Company has
various contracts with vendors that have been determined to contain an embedded lease in accordance with Topic 842. As of the date of adoption, the
Company recognized a ROU Asset and lease liability equal to the present value of these leases within its consolidated balance sheet for any leases with
terms longer than 12 months. The Company also has one finance lease, subleases facilities to certain franchises and is the lessor for certain property,
facilities and equipment owned by the Company. The adoption of Topic 842 did not have an impact on our current accounting policies for these items.
Furthermore, the adoption of this standard did not have any impact on the Company’s consolidated statement of operations or the consolidated statement of
cash flows.

The Company applied Topic 842 using the effective date method, which allowed the Company to apply the standard as of the adoption date, and to
recognize the cumulative effect of initially applying Topic 842 as an adjustment to retained earnings at December 27, 2018, if applicable. Therefore, the
comparative information has not been adjusted and continues to be reported under Topic 840. However, the adoption of Topic 842 did not have any impact
to its retained earnings.

Additionally, the Company elected to apply the package of practical expedients, which allowed for carryforwards of 1) historical lease classifications, 2)
determination of whether a contract contains a lease under the new definition of a lease and 3) whether previously capitalized initial direct costs qualify for
capitalization. See "Note 5. Leases," for further details.

Franchise Development Option Agreement with Related Party

On July 11, 2014, EPL and LLC entered into a Franchise Development Option Agreement relating to development of our restaurants in the New York–
Newark, NY–NJ–CT–PA Combined Statistical Area (the “Territory”). EPL granted LLC the exclusive option to develop and open 15 restaurants in the
Territory over five years (the “Initial Option”), and, provided that the Initial Option is exercised, the exclusive option to develop and open up to an
additional 100 restaurants in the Territory over ten years. The Franchise Development Option Agreement terminates (i) ten years after execution, or (ii) if
the Initial Option is exercised, five years after that exercise. LLC may only exercise the Initial Option if EPL first determines to begin development of
company-operated restaurants in the Territory or support the development of the Territory. We have no current intention to begin development in the
Territory and as of December 25, 2019, no stores have been opened in the Territory.

3. PROPERTY AND EQUIPMENT

The costs and related accumulated depreciation and amortization of major classes of property are as follows (in thousands):

December 25, 2019

Land

Buildings and improvements

Other property and equipment

Construction in progress

Less: accumulated depreciation and amortization

$

$

  December 26, 2018
12,323

12,323   $

144,794  

75,234  

4,213  

236,564  

(144,786)  

91,778   $

156,806

76,061

2,989

248,179

(144,034)

104,145

Depreciation and amortization expense was $17.9 million, $17.8 million and $18.1 million for the years ended December 25, 2019, December 26, 2018,
and December 27, 2017, respectively.

Based on the Company’s review of its long-lived assets for impairment, the Company recorded non-cash impairment charges of $0.3 million, $5.1 million
and $32.6 million for the years ended December 25, 2019, December 26, 2018, and December 27, 2017, respectively.

76

 
 
 
EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

4. TRADEMARKS, OTHER INTANGIBLE ASSETS AND LIABILITIES

Domestic trademarks consist of the following (in thousands):

Cost

Accumulated impairment charges

Trademarks, net

Other intangible assets subject to amortization consist of the following (in thousands):

Favorable leasehold interest

Less: accumulated amortization

Total favorable leasehold interest, net

Unfavorable leasehold interest liability

Less: accumulated amortization

Unfavorable leasehold interest liability, net

$

$

$

$

$

$

December 25, 2019

  December 26, 2018
120,700

120,700   $

(58,812)  

61,888   $

(58,812)

61,888

December 25, 2019

  December 26, 2018
6,038

—   $

—  

—   $

—   $

—  

—   $

(5,758)

280

(9,156)

8,514

(642)

Upon the adoption of Topic 842 the favorable and unfavorable leasehold interest balances were netted with the ROU Asset for the respective operating
lease. See “Change in accounting policies" in Note 2 and "Note 5. Leases” for further details of the Company’s adoption of Topic 842. The aggregate
amortization expense for the years ended December 26, 2018, and December 27, 2017 was less than $0.1 million and $0.1 million, respectively.

5. LEASES

Adoption of Topic 842 "Leases"

On December 27, 2018, the Company adopted Topic 842, using the effective date method, recognizing and measuring all leases that existed as of
December 27, 2018. The Company recorded a cumulative-effect adjustment as of December 27, 2018. Comparative periods are presented in accordance
with ASC Topic 840 and do not include any retrospective adjustments to comparative periods to reflect the adoption of Topic 842. All leases that either (1)
commenced, or (2) were modified or re-measured after December 27, 2018 are accounted for under Topic 842.

As a result of Topic 842, the Company recognized a ROU Asset of $205.2 million and a lease liability of $222.3 million on its consolidated balance sheet
as of December 27, 2018. However, the adoption of Topic 842 did not result in a material impact on the Company’s consolidated statement of operations or
consolidated statement of cash flows.

Nature of leases

The Company’s operations utilize property, facilities, equipment and vehicles leased from others. Additionally, the Company has various contracts with
vendors that have been determined to contain an embedded lease in accordance with Topic 842.

As of December 25, 2019, the Company had one lease that it had entered into, but had not yet commenced. The Company does not have control of the
property until lease commencement.

Building and facility leases

The majority of the Company’s building and facilities leases are classified as operating leases; however, the Company currently has one facility lease that is
classified as a finance lease.

Restaurants are operated under lease arrangements that generally provide for a fixed base rent and, in some instances, contingent rent based on a percentage
of gross operating profit or net revenues in excess of a defined amount. Additionally, a number of the Company’s leases have payments, which increase at
pre-determined dates based on the change in the consumer price index. For all leases, the Company also reimburses the landlord for non-lease components,
or items that are not considered components of a contract, such as common area maintenance, property tax and insurance costs. While the Company

77

 
 
EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

determined not to separate lease and non-lease components, these payments are based on actual costs, making them variable consideration and excluding
them from the calculations of the ROU Asset and lease liability.

The initial terms of land and restaurant building leases are generally 20 years, exclusive of options to renew. These leases typically have four 5-year
renewal options, which have generally been excluded in the calculation of the ROU Asset and lease liability, as they are not considered reasonably certain
to be exercised, unless (1) the renewal had already occurred as of the time of adoption of Topic 842, or (2) there have been significant leasehold
improvements that have a useful life that extend past the original lease term. Furthermore, there are no residual value guarantees and no restrictions
imposed by the lease.

During the year ended December 25, 2019, the Company reassessed the lease terms on 11 restaurants due to certain triggering events, such as, the addition
of significant leasehold improvements, the decision to terminate a lease, or the decision to renew. As a result of the reassessment, an additional $4.7 million
of ROU assets and lease liabilities for the year ended December 25, 2019 were recognized, and will be amortized over the new lease term. The
reassessment did not have any impact on the original lease classification. Additionally, as the Company adopted all practical expedients available under
Topic 842, no reallocation between lease and non-lease components was necessary.

The Company also subleases facilities to certain franchisees and other non-related parties which are also considered operating leases. Sublease income also
includes contingent rental income based on net revenues. The vast majority of these leases have rights to extend terms via fixed rental increases. However,
none of these leases have early termination rights, the right to purchase the premises or any residual value guarantees. The Company does not have any
related party leases.

During fiscal 2019, we determined that the carrying value of ROU assets at certain restaurants was not recoverable. As a result, we recorded a $3.2 million
impairment expense for the year ended December 25, 2019. The impairment primarily related to four restaurants sold to franchisees and one restaurant
closed during fiscal 2019.

Equipment

Leases of equipment primarily consist of restaurant equipment, copiers and vehicles. These leases are fixed payments with no variable component.
Additionally, no optional renewal periods have been included in the calculation of the ROU Asset, there are no residual value guarantees and no restrictions
imposed.

Significant Assumptions and Judgments

In applying the requirements of Topic 842 the Company made significant assumptions and judgments related to determination of whether a contract
contains a lease and the discount rate used for the lease.

In determining if any of the Company’s contracts contain a lease the Company made assumptions and judgments related to its ability to direct the use of
any assets stated in the contract and the likelihood of renewing any short-term contracts for a period extending past twelve months.

The Company also made significant assumptions and judgments in determining an appropriate discount rate for property leases. These included using a
consistent discount rate for a portfolio of leases entered into at varying dates, using the full 20-year term of the lease, excluding any options, and using the
total minimum lease payments. The Company utilizes a third-party valuation firm in determining the discount rate, based on the above assumptions. For all
other leases, the Company uses the discount rate implicit in the lease, or the Company’s incremental borrowing rate.

As the Company has adopted the practical expedient not to separate lease and non-lease components, no significant assumptions or judgments were
necessary in allocating consideration between these components, for all classes of underlying assets.

The following table presents the Company’s total lease cost at December 25, 2019, disaggregated by underlying asset (in thousands):

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EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

Finance lease cost:

Amortization of right-of-use assets

Interest on lease liabilities

Operating lease cost

Short-term lease cost

Variable lease cost  

Sublease income

Total lease cost

Property
Leases

Equipment
Leases

Total

$

9   $

27  

—   $

—  

9

27

26,212  

1,273  

27,485

—  

455  

(2,430)  

34  

186  

—  

$

24,273   $

1,493   $

34

641

(2,430)

25,766

The following table presents the Company’s total lease cost on the consolidated statement of operations (in thousands):

Lease cost – Occupancy and other operating expenses

Lease cost – General & administrative

Lease cost – Depreciation and amortization

Lease cost – Interest expense

Lease cost - Closed-store reserve

Total lease cost, net

December 25, 2019

24,540

463

9

27

727

25,766

$

$

During the year ended December 25, 2019, the Company had the following cash and non-cash activities associated with its leases (in thousands):

Cash paid for amounts included in the measurement of lease liabilities

Operating cash flows used for operating leases

Financing cash flows used for finance leases

Non-cash investing and financing activities:

Operating lease ROU assets obtained in exchange for lease liabilities:

Operating lease ROU assets

Derecognition of ROU assets due to terminations, impairment or modifications

December 25, 2019

Property
Leases

Equipment
Leases

Total

$

$

25,168

(68)

  $

  $

1,282

  $

26,450

—   $

(68)

10,339

(4,574)

256

(157)

  $

  $

10,595

(4,731)

Operating lease ROU assets obtained and liabilities incurred as a result of adoption of ASC 842:

Operating lease ROU assets

Operating lease liabilities

$

$

200,555

217,615

  $

  $

4,668

4,668

  $

  $

205,223

222,283

Other Information

Weighted-average remaining lease term—finance leases

Weighted-average remaining lease term—operating leases

Weighted-average discount rate—finance leases

Weighted-average discount rate—operating leases

2.83

12.08

11.10%  

4.38%  

—    

3.20

—    

3.96%    

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EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

Information regarding the Company’s minimum future lease obligations at December 25, 2019 is as follows (in thousands):

For the Years Ending
December 30, 2020

December 29, 2021

December 28, 2022

December 27, 2023

December 25, 2024

Thereafter

Total

Less: imputed interest (3.96% to 11.1%)

Present value of capital lease obligations

Less: current maturities

Noncurrent portion

Finance Leases

Operating Leases

Minimum
Lease
Payments

Minimum
Lease
Payments

Minimum
Sublease
Income

$

$

$

2,754

2,887

3,284

3,318

3,203

27,265

42,711

54   $

26,808   $

54  

45  

—  

—  

—  

153   $

(36)  

117  

(34)  

83   $

25,978  

24,871  

22,309  

19,751  

139,454  

259,171   $

(45,273)  

213,898  

(16,406)  

197,492  

Information regarding the Company’s minimum future lease obligations at December 26, 2018 is as follows, under ASC 840 (in thousands):

For the Years Ending
December 25, 2019

December 30, 2020

December 29, 2021

December 28, 2022

December 27, 2023

Thereafter

Total

Less: imputed interest (11.0% to 11.1%)

Present value of capital lease obligations

Less: current maturities

Noncurrent portion

Short-Term Leases

Capital Leases

Minimum
Lease
Payments

Operating Leases

Minimum
Lease
Payments

Minimum
Sublease
Income

$

$

$

95   $

25,388   $

24,437  

23,342  

22,338  

20,634  

150,342  

266,481   $

54  

54  

45  

—  

—  

248   $

(64)    

184    

(68)    

116  

1,443

1,108

1,078

1,001

989

2,612

8,231

The Company has multiple short-term leases, which have terms of less than 12 months, and thus were excluded from the recognition requirements of Topic
842. The Company has recognized these lease payments in its consolidated statement of operations on a straight-line basis over the lease term and variable
lease payments in the period in which the obligation for those payments is incurred.

Lessor

The Company is a lessor for certain property, facilities and equipment owned by the Company and leased to others, principally franchisees, under non-
cancelable leases with initial terms ranging from 3 to 20 years. These lease agreements generally provide for a fixed base rent and, in some instances,
contingent rent based on a percentage of gross operating profit or net revenues. All leases are considered operating leases.

For the leases in which the Company is the lessor, there are options to extend the lease. However, there are no terms and conditions to terminate the lease,
no right to purchase premises and no residual value guarantees. Additionally, there are no related party leases.

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EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

For each of the years ended December 25, 2019, December 26, 2018 and December 27, 2017, the Company received $0.5 million of lease income from
company-owned locations.

6. LONG-TERM DEBT

On July 13, 2018, the Company refinanced the 2014 Revolver, pursuant to a credit agreement (the "2018 Credit Agreement") among EPL, as borrower, and
the Company and Intermediate, as guarantors, Bank of America, N.A., as administrative agent, swingline lender, and letter of credit issuer, the lenders party
thereto,  and  the  other  parties  thereto,  which  provides  for  the  $150.0 million five-year  2018  Revolver.  The  2018  Revolver  includes  a  sub  limit  of  $15.0
million  for  letters  of  credit  and  a  sub  limit  of  $15.0  million  for  swingline  loans.  The  obligations  under  the  2018  Credit  Agreement  and  related  loan
documents are guaranteed by the Company and Intermediate. The obligations of the Company, EPL and Intermediate under the 2018 Credit Agreement and
related loan documents are secured by a first priority lien on substantially all of their respective assets.

Under the 2018 Revolver, Holdings may not make certain payments such as cash dividends, except that it may, inter alia, (i) pay up to $1.0 million per year
to repurchase or redeem qualified equity interests of Holdings held by past or present officers, directors, or employees (or their estates) of the Company
upon death, disability, or termination of employment, (ii) pay under its income tax receivable agreement (the “TRA”), and, (iii) so long as no default or
event  of  default  has  occurred  and  is  continuing,  (a)  make  non-cash  repurchases  of  equity  interests  in  connection  with  the  exercise  of  stock  options  by
directors, officers and management, provided that those equity interests represent a portion of the consideration of the exercise price of those stock options,
(b) pay up to $0.5 million in any 12 month consecutive period to redeem, repurchase or otherwise acquire equity interests of any subsidiary that is not a
wholly-owned  subsidiary  from  any  holder  of  equity  interest  in  such  subsidiary,  (c)  pay  up  to  $2.5  million  per  year  pursuant  to  stock  option  plans,
employment agreements, or incentive plans, (d) make up to $5.0 million  in  other  restricted  payments  per  year,  and  (e)  make  other  restricted  payments,
subject  to  its  compliance,  on  a  pro  forma  basis,  with  (x)  a  lease-adjusted  consolidated  leverage  ratio  not  to  exceed  4.25  times  and  (y)  the  financial
covenants applicable to the 2018 Revolver.

Borrowings under the 2018 Revolver (other than any swingline loans) bear interest, at the borrower’s option, at rates based upon either LIBOR or a base
rate, plus, for each rate, a margin determined in accordance with a lease-adjusted consolidated leverage ratio-based pricing grid. The base rate is calculated
as the highest of (a) the federal funds rate plus 0.50%, (b) the published Bank of America prime rate, or (c) LIBOR plus 1.00%. For LIBOR loans, the
margin is in the range of 1.25% to 2.25%, and for base rate loans the margin is in the range of 0.25% to 1.25%. For borrowings under the 2018 Revolver
during  fiscal  2019,  the  interest  rate  range  was  3.2%  to  6.0%.  For  borrowings  under  the  2014  Revolver  and  the  2018  Revolver  during  fiscal  2018,  the
interest rate range was 3.3% to 4.0%. The interest rate under the 2018 Revolver was 3.2% at December 25, 2019 and 4.0%  under  the  2018  Revolver  at
December 26, 2018.  For  the  year  ended  December  25,  2019,  the  Company  had  interest  expense  of  $3.1 million  under  the  2018  Revolver.  For  the  year
ended December 26, 2018, the Company had interest expense of $3.0 million under the 2018 and 2014 Revolver, and for the year ended December 27,
2017, the Company had interest expense of $2.7 million under the 2014 Revolver.

The 2018 Credit Agreement contains certain financial covenants. The Company was in compliance with all such covenants at December 25, 2019.

At December 25, 2019, $8.4 million of letters of credit and $97.0 million of the revolving line of credit were outstanding. The amount available under the
revolving line of credit was $44.6 million at December 25, 2019.

Maturities

The 2018 Revolver and 2018 Credit Agreement will mature on July 13, 2023. During the year ended December 25, 2019, the Company borrowed $23.0
million net of pay downs of $19.0 million on the Company’s 2018 Revolver, primarily to fund settlement payments. See Note 13 for further details
regarding the settlement payments. During the year ended December 26, 2018, the Company elected to pay down $20.0 million, net of new borrowings of
$13.0 million during the year, of outstanding borrowings on the Company’s 2014 Revolver, respectively. There are no required principal payments prior to
maturity for the 2018 Revolver.

Interest Rate Swap

During the year ended December 25, 2019, the Company entered into a variable-to-fixed interest rate swap agreement with a notional amount of $40.0
million that matures in June 2023. The objective of the interest rate swap is to reduce the Company's exposure to interest rate risk for a portion of its
variable-rate interest payments on its borrowings under the 2018 Revolver. Under the terms of the swap agreement, the variable LIBOR-based component
of interest payments are converted to a fixed rate

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EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

of 2.81%. The interest rate swap is designated as a cash flow hedge, as the changes in the future cash flows of the swap are expected to offset changes in
expected future interest payments on the related variable-rate debt, in accordance with ASC 815, Derivatives and Hedging. There were no
interest rate swaps outstanding as of December 26, 2018.

The changes in the fair value of the interest rate swap are not included in earnings, but are included in other comprehensive income (“OCI”). These changes
in fair value are subsequently reclassified into net earnings as a component of interest expense as the hedged interest payments are made on the
variable rate borrowings.

For the year ended December 25, 2019, the swap was a highly effective cash flow hedge.

As of December 25, 2019, the estimated net gain included in AOCI related to the Company's cash flow hedge that will be reclassified into earnings in the
next 12 months is $0.3 million, based on current LIBOR interest rates.

The following table shows the financial statement line item and amount of the Company's cash flow hedge accounting on the consolidated balance sheet (in
thousands):

Other Assets - Interest rate swap

December 25, 2019

Notional

Fair value

$

40,000   $

360

The following table summarizes the effect of the Company's cash flow hedge accounting on the consolidated statements of operations (in thousands):

Interest expense on hedged portion of debt

Interest income on interest rate swap

Interest expense on debt and derivatives, net

December 25, 2019

December 26, 2018

$

$

461   $

(84)  

377   $

—

—

—

The following table summarizes the effect of the Company's cash flow hedge accounting on AOCI for the years ended December 25, 2019 and
December 26, 2018 (in thousands):

Gain Recognized in OCI

(Gain) Reclassified from AOCI into
Interest expense

December 25,
2019

December 26,
2018

December 25,
2019

December 26,
2018

$

430  

—   $

(84)  

—

Interest rate swap

See Note 2 for the fair value of the Company's derivative asset.

7. OTHER ACCRUED EXPENSES AND CURRENT LIABILITIES

Other accrued expenses and current liabilities consist of the following (in thousands):

82

 
 
 
 
 
 
 
 
 
 
 
Accrued sales and property taxes

Accrued legal settlements and professional fees

Gift card liability

Deferred franchise and development fees
Other (1)
Total other accrued expenses and current liabilities

$

$

December 25, 2019

  December 26, 2018
5,016

4,665   $

16,901  

3,006  

705  

3,320  

28,597   $

38,639

2,512

369

5,228

51,764

(1) The Company previously included the short-term portion deferred rent, tenant improvement allowance and lease escalation liabilities within “Other accrued expenses and current liabilities.” Upon its adoption of Topic
842, these balances were netted with the ROU Asset for the respective operating lease. See “Change in accounting policies" in Note 2 and Note 5 for further details of the Company’s adoption of Topic 842. 

8. OTHER NONCURRENT LIABILITIES

Other noncurrent liabilities consist of the following (in thousands):

Deferred rent (1)

Deferred franchise and development fees
Other (2)
Total other noncurrent liabilities

$

$

December 25, 2019

  December 26, 2018
10,660

—   $

5,612  

67  

5,679   $

5,224

4,140

20,024

(1) In accordance with the Company’s adoption of Topic 842 “Leases” all deferred rent balances are now included with in the Company’s ROU Asset. Refer to “Changes in accounting policies” in Note 2 and Note 5 for
further details of the Company’s adoption of Topic 842. 

(2) The Company previously included the non-current portion tenant improvement allowance and lease escalation liabilities within “Other noncurrent liabilities.” Upon its adoption of Topic 842, these balances were netted
with the ROU Asset for the respective operating lease. See “Changes in accounting policies” in Note 2 and Note 5 for further details of the Company’s adoption of Topic 842. 

9. INCOME TAXES

The provision (benefit) for income taxes is based on the following components (in thousands):

For the Years Ended
Current income taxes:

Federal

State

Total current

Deferred income taxes:

Federal

State

Total deferred

Adjustment to deferred taxes for tax rate change

Tax provision (benefit) for income taxes

December 25, 2019

  December 26, 2018

  December 27, 2017

$

—   $

104  

104  

5,991  

3,587  

9,578  

—  

—   $

220  

220  

(3,526)  

98  

(3,428)  

—  

$

9,682   $

(3,208)   $

—

250

250

1,495

192

1,687

(1,440)

497

On December 22, 2017 the U.S. government enacted the Tax Cuts and Jobs Act (the "Tax Act"). The Tax Act reduces the corporate tax rate to from 35% to
21%, effective for tax years beginning January 1, 2018. The Company is subject to the provisions of ASC 740, Income Taxes, which requires that the effect
on deferred tax assets and liabilities of a change in tax rates be recognized in the period the tax rate change was enacted. The enacted reduction in the
corporate federal income tax rate resulted in a re-measurement of the Company’s net deferred tax assets and liabilities with a one-time, non-cash increase to
income tax benefit. Consequently, we recorded a decrease related to deferred tax assets and deferred tax liabilities of $12.1

83

 
 
 
 
 
 
 
 
 
 
 
 
EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

million and $13.5 million, respectively, with a net benefit to deferred income tax expense of $1.4 million for the year ended December 27, 2017. In
addition, under the new tax law, the corporate alternative minimum tax (“AMT”) is repealed effective for tax years beginning January 1, 2018. For tax
years beginning in 2018, 2019 and 2020, to the extent AMT credit carryovers exceed regular tax liability, 50% of the excess of AMT credit carryovers
would be refundable. Any remaining AMT credits would be fully refundable in 2021.

The provision for income taxes differs from the amount computed by applying the federal income tax rate of 21.0% for both fiscal 2019 and 2018 and
35.0% for fiscal 2017 as follows:

For the Years Ended
Statutory federal income tax rate applied to
   earnings before income taxes and extraordinary items

State tax benefit (net of federal benefit)

Change in valuation allowance

TRA expense

Revaluation of deferred taxes

WOTC Credit

Stock option exercises

Other

Total

December 25, 2019

December 26, 2018

December 27, 2017

21.0 %  

21.0 %  

35.0 %

6.0

2.4

—  

—  

(0.8)

(1.0)

0.3

5.0

(6.9)

1.3

—  

3.3

2.1

0.5

0.6

10.9

(21.4)

(15.8)

(2.5)

—

(1.3)

27.9 %  

26.3 %  

5.5 %

Deferred income tax assets and liabilities are recorded for differences between the financial statement and tax basis of the assets and liabilities that will
result in taxable or deductible amounts in the future based on enacted laws and rates applicable to the periods in which the differences are expected to affect
taxable income. Valuation allowances are established when necessary to reduce deferred tax assets to the amount expected to be realized.

The Company has evaluated the available evidence supporting the realization of its gross deferred tax assets. After evaluating all of the positive and
negative evidence, including the Company’s continued income from operations, the Company concluded that it is more likely than not that its deferred tax
assets will be realized. In fiscal 2018 and 2017, the Company recorded a valuation allowance of approximately $5.1 million and $4.3 million, respectively,
against its deferred tax asset resulting from certain tax credits that may not be realizable prior to the time the credits expire. In fiscal 2019, the Company
recorded an additional $0.9 million to the valuation allowance. As of December 25, 2019, the total valuation allowance was $6.0 million.

On July 30, 2014, the Company entered into the TRA. The TRA calls for the Company to pay its pre-IPO stockholders 85% of the cash savings that the
Company realizes in its taxes as a result of utilizing its NOLs and other tax attributes attributable to preceding periods. The TRA charge expense (benefit)
is a permanent add-back to the Company’s taxable income. TRA resulted in approximately $0.1 million of expense in fiscal 2019 as a result of changes to
future forecasted results, $0.8 million of benefit in fiscal 2018 as a result of changes to future forecasted results and timing of deductibility of certain
temporary differences including the current year settlement accrual and $5.6 million benefit in fiscal 2017 as a result of reduction in the federal corporate
income tax rate related to tax reform. In fiscal 2019, we paid $5.8 million to our pre-IPO stockholders under the TRA.

As of December 25, 2019 and December 26, 2018, the deferred tax assets related to California Enterprise Zone credits, net of valuation allowances are $3.3
million and $4.4 million, respectively.

84

 
 
 
 
 
 
 
 
 
 
 
 
 
EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

The Company’s deferred tax assets and liabilities as of December 25, 2019 and December 26, 2018 are summarized below. The balances reflect the
revaluation for the reduction in the Federal corporate rate to 21.0%.

Deferred assets:

Capital leases

Accrued vacation

Accrued legal

Deferred rent

Accrued workers’ compensation

Enterprise zone and other credits

Net operating losses

Fixed assets

ROU assets

Other

Total deferred tax assets

Valuation allowance

Net deferred tax assets

Deferred liabilities:

Goodwill

Trademark

Prepaid expense

ROU liabilities

Other

Deferred tax liabilities

Net deferred tax asset

December 25, 2019

  December 26, 2018

$

31   $

454  

4,434  

—  

1,090  

10,442  

1,814  

2,955  

57,931  

4,698  

83,849  

(5,993)  

77,856  

(6,060)  

(16,745)  

(791)  

(52,056)  

(167)  

(75,819)  

$

2,037   $

53

456

10,343

3,788

1,660

13,001

6,260

3,374

—

5,239

44,174

(5,149)

39,025

(6,229)

(17,654)

(528)

—

(2,905)

(27,316)

11,709

The net deferred tax asset amounts above as of December 25, 2019 and December 26, 2018 have been classified in the accompanying consolidated balance
sheets as noncurrent assets.

As of December 25, 2019, the Company has federal and state NOL carryforwards of approximately $8.6 million and less than $0.1 million, respectively,
which expire beginning in 2032 and 2027, respectively.  The Company also has state enterprise zone credits of approximately $10.6 million, which expire
in 2023, and federal Work Opportunity Credits of approximately $1.7 million, which will expire in 2038. The utilization of NOL carryforwards may be
subject to limitation under section 382 of the Internal Revenue Code of 1986 (the “Code”) and similar state law provisions.    

As of December 25, 2019, December 26, 2018, and December 27, 2017, the Company had no accrual for unrecognized tax benefits.  Consequently, no
interest or penalties have been accrued by the Company. The Company believes that no significant changes to the amount of unrecognized tax benefits will
occur within the next twelve months. The Company is subject to taxation in the United States and in various state jurisdictions.

The Company is no longer subject to U.S. examination for years before 2015 by the federal taxing authority, and for years before 2014 by state taxing
authorities.  The Company is currently under IRS examination for tax year ending December 28, 2016 and December 27, 2017. As of December 25, 2019,
no proposed adjustments were issued by the IRS. During the first quarter of 2020, the Company has had new discussions with the IRS regarding a potential
timing difference adjustment that would not result in a significant impact to the financial statements, if agreed to by the Company.

85

 
 
 
 
 
 
 
10. EMPLOYEE BENEFIT PLANS

The Company sponsors a defined contribution employee benefit plan that permits its employees, subject to certain eligibility requirements, to contribute up
to 25% of their qualified compensation to the plan. The Company matches 100% of the employees’ contributions of the first 3% of the employees’ annual
qualified compensation, and 50% of the employees’ contributions of the next 2% of the employees’ annual qualified compensation. The Company’s
matching contribution immediately fully vests. The Company’s contributions to the plan were $0.8 million for both years ended December 25, 2019
and December 26, 2018 and $0.7 million for the year ended December 27, 2017.

11. STOCK-BASED COMPENSATION

Stock Options

At December 25, 2019, options to purchase 2,077,570 shares of common stock of the Company were outstanding, including 1,518,145 vested and 559,425
unvested. Unvested options vest over time, or upon our achieving annual financial goals. However, the compensation committee of the board of directors,
as administrator of the Company’s 2018 Omnibus Equity Incentive Plan, has the power to accelerate the vesting schedule of stock-based compensation,
and, generally, in the event of an employee termination in connection with a change in control of the Company, any unvested portion of an award under the
plan shall become fully vested. At December 25, 2019, 1,159,366 premium options, options granted above the stock price at date of grant, remained
outstanding. In fiscal 2019 and 2018, the Company granted 323,900 and 311,272 options, respectively, with an exercise price equal to the fair market value
of the common stock on the date of grant. The options granted in fiscal 2019 and 2018 had a four-year vesting period. On November 15, 2016, the board of
directors approved the modification of the remaining performance-based stock options granted in 2014 and 2013 to vest based solely on service conditions.
As a result, 17,378 performance-based stock options that would not have vested based on the 2017 performance target vested at the end of fiscal 2017,
subject to continued employment of the option holder and the other terms and conditions of the 2014 Stock Option Plan. As of December 25, 2019, there
were no remaining performance-based stock options and 2,077,570 time based stock options outstanding. Stock options generally expire 10 years from the
date of grant. Changes in stock options for the years ended December 25, 2019 and December 26, 2018, are as follows:

Outstanding - December 27, 2017

Grants

Exercised

Forfeited, cancelled or expired

Outstanding - December 26, 2018

Grants

Exercised

Forfeited, cancelled or expired

Outstanding - December 25, 2019

Vested and expected to vest at December 25, 2019

Exercisable at December 25, 2019

Stock options at December 25, 2019 are summarized as follows:

Range of Exercise Prices
$4.09

$5.84

$9.65 - $13.95

$15.00

$4.09 - $15.00

Number
Outstanding

99,531  

1,159,366  

731,158  

87,515  

  $

2,077,570  

Shares

2,309,103   $

311,272  

(269,549)  

(248,422)  

2,102,404  

323,900  

(234,728)  

(114,006)  

2,077,570   $

2,066,768   $

1,518,145   $

Weighted-Average
Exercise Price

7.65

10.98

6.81

12.46

7.68

11.51

6.18

13.35

8.14

8.12

6.93

Weighted-Average
Remaining
Contractual Life
(in Years)

Weighted-
Average Exercise
Price

Number
Exercisable

Weighted-Average
Exercise Price

4.09  

5.84  

11.51  

15.00  

99,531   $

1,159,366   $

175,097   $

84,151   $

8.14   $

1,518,145   $

4.09

5.84

11.86

15.00

6.93

3.50   $

2.55  

8.54  

4.78  

3.28   $

86

 
 
 
 
 
 
 
 
 
 
 
EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

The intrinsic value of options outstanding and options exercisable, calculated as the difference between the market value as of December 25, 2019 and the
exercise price, is $14.3 million and $12.3 million, respectively. The intrinsic value of options exercised, calculated as the difference between the market
value on the date of exercise and the exercise price, was $2.1 million, $1.5 million and $0.2 million for fiscal years 2019, 2018 and 2017, respectively.

The Company measures and recognizes compensation expense for the estimated fair value of stock options for employees and non-employee directors and
similar awards based on the grant-date fair value of the award. For options that are based on a service requirement, the cost is recognized on a straight-line
basis over the requisite service period, usually the vesting period. For options that were based on performance requirements, costs were recognized over
periods to which the performance criteria related. The Company has authorized 5,652,240 shares of common stock for issuance in connection with stock
awards. As of December 25, 2019, 1,040,703 shares were available for grant. In order to calculate our stock options’ fair values and the associated
compensation costs for share-based awards, the Company utilizes the Black–Scholes option pricing model, and has developed estimates of various inputs
including forfeiture rate, expected term, expected volatility, and risk-free interest rate. The forfeiture rate is based on historical rates and reduces the
compensation expense recognized. The expected term for options granted is derived using the “simplified” method, in accordance with SEC guidance. The
Company calculates the risk-free interest rate using the implied yield for a U.S. Treasury security with constant maturity and a remaining term equal to the
expected term of the Company’s employee stock options. The Company does not anticipate paying any cash dividends for the foreseeable future and
therefore uses an expected dividend yield of zero for option valuation purposes. Expected volatility is estimated using four publicly-traded companies in
our market category. These are selected based on similarities of market capitalization, size, and other financial and operational characteristics. Volatility is
calculated by taking the historical daily closing equity prices of our peer companies, prior to the grant date, over a period equal to the expected term.

The weighted-average estimated fair value of employee stock options granted in fiscal 2019 and 2018 was $3.85 per share and $3.78 per share,
respectively, using the Black–Scholes model with the following weighted-average assumptions used to value the option grants:

Expected volatility

Risk-free interest rate

Expected term (years)

Expected dividends

December 25, 2019

December 26, 2018

28.7%  

2.3%  

6.25

—  

28.4%

2.9%

6.25

—

During the years ended December 25, 2019, December 26, 2018 and December 27, 2017, the Company recognized stock option compensation expense of
$0.5 million, $1.1 million and $0.6 million, respectively. These expenses were included in general and administrative expenses consistent with the salary
expense for the related optionees in the accompanying consolidated statements of operations. In connection with the retirement of our former President and
Chief Executive Officer ("CEO") during fiscal 2018, the Company modified previously granted equity awards to accelerate the vesting of 33,545 awards,
which would have otherwise vested in May 2018, and extended the exercisability of all vested and outstanding options until the expiration of the original
term of such awards. As a result, the Company incurred incremental stock-based compensation expense of $0.8 million for the year ended December 26,
2018.

As of December 25, 2019, we had total unrecognized compensation expense of $1.8 million related to unvested stock options, which the Company expects
to recognize over a weighted average period of 2.95 years.

The above assumptions generally require significant judgment. If in the future we determine that another method is more reasonable, or if another method
for calculating these input assumptions is prescribed by authoritative guidance, and, therefore, should be used to estimate volatility or expected term, the
fair value calculated for our stock options could change significantly. Higher volatility and longer expected lives result in an increase to stock-based
compensation expense determined at the date of grant. Stock-based compensation expense affects our general and administrative expense.

We estimate our forfeiture rate based on an analysis of our actual forfeitures and will continue to evaluate the appropriateness of the forfeiture rate based on
actual forfeiture experience, analysis of employee turnover behavior, and other factors. Changes in the estimated forfeiture rate can have a significant effect
on reported stock-based compensation expense, as the cumulative effect of adjusting the rate for all expense amortization is recognized in the period the
forfeiture estimate is changed. If a revised forfeiture rate is higher than the previously-estimated forfeiture rate, an adjustment is made that will result in a
decrease to the stock-based compensation expense recognized in the financial statements. If a revised forfeiture rate is lower than the previously-estimated
forfeiture rate, an adjustment is made that will result in an increase to the stock-based compensation expense recognized in the financial statements. The
effect of forfeiture adjustments was insignificant in fiscal 2019, 2018 and

87

 
 
 
EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

2017. We will continue to use significant judgment in evaluating the expected term, volatility, and forfeiture rate related to our stock-based compensation.

Restricted Shares

In fiscal 2019 and 2018, 299,052 and 323,764 restricted share awards were granted, respectively, at the fair market value on the date of grant. These grants
vest based on continued service over three years for directors and four years for employees. Additionally, in fiscal 2018, 72,116 performance share units
were granted, which vest over a minimum of one year and a maximum of five years. Performance share units are granted at fair market value on the date of
grant and are subject to service-based and market-based vesting conditions. A portion of the performance share units satisfied their market-based vesting
conditions during the fourth quarter of fiscal 2018 and vested upon the satisfaction of their service condition in the second quarter of fiscal 2019. The
Company bases the amount of unearned compensation recorded on the fair market value of the awards on the date of issuance. In fiscal 2019, 2018, and
2017 the Company recognized share-based compensation expense of $2.0 million, $1.0 million, and $0.5 million, respectively. This expense was included
in general and administrative expenses in the accompanying consolidated statements of operations. As of December 25, 2019, there was total unrecognized
compensation expense of $5.4 million related to unvested restricted share awards, which the Company expects to recognize over a weighted-average period
of 2.79 years.

Changes in restricted shares for the years ended December 25, 2019 and December 26, 2018, are as follows:

Unvested shares at December 27, 2017

Granted

Released

Forfeited, cancelled, or expired

Unvested shares at December 26, 2018

Granted

Released

Forfeited, cancelled, or expired

Unvested shares at December 25, 2019

Shares

Weighted-Average
Fair Value

196,642   $

395,880   $

(45,991)   $

(55,831)   $

490,700   $

299,052   $

(147,862)   $

(53,882)   $

588,008   $

13.70

10.22

13.86

13.42

10.91

11.62

10.73

11.81

11.23

88

 
 
EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

12. EARNINGS PER SHARE

Basic EPS is calculated using the weighted-average number of shares of common stock outstanding during the years ended December 25,
2019, December 26, 2018, and December 27, 2017. Diluted EPS is calculated using the weighted-average number of shares of common stock outstanding
and potentially dilutive during the period, using the treasury stock method.

Below are basic and diluted EPS data for the periods indicated, which are in thousands except for per share data.

For the Years Ended
Numerator:

Net income (loss)

Denominator:

Weighted-average shares outstanding—Basic

Weighted-average shares outstanding—Diluted

Net income (loss) per share—Basic

Net income (loss) per share—Diluted

Anti-dilutive securities not considered in diluted EPS
   calculation

Below is a reconciliation of basic and diluted share counts.

For the Years Ended
Weighted-average shares outstanding—Basic

Dilutive effect of stock options and restricted shares

Weighted-average shares outstanding—Diluted

13. COMMITMENTS AND CONTINGENCIES

Legal Matters

December 25, 2019

  December 26, 2018

  December 27, 2017

$

$

$

24,900   $

(8,994)   $

8,619

36,739,209  
37,441,503  

38,574,553  
38,574,553  

38,453,347

39,086,676

0.68   $
0.67   $

(0.23)   $
(0.23)   $

0.22

0.22

526,295  

2,593,104  

747,985

December 25, 2019

  December 26, 2018

36,739,209  

702,294  

38,574,553  

  December 27, 2017
38,453,347

—  

633,329

37,441,503  

38,574,553  

39,086,676

On or about February 24, 2014, a former employee filed a class action in the Superior Court of the State of California, County of Orange, under the caption
Elliott Olvera, et al v. El Pollo Loco, Inc., et al (Case No. 30-2014-00707367-CU-OE-CXC) (the "Olvera Action") on behalf of all putative class members
(all hourly employees from 2010 to the present) alleging certain violations of California labor laws, including failure to pay overtime compensation, failure
to provide meal periods and rest breaks, and failure to provide itemized wage statements. The putative lead plaintiff’s requested remedies include
compensatory and punitive damages, injunctive relief, disgorgement of profits, and reasonable attorneys’ fees and costs. No specific amount of damages
sought was specified in the complaint. The court recently certified two classes of plaintiffs - one class encompasses restaurant employees who were not
provided proper rest breaks because they were not allowed to leave the premises during their breaks and the other class encompasses restaurant employees
who were required to wait at the restaurant after they finished working for the night until the manager set the alarm for safety purposes. The parties reached
a settlement in principle on January 24, 2019 of all claims brought on behalf of the 32,000+ putative class members in the Olvera Action, as well as all
claims for failure to pay overtime compensation, failure to provide meal periods and rest breaks, and failure to provide itemized wage statements brought in
the class actions captioned Martha Perez v. El Pollo Loco, Inc. (Los Angeles Superior Court Case No. BC624001), Maria Vega, et al. v. El Pollo Loco, Inc.
(Los Angeles Superior Court Case No. BC649719), and Gonzalez v. El Pollo Loco, Inc. (Los Angeles Superior Court Case No. BC712867).   The
settlement reached in principle in the Olvera, Perez, Vega, and Gonzalez actions resolves all potential claims from April 12, 2010 through April 1, 2019 El
Pollo Loco restaurant employees may have against El Pollo Loco for failure to pay for all compensation owed, failure to pay overtime compensation,
failure to provide meal periods and rest breaks, and failure to provide itemized wage statements, among other wage and hour related claims. A $16.3
million accrual of an expected settlement amount related to this matter was recorded as of December 26, 2018, and the court formally approved the
settlement on January 31, 2020. Purported class actions alleging wage and hour violations are commonly filed against California employers. The Company
fully expects to have to defend against similar lawsuits in the future.

Daniel Turocy, et al. v. El Pollo Loco Holdings, Inc., et al. (Case No. 8:15-cv-01343) was filed in the United States District Court for the Central District of
California on August 24, 2015, and Ron Huston, et al. v. El Pollo Loco Holdings, Inc., et al.

89

 
 
 
 
 
 
 
 
 
 
EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

(Case No. 8:15-cv-01710) was filed in the United States District Court for the Central District of California on October 22, 2015. The two lawsuits have
been consolidated, with co-lead plaintiffs and class counsel.  A consolidated complaint was filed on January 29, 2016, on behalf of co-lead plaintiffs and
others similarly situated, alleging violations of federal securities laws in connection with Holdings common stock purchased or otherwise acquired and the
purchase of call options or the sale of put options, between May 1, 2015 and August 13, 2015 (the “Class Period”). The named defendants are Holdings;
Stephen J. Sather, Laurance Roberts, and Edward J. Valle (collectively, the “Individual Defendants”); and Trimaran Pollo Partners, LLC, Trimaran Capital
Partners, and Freeman Spogli & Co. (collectively, the “Controlling Shareholder Defendants”). Among other things, Plaintiffs allege that, in 2014 and early
2015, Holdings suffered losses due to rising labor costs in California and, in an attempt to mitigate the effects of such rising costs, removed a $5 value
option from the Company's menu, which resulted in a decrease in traffic from value-conscious consumers. Plaintiffs further allege that during the Class
Period, Holdings and the Individual Defendants made a series of materially false and misleading statements that concealed the effect that these factors were
having on store sales growth, resulting in Holdings stock continuing to be traded at artificially inflated prices. As a result, Plaintiffs and other members of
the putative class allegedly suffered damages in connection with their purchase of Holdings’ stock during the Class Period. In addition, Plaintiffs allege that
the Individual Defendants and Controlling Shareholder Defendants had direct involvement in, and responsibility over, the operations of Holdings, and are
presumed to have had, among other things, the power to control or influence the transactions giving rise to the alleged securities law violations. In both
cases, Plaintiffs seek an unspecified amount of damages, as well as costs and expenses (including attorneys’ fees).

On July 25, 2016, the Court issued an order granting, without prejudice, Defendants’ Motion to Dismiss plaintiff’s complaint for failure to state a claim.
Plaintiffs were granted leave to amend their complaint, and filed an amended complaint on August 22, 2016. Defendants moved to dismiss the amended
complaint, and on March 20, 2017, the Court dismissed the amended complaint and granted Plaintiffs leave to file another amended complaint.  Plaintiffs
filed another amended complaint on April 17, 2017. Defendants filed a motion to dismiss the amended complaint on or about May 17, 2017. The Court
denied Defendants' motion to dismiss the third amended complaint on August 4, 2017. On December 8, 2017, Plaintiffs filed a motion for class
certification, and on July 3, 2018, the Court granted Plaintiffs’ motion and certified a class as to all of Plaintiffs’ claims. Defendants filed a petition for
appellate review of a portion of the Court's July 3, 2018 class certification order.  On October 19, 2018 the Ninth Circuit Court of Appeals denied the
petition.

On January 23, 2019, the parties filed a Notice of Settlement and Joint Request for Order to Stay Proceedings, stating the parties have reached an
agreement in principle to settle the claims and allegations in the action and are negotiating the terms of a Stipulation of Settlement.  On January 24, 2019,
the Court ordered that all proceedings in the action be stayed until April 3, 2019, on or before which the parties are to file a Stipulation of Settlement and a
motion for preliminary approval of the settlement.  Defendants maintain that the Plaintiffs' claims are without merit, and have entered into the settlement to
eliminate the uncertainties, burden and expense of further protracted litigation. A $20.0 million accrual of an expected settlement amount related to this
matter was recorded as of December 26, 2018 and all settlement payments were made during the year ended December 25, 2019.

On or about November 5, 2015, a purported Holdings shareholder filed a derivative complaint on behalf of Holdings in the Court of Chancery of the State
of Delaware against certain Holdings officers, directors and Trimaran Pollo Partners, L.L.C., under the caption Armen Galustyan v. Sather, et al. (Case No.
11676-VCL). The derivative complaint alleges that these defendants breached their fiduciary duties to Holdings and were unjustly enriched when they sold
shares of Holdings at artificially inflated prices due to alleged misrepresentations and omissions regarding EPL’s comparable store sales in the second
quarter of 2015. The Holdings shareholder’s requested remedies include an award of compensatory damages to Holdings, as well as a court order to
improve corporate governance by putting forward for stockholder vote certain resolutions for amendments to Holdings’ Bylaws or Certificate of
Incorporation. The parties have stipulated to, which the court has ordered, a stay of these proceedings pending the outcome of Turocy v. El Pollo Loco
Holdings, Inc., discussed above. A second purported Holdings shareholder filed a derivative complaint on or about September 23, 2016, under the caption
Diep v. Sather, CA 12760-VCL in the Delaware Court of Chancery. The Diep action is also purportedly brought on behalf of Holdings, names the same
defendants and asserts substantially the same claims on substantially the same alleged facts as does Galustyan. Defendants moved to stay or dismiss the
Diep action.

On March 17, 2017, the Delaware court granted in part, and denied in part, the motion to stay the Diep action.  The court denied defendants' motion to
dismiss the complaint for failure to state a claim. On January 17, 2018, the court entered an order granting the parties’ stipulation staying all proceedings in
the Diep action for five months or until the completion of an investigation of the allegations in the action by a special litigation committee of the Holdings
board of directors (the "SLC"). On February 13, 2019, after concluding its investigation, the SLC filed a motion to dismiss the Diep action.  The SLC filed
its investigative report under seal as an exhibit to the motion to dismiss. Discovery related to the SLC's motion is ongoing.

90

EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

Janice P. Handlers-Bryman and Michael D. Bryman v. El Pollo Loco, Inc., Los Angeles Superior Court (Case No. MC026045) (the “Lancaster Lawsuit”)
was filed on February 9, 2016.   Existing El Pollo Loco franchisees, Janice P. Handlers-Bryman and Michael D. Bryman, as individuals and in their
capacities as trustees of the Handlers Bryman Trust (collectively, “Plaintiffs”), filed suit against us alleging, among other things, that we “imposed
unreasonable time limitations” on their development of additional restaurant locations in Lancaster, California, and that we thereafter developed  company-
operated El Pollo Loco restaurants in the “market area” of Plaintiffs’ existing El Pollo Loco restaurant in Lancaster. Plaintiffs asserted claims against us for,
among other things, (i) breach of the implied covenant of good faith and fair dealing, (ii) intentional interference with prospective business, and (iii) unfair
business practices. In addition to an unspecified amount of damages and costs of the lawsuit, Plaintiffs sought reformation of the contract, declaratory
relief, disgorgement of alleged revenues and profits, injunctive relief, and a judicial mandate requiring us to either transfer the company-operated locations
to Plaintiffs or to continuously disgorge to Plaintiffs the unjust enrichment allegedly obtained by us through the operation of the company-operated
restaurants in Lancaster. We denied Plaintiffs’ allegations as the franchise agreement did not grant Plaintiffs any exclusive territorial rights and, instead,
expressly reserved for us the right to open and operate - and the right to grant others the right to open and operate - El Pollo Loco restaurants “in the
immediate vicinity of or adjacent to” Plaintiffs’ restaurant in Lancaster. On April 24, 2017, four days before the commencement of trial, Plaintiffs filed a
voluntary dismissal, without prejudice, of the Lancaster Lawsuit without any payment or other concession by us. The corresponding dismissal was entered
by the court on April 25, 2017. On May 22, 2017, Plaintiffs filed a motion for relief from the dismissal which was granted by the court on June 29, 2017.
 The trial in the case was bifurcated between the liability and damages phases.  The liability phase commenced on November 16, 2017.  The only cause of
action that the court allowed to go to the jury was the cause of action for breach of the covenant of good faith and fair dealing.  The court elected not to
present the cause of action for intentional interference with prospective business to the jury.  (The causes of action for reformation due to mistake and
unconscionability, unfair business practices under California Business & Professions Code §17200 et seq., and declaratory relief were not presented to the
jury as these types of equitable claims are to be decided by the court as a matter of law.) On December 11, 2017, the jury returned a verdict in favor of
Plaintiffs finding that the Company breached the implied covenant of good faith and fair dealing by (1) constructing the two new company-operated El
Pollo Loco restaurants in Lancaster, and (2) not offering the two new company-operated El Pollo Loco restaurants in Lancaster to Plaintiffs. Because the
trial was bifurcated, the December 11, 2017 verdict did not include a determination of damages.  

The damages phase of the trial commenced on April 20, 2018. On May 1, 2018, the jury returned a verdict on damages in favor of Plaintiffs in the
following amounts: (1) $4,356,600 in “impact damages” arising out of our construction of the two new company-operated El Pollo Loco restaurants in
Lancaster, and (2) $4,481,206 in “lost opportunity damages” arising out of our failure to offer the two new company-operated El Pollo Loco restaurants in
Lancaster to Plaintiffs. On August 1, 2018, the court issued a final judgment and decision on the unfair business practices claim under California Business
& Professions Code § 17200 et seq. As part of the final judgment, the court found El Pollo Loco liable and issued injunctive relief requiring El Pollo Loco
to revise its franchise disclosure document and franchise agreement. The court also awarded Plaintiffs restitution of
$4,356,600 for “impact damages” arising out of our construction of the two new company-operated El Pollo Loco restaurants in Lancaster. The court,
reversing its previous position, held that these damages could be awarded in addition to the "lost opportunity damages" awarded by the jury. Thus, the court
entered a total monetary judgment of $8,837,806. There was no ruling on the causes of action for reformation due to mistake, and declaratory relief, and on
January 27, 2020, the court entered an amended judgment dismissing these claims. The trial court subsequently awarded the Plaintiffs $249,728 in costs
and $1,391,703 in attorney fees. Post judgment interest is running at 10% simple interest per year on the total amount of the monetary judgment, costs, and
attorney’ fees.

On August 27, 2018, the Company filed a notice of appeal as to the entire judgment. The appeal on the merits is currently pending. Briefing on the merits
has not yet occurred in the appellate court. The record was delivered by the trial court clerk to the court of appeal on August 20, 2019. The Company's
opening brief is due to be filed in the Court of Appeals by April 1, 2020. Based on the assessment by management of the numerous legal arguments that
can be raised on appeal, together with independent assessments from our legal trial and appellate counsel, the Company believes that a loss is currently not
probable or estimable under ASC 450, "Contingencies", and as of December 25, 2019 no accrual has been made with regard to the verdict.

The Company is also involved in various other claims and legal actions that arise in the ordinary course of business. The Company does not believe that the
ultimate resolution of these other actions will have a material adverse effect on its financial position, results of operations, liquidity, or capital resources. A
significant increase in the number of claims, or an increase in amounts owing under successful claims, could materially and adversely affect its business,
consolidated financial condition, results of operations, and cash flows.

91

EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

Purchase Commitments

The Company has long-term beverage supply agreements with certain major beverage vendors. Pursuant to the terms of these arrangements, marketing
rebates are provided to the Company and its franchisees from the beverage vendors based upon the dollar volume of purchases for system-wide restaurants
which will vary according to their demand for beverage syrup and fluctuations in the market rates for beverage syrup. These contracts have terms extending
through the end of 2024.

At December 25, 2019, the Company’s total estimated commitment to purchase chicken was $25.2 million.

Contingent Lease Obligations

As a result of assigning the Company’s interest in obligations under real estate leases in connection with the sale of company-operated restaurants to some
of the Company’s franchisees, the Company is contingently liable on five lease agreements. These leases have various terms, the latest of which expires in
2036. As of December 25, 2019, the potential amount of undiscounted payments the Company could be required to make in the event of non-payment by
the primary lessee was $2.0 million. The present value of these potential payments discounted at the Company’s estimated pre-tax cost of debt at
December 25, 2019 was $1.7 million. The Company’s franchisees are primarily liable on the leases. The Company has cross-default provisions with these
franchisees that would put them in default of their franchise agreements in the event of non-payment under the leases. The Company believes that these
cross-default provisions reduce the risk that payments will be required to be made under these leases. Accordingly, no liability has been recorded in the
Company’s consolidated financial statements related to these contingent liabilities.

Employment Agreements

As of December 25, 2019, the Company had employment agreements with four of the officers of the Company. These agreements provide for minimum
salary levels, possible annual adjustments for cost-of-living changes, and incentive bonuses that are payable under certain business conditions.

Indemnification Agreements

The Company has entered into indemnification agreements with each of its current directors and officers. These agreements require the Company to
indemnify these individuals to the fullest extent permitted under Delaware law against liabilities that may arise by reason of their service to the Company
and to advance expenses incurred as a result of any proceeding against them as to which they could be indemnified. The Company also intends to enter into
indemnification agreements with future directors and officers.

14. RELATED PARTY TRANSACTIONS

LLC owns approximately 47.7% of the Company’s outstanding common stock. This large position means that LLC and its majority owners—predecessors
and affiliates of, and certain funds managed by, Trimaran Capital Partners and Freeman Spogli & Co. (collectively, “Trimaran” and “Freeman Spogli,”
respectively)—possess significant influence when stockholders vote on matters such as election of directors, mergers, consolidations and acquisitions, the
sale of all or substantially all of the Company’s assets, decisions affecting the Company’s capital structure, amendments to the Company’s certificate of
incorporation or by-laws, and the Company’s winding up and dissolution. So long as LLC maintains at least 40% ownership, (i) any member of the board
of directors may be removed at any time without cause by affirmative vote of a majority of the Company’s common stock, and (ii) stockholders
representing 40% or greater ownership may cause special stockholder meetings to be called.

15. REVENUE FROM CONTRACTS WITH CUSTOMERS

Adoption of Topic 606, "Revenue from Contracts with Customers"

On December 28, 2017, the Company adopted Topic 606 using the modified retrospective method applied to those contracts, which were not fully satisfied
as of December 28, 2017. Results for reporting periods beginning after December 28, 2017, are presented under Topic 606, while prior period amounts are
not adjusted and continue to be reported in accordance with our historic accounting under Topic 605.

Revenue Recognition

Nature of products and services

92

The Company has two revenue streams, company-operated restaurant revenue and franchise related revenue. See Note 2 for a description of the revenue
recognition policies.

Franchise and franchise advertising revenue

Franchise revenue consists of franchise royalties, initial franchise fees, license fees due from franchisees, IT support services, and rental income for
subleases to franchisees. Franchise advertising revenue consists of advertising contributions received from franchisees.

Disaggregated revenue

The following table presents our revenues for the years ended December 25, 2019 and December 26, 2018 disaggregated by revenue source and market (in
thousands):

Core Market(1):

Company-operated restaurant revenue

Franchise revenue

Franchise advertising fee revenue

Total core market

Non-Core Market(2):

Company-operated restaurant revenue

Franchise revenue

Franchise advertising fee revenue

Total non-core market

Total revenue

December 25,
2019

  December 26, 2018

$

$

$

$

$

351,624   $

14,918  

11,049  

377,591   $

39,488   $

13,901  

11,350  

64,739   $

442,330   $

340,421

14,144

10,831

365,396

48,414

11,627

10,391

70,432

435,828

(1) Core Market includes markets with existing company-operated restaurants at the time of the Company's Initial Public Offering ("IPO") on July 28, 2014.

(2) Non-Core Market includes markets entered into by the Company subsequent to the IPO date.

The following table presents our revenues disaggregated by geographic market for the years ended December 25, 2019 and December 26, 2018:

Greater Los Angeles area market

Other markets

Total

Contract balances

93

December 25, 2019

December 26, 2018

70.5%  

29.5%  

100%  

69.2%

30.8%

100%

 
 
   
 
   
 
 
The following table provides information about the change in the franchise contract liability balances during the year ended December 25, 2019 and
December 26, 2018 (in thousands):

December 27, 2017

Revenue recognized - beginning balance

Additional contract liability

Revenue recognized - additional contract liability

December 26, 2018

Revenue recognized - beginning balance

Additional contract liability

Revenue recognized - additional contract liability

December 25, 2019

$

$

$

5,759

(396)

365

(135)

5,593

(441)

1,457

(292)

6,317

The Company’s franchise contract liability includes development fees, initial franchise and license fees, franchise renewal fees, lease subsidies and royalty
discounts and is included within other accrued expenses and current liabilities and other noncurrent liabilities within the accompanying consolidated
balance sheets. The Company receives area development fees from franchisees when they execute multi-unit area development agreements. Initial
franchise and license fees, or franchise renewal fees, are received from franchisees upon the execution of, or renewal of, a franchise agreement. Revenue is
recognized from these agreements as the underlying performance obligation is satisfied, which is over the term of the agreement.

For the year ended December 25, 2019, there was an increase to the contract liability balance due to the Company's completion of the sale of four
company-operated restaurants within the San Francisco area to an existing franchisee and seven company-operated restaurants in the Phoenix area to
another existing franchisee. This resulted in an additional contract liability of $0.7 million, relating to allocation of the transaction price to various
performance obligations under the applicable contracts of the sale.

The following table illustrates the estimated revenue to be recognized in the future related to performance obligations that are unsatisfied as of
December 25, 2019:

Franchise revenues (in thousands):

2020

2021

2022

2023

2024

Thereafter

Total

Contract Costs

$

$

705

515

434

420

406

3,837

6,317

The Company does not currently incur costs to obtain or fulfill a contract that would be considered contract assets under Topic 606.

16. QUARTERLY RESULTS OF OPERATIONS (UNAUDITED)

The following table sets forth a summary of our unaudited quarterly operating results for each of the last eight quarters in the period ended December 25,
2019. We have derived this data from our unaudited consolidated interim financial statements that, in our opinion, have been prepared on substantially the
same basis as the audited financial statements contained elsewhere in this report and include all normal recurring adjustments necessary for a fair
presentation of the financial information for the periods presented. These unaudited quarterly results should be read in conjunction with our financial
statements and notes thereto included elsewhere in this report. The operating results in any quarter are not necessarily indicative of the results that may be
expected for any future period.

94

 
EL POLLO LOCO HOLDINGS, INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (continued)

QUARTERLY FINANCIAL INFORMATION (UNAUDITED) 

(Dollar amounts in thousands,
except
share data)
Selected Financial Data

Total revenue ($)

Income (loss) from operations
($)
Provision (benefit) for income
taxes ($)
Net income (loss) ($)

Per Share Data (2):

Net income (loss) per share:

Basic

Diluted

Weighted average shares used
in computing net income per
share:
Basic

Diluted

Selected Operating Data

Number of restaurants (at
period end)
Company-operated

Franchised

System-wide

Average unit volume (AUV)
   (company-operated) (1)

Comparable restaurant sales
growth (%)
Company-operated

Franchised

System-wide

2019

2018

December

September

June

March

December

September

June

March

107,546

112,067  

113,740  

108,977  

106,261  

112,178  

111,633  

105,756

5,336

728

3,498

0.10

0.10

10,118  

2,940  
6,402  

20,580  

5,665  
14,087  

2,292  

349  
913  

(30,990)

(4)

(8,410)  

(23,410)

(4)

0.18  
0.18  

0.37  
0.37  

0.02  
0.02  

-0.60  
-0.60  

9,492  

2,388  
6,835  

0.18  
0.17  

7,589  

865  
5,052  

0.13  
0.13  

4,448

1,949

2,529

0.07

0.06

34,503,722

35,242,122

35,859,502  
36,397,368  

37,939,912  
38,580,722  

38,633,702  
39,496,436  

38,751,522  

38,751,522

(3)

38,602,658  
39,205,090  

38,482,074  
39,043,434  

38,465,208

38,987,351

195

287

482

1,931

4.3

3.6

3.9

201  
284  
485  

200  
284  
484  

211  
273  
484  

213  
271  
484  

212  
271  
483  

211  
269  
480  

212

268

480

1,978  

1,934  

1,838  

1,785  

1,891  

1,890  

1,791

1.6  
0.6  
1.1  

0.4  
0.9  
0.7  

1.5  
3.2  
2.4  

3.7  
5.1  
4.4  

2.0  
3.0  
2.6  

(1.6)  
(0.3)  
(0.9)  

(2.0)

(0.4)

(1.1)

(1)
(2)

(3)
(4)

AUVs consist of average annualized sales of all company-operated restaurants over the fiscal quarter.
Due to the use of weighted average shares outstanding for each quarter of computing earnings per share, the sum of the quarterly per share
amounts may not equal the per share amount for the year.
Due to a loss for the period, zero incremental shares are included because the effect would be antidilutive.
Loss from operations and net loss includes a $36.3 million legal settlement in the period.

ITEM 9.

CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND FINANCIAL DISCLOSURE

None.

ITEM 9A.

CONTROLS AND PROCEDURES

Disclosure Controls and Procedures

We maintain disclosure controls and procedures (as defined in Rules 13a-15(e) of the Exchange Act) that are designed to ensure that information required
to be disclosed by us in the reports that we file or submit under the Exchange Act is recorded, processed, summarized and reported, within the required
time periods, and that such information is accumulated and communicated to our management, including our Chief Executive Officer and Chief Financial
Officer, as appropriate to allow timely decisions regarding required disclosure.

95

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Our disclosure controls and procedures are based on assumptions about the likelihood of future events, and even effective disclosure controls and
procedures can only provide reasonable assurance of achieving their objectives. Because of their inherent limitations, we cannot guarantee that our
disclosure controls and procedures will succeed in achieving their stated objectives in all cases, that they will be complied with in all cases, or that they will
prevent or detect all misstatements.

Our management has evaluated, with the participation of our Chief Executive Officer and Chief Financial Officer, the effectiveness of our disclosure
controls and procedures, as of the end of the period covered by this report. Based on this evaluation, our Chief Executive Officer and Chief Financial
Officer have concluded that our disclosure controls and procedures were effective at the reasonable assurance level as of December 25, 2019.

Management Report on Internal Control over Financial Reporting

Our management is responsible for establishing and maintaining adequate internal control over financial reporting. As defined in Exchange Act Rule 13a-
15(f), internal control over financial reporting is a process designed by, or under the supervision of, our principal executive officer and principal financial
officer and effected by our Board of Directors, management and other personnel, to provide reasonable assurance regarding the reliability of financial
reporting and the preparation of financial statements for external purposes in accordance with GAAP and includes those policies and procedures that
(i) pertain to the maintenance of records that in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the
Company; (ii) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with
GAAP, and that receipts and expenditures of the Company are being made only in accordance with authorizations of management and directors of the
Company; and (iii) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of the Company’s
assets that could have a material effect on the financial statements. The design of any system of control is based upon certain assumptions about the
likelihood of future events, and there can be no assurance that any design will succeed in achieving its stated objectives under all future events, no matter
how remote, or that the degree of compliance with the policies or procedures may not deteriorate. Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements. Accordingly, even effective internal control over financial reporting can only provide
reasonable assurance of achieving their control objectives. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that
controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Under the supervision and with the participation of our management, including our Chief Executive Officer and Chief Financial Officer, we carried out an
evaluation of the effectiveness of our internal control over financial reporting as of December 25, 2019 based on the criteria in Internal Control —
Integrated Framework ("2013 Framework") issued by the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”). Based on this
evaluation, our management concluded that our internal control over financial reporting was effective as of December 25, 2019 based on the criteria
established in the 2013 Framework.

The effectiveness of our internal control over financial reporting as of December 25, 2019 has been audited by BDO USA, LLP, an independent registered
public accounting firm, as stated in their report included herein.

Changes in Internal Control over Financial Reporting

No changes in our internal control over financial reporting occurred during the thirteen weeks ended December 25, 2019 have materially affected, or are
reasonably likely to materially affect, our internal control over financial reporting.

96

Report of Independent Registered Public Accounting Firm

Shareholders and Board of Directors
El Pollo Loco Holdings, Inc.
Costa Mesa, California

Opinion on Internal Control over Financial Reporting

We have audited El Pollo Loco Holdings, Inc.’s (the “Company”) internal control over financial reporting as of December 25, 2019, based on criteria
established in Internal Control - Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission (the
“COSO criteria”). In our opinion, the Company maintained, in all material respects, effective internal control over financial reporting as of December 25,
2019, based on the COSO criteria.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (“PCAOB”), the consolidated
balance sheets of the Company as of December 25, 2019 and December 26, 2018, the related consolidated statements of operations, comprehensive income
(loss), changes in stockholders’ equity, and cash flows for each of the three years in the period ended December 25, 2019, and the related notes and our
report dated March 6, 2020, expressed an unqualified opinion thereon.

Basis for Opinion

The Company’s management is responsible for maintaining effective internal control over financial reporting and for its assessment of the effectiveness of
internal control over financial reporting, included in the accompanying Item 9A, Management’s Report on Internal Control over Financial Reporting. Our
responsibility is to express an opinion on the Company’s internal control over financial reporting based on our audit. We are a public accounting firm
registered with the PCAOB and are required to be independent with respect to the Company in accordance with U.S. federal securities laws and the
applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit of internal control over financial reporting in accordance with the standards of the PCAOB. Those standards require that we plan
and perform the audit to obtain reasonable assurance about whether effective internal control over financial reporting was maintained in all material
respects. Our audit included obtaining an understanding of internal control over financial reporting, assessing the risk that a material weakness exists, and
testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. Our audit also included performing such other
procedures as we considered necessary in the circumstances. We believe that our audit provides a reasonable basis for our opinion.

Definition and Limitations of Internal Control over Financial Reporting

A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting
and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company’s internal control
over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly
reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit
preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are
being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding
prevention or timely detection of unauthorized acquisition, use, or disposition of the company’s assets that could have a material effect on the financial
statements.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of
effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of
compliance with the policies or procedures may deteriorate.

/s/ BDO USA, LLP

Costa Mesa, California

March 6, 2020

97

98

ITEM 9B.

OTHER INFORMATION

None.

99

PART III

ITEM 10.

DIRECTORS, EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE

Incorporated by reference from our definitive proxy statement to be filed not later than 120 days after the end of our 2019 fiscal year. In addition, our
Board of Directors has adopted a Code of Business Conduct and Ethics that applies to all of our directors, employees and officers, including our principal
executive officer, principal financial officer, principal accounting officer, controller, and any persons performing similar functions. The current version of
the Code of Business Conduct and Ethics is available on our website under the Corporate Governance section at www.elpolloloco.com. To the extent
required by rules adopted by the SEC and The Nasdaq Stock Market LLC, we intend to promptly disclose future amendments to certain provisions of the
Code of Business Conduct and Ethics, or waivers of such provisions granted to executive officers and directors, on our website under the Corporate
Governance section at www.elpolloloco.com.

ITEM 11.

EXECUTIVE COMPENSATION

Incorporated by reference from our definitive proxy statement to be filed not later than 120 days after the end of our 2019 fiscal year.

ITEM 12.

SECURITY OWNERSHIP OF CERTAIN BENEFICIAL OWNERS AND MANAGEMENT AND RELATED STOCKHOLDER
MATTERS

Incorporated by reference from our definitive proxy statement to be filed not later than 120 days after the end of our 2019 fiscal year.

ITEM 13.

CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS, AND DIRECTOR INDEPENDENCE

Incorporated by reference from our definitive proxy statement to be filed not later than 120 days after the end of our 2019 fiscal year.

ITEM 14.

PRINCIPAL ACCOUNTING FEES AND SERVICES

Incorporated by reference from our definitive proxy statement to be filed not later than 120 days after the end of our 2019 fiscal year.

100

ITEM 15.

EXHIBITS, FINANCIAL STATEMENT SCHEDULES

The following documents are filed as a part of this report:

PART IV

(1) Financial Statements: Consolidated financial statements filed as part of this report are listed under Item 8. Financial Statements and Supplementary

Data.

(2) Financial Statement Schedules: None.

(3) Exhibits:

Number
3.1

3.2

4.1

10.1

10.2

10.3

10.4

10.5

  Description

Amended and Restated Certificate of
Incorporation of El Pollo Loco
Holdings, Inc.

Amended and Restated By-Laws of El
Pollo Loco Holdings, Inc.

Description of El Pollo Loco
Holdings, Inc. Capital Stock

Income Tax Receivable Agreement,
dated July 30, 2014, between El Pollo
Loco Holdings, Inc., and Trimaran
Pollo Partners, L.L.C.

Credit Agreement, dated as of
December 11, 2014, among El Pollo
Loco, Inc., as borrower, El Pollo Loco
Holdings, Inc., and EPL Intermediate,
Inc., as guarantors, Bank of America,
N.A., as administrative agent,
swingline lender and letter of credit
issuer, the lenders party thereto, and
the other parties thereto

Franchise Development Agreement
(Exclusive), dated August 20, 2014,
between El Pollo Loco, Inc., as
franchisor, and Anil Yadav and Atour
Eyvazian, collectively, as developer

Consent to and Assignment of
Development Rights (Initial Change of
Entity), dated August 20, 2014,
between El Pollo Loco, Inc., as
franchisor, and (i) Anil Yadav and
Atour Eyvazian, collectively, as
assignor, and (ii) AA Pollo, Inc., as
assignee

Franchise Development Option
Agreement, dated July 11, 2014,
between El Pollo Loco, Inc., and
Trimaran Pollo Partners, L.L.C.

Filed
Herewith

  Form  
10-Q

Incorporated by Reference

Period
Ended
6/25/2014

  Exhibit
3.1

Filing
Date
9/5/2014

SEC File Number

001-36556

10-Q

6/25/2014

3.2

9/5/2014

001-36556

X

10-Q

9/24/2014

10.1

11/7/2014

001-36556

8-K

N/A

10.1

12/16/2014

001-36556

8-K

N/A

10.1

8/22/2014

001-36556

8-K

N/A

10.2

8/22/2014

001-36556

S-1/A

N/A

10.14

7/14/2014

333-197001

101

 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
   
   
   
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
10.6

10.7

10.8

10.9

10.10

10.11

10.12

Stockholders Agreement, dated as of
November 18, 2005, by and among El
Pollo Loco Holdings, Inc. (formerly
Chicken Acquisition Corp.) and the
stockholders listed therein

Amendment No. 1 to Stockholders
Agreement, dated as of April 20,
2006, by and between El Pollo Loco
Holdings, Inc. (formerly Chicken
Acquisition Corp.) and Trimaran Pollo
Partners, L.L.C.

Amendment No. 2 to Stockholders
Agreement, dated as of December 26,
2007, by and between El Pollo Loco
Holdings, Inc. (formerly Chicken
Acquisition Corp.) and Trimaran Pollo
Partners, L.L.C.

Second Amended and Restated
Limited Liability Company Operating
Agreement of Trimaran Pollo Partners,
L.L.C., dated as of March 8, 2006

Amendment No. 1 to Second
Amended and Restated Limited
Liability Company Operating
Agreement of Trimaran Pollo Partners,
L.L.C., dated as of December 26, 2007  

Amendment No. 2 to Second
Amended and Restated Limited
Liability Company Operating
Agreement of Trimaran Pollo Partners,
L.L.C., dated as of January 30, 2008

Amendment No. 3 to Second
Amended and Restated Limited
Liability Company Operating
Agreement of Trimaran Pollo Partners,
L.L.C., dated as of July 14, 2011

10.13

  Form of Franchise Agreement

10.14*

10.15

10.16

10.17

Form of Franchise Development
Agreement

  Form of Franchise Agreement (2019)

Form of Franchise Development
Agreement (2019)

Form of Indemnification Agreement
between El Pollo Loco Holdings, Inc.
and each of its directors and executive
officers

X    

X

S-1

N/A

10.3

6/24/2014

333-197001

S-1

N/A

10.4

6/24/2014

333-197001

S-1

N/A

10.5

6/24/2014

333-197001

S-1

N/A

10.6

6/24/2014

333-197001

S-1

N/A

10.7

6/24/2014

333-197001

S-1

N/A

10.8

6/24/2014

333-197001

S-1

N/A

10.9

6/24/2014

333-197001

S-1  

S-1

N/A  

10.12  

6/24/2014  

333-197001

N/A

10.13

6/24/2014

333-197001

S-1/A

N/A

10.27

7/22/2014

333-197001

10.18*

  2014 Omnibus Equity Incentive Plan

    S-1/A  

N/A  

10.22  

7/22/2014  

333-197001

10.19*

Form of Option Award Agreement
(Fair Market Value Options) under
2014 Omnibus Equity Incentive Plan

S-1/A

N/A

10.25

7/22/2014

333-197001

102

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
   
   
   
   
 
 
   
   
   
   
   
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
10.20*

10.21*

10.22*

Form of Non-Officer Director
Restricted Share Agreement under
2014 Omnibus Equity Incentive Plan

Form of Option Award Agreement
(Fair Market Value Options) under
2014 Omnibus Equity Incentive Plan
(Time Vesting Only)

Form of Employee Restricted Share
Agreement under 2014 Omnibus
Equity Incentive Plan

S-1/A

N/A

10.26

7/22/2014

333-197001

10-Q

6/29/2016

10.27

8/5/2016

001-36556

10-Q

9/28/2016

10.28

11/4/2016

001-36556

10.23*

  2018 Omnibus Equity Incentive Plan

S-8  

N/A  

4.3  

8/6/2018  

333-226621

X

X

X

X

X

10.24*

10.25*

10.26*

10.27*

10.28*

10.29*

10.30*

10.31*

10.32*

10.33*

10.34*

10.35*

10.36*

Form of Restricted Stock Agreement
under 2018 Omnibus Equity Incentive
Plan

Form of Restricted Stock Agreement
under 2018 Omnibus Equity Incentive
Plan (Non-Employee Directors)

Form of Restricted Stock Unit
Agreement under 2018 Omnibus
Equity Incentive Plan

Form of Stock Option Awards
Agreement under 2018 Omnibus
Equity Incentive Plan

Employment Agreement between
Bernard Acoca and El Pollo Loco, Inc.    

Employment Agreement between
Laurance Roberts and El Pollo Loco,
Inc.

Employment Agreement between
Hector Munoz and El Pollo Loco, Inc.

Employment Agreement between
Miguel Lozano and El Pollo Loco,
Inc.

Retirement Agreement between
Stephen J. Sather and El Pollo Loco,
Inc. and Executive’s Waiver and
Release of Claims between Stephen J.
Sather and El Pollo Loco, Inc.

Separation Agreement between Gus
Siade and El Pollo Loco, Inc.

Form of Non-Qualified Stock Option
Agreement between El Pollo Loco
Holdings, Inc. and Bernard Acoca

Form of Restricted Share Unit Award
Agreement between El Pollo Loco
Holdings, Inc. and Bernard Acoca

Form of Performance Share Unit
Award Agreement between El Pollo
Loco Holdings, Inc. and Bernard
Acoca

10-K

12/27/2017

10.29

3/9/2018

001-36556

S-1

N/A

10.15

6/24/2014

333-197001

10-Q

3/27/2019

10.31

5/3/2019

001-36556

10-K

12/27/2017

10.30

3/9/2018

001-36556

10-Q

3/27/2019

10.32

5/3/2019

001-36556

N/A

4.3

5/8/2018

333-224730

N/A

4.4

5/8/2018

333-224730

N/A

4.5

5/8/2018

333-224730

S-8

S-8

S-8

103

 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
   
   
   
   
   
 
 
   
   
   
   
   
 
 
   
   
   
   
   
 
 
   
   
   
   
   
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
   
   
   
   
   
 
   
 
 
 
 
 
 
   
 
 
 
 
 
 
   
 
 
 
 
 
 
   
 
 
 
 
 
 
   
 
 
 
 
 
 
   
 
 
 
 
 
S-1

N/A

21.1

6/24/2014

333-197001

21.1

23.1

24.1

31.1

31.2

32.1

Subsidiaries of El Pollo Loco
Holdings, Inc.

  Consent of BDO USA, LLP

Power of Attorney (included on
signature page hereto)

Certification of Principal Executive
Officer under section 302 of the
Sarbanes–Oxley Act of 2002

Certification of Principal Financial
Officer under section 302 of the
Sarbanes–Oxley Act of 2002

Certification of Chief Executive
Officer and Chief Financial Officer
under 18 U.S.C. section 1350, adopted
by section 906 of the Sarbanes–Oxley
Act of 2002

101.INS   XBRL Instance Document

101.SCH

101.CAL

101.DEF

101.LAB

101.PRE

XBRL Taxonomy Extension Schema
Document

XBRL Taxonomy Extension
Calculation Linkbase Document

XBRL Taxonomy Extension
Definition Linkbase Document

XBRL Taxonomy Extension Label
Linkbase Document

XBRL Taxonomy Extension
Presentation Linkbase Document

X  

X

X

X

**

X  

X

X

X

X

X

*

**

This exhibit is a management contract or a compensatory plan or arrangement.

Furnished herewith.

ITEM 16.

FORM 10-K SUMMARY

None.

104

 
 
 
 
 
 
 
 
 
   
   
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its
behalf by the undersigned, thereunto duly authorized.

SIGNATURES

EL POLLO LOCO HOLDINGS, INC.

By:

/s/ Bernard Acoca

  Bernard Acoca

  President and Chief Executive Officer

Date: March 6, 2020

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, this report has been signed below by the following persons on behalf of the registrant
and in the capacities and on the dates indicated.

Name

/s/ Bernard Acoca

Bernard Acoca

/s/ Laurance Roberts

Laurance Roberts

/s/ Michael G. Maselli

Michael G. Maselli

/s/ Dean C. Kehler

Dean C. Kehler

/s/ John M. Roth

John M. Roth

/s/ Douglas J. Babb

Douglas J. Babb

/s/ Samuel N. Borgese

Samuel N. Borgese

/s/ Mark Buller

Mark Buller

/s/ William R. Floyd

William R. Floyd

/s/ Carol Lynton

Carol Lynton

Title

Date

Director, President and Chief Executive Officer (principal executive officer)

Chief Financial Officer (principal financial and accounting officer)

Chairman and Director

Director

Director

Director

Director

Director

Director

Director

105

  March 6, 2020

  March 6, 2020

  March 6, 2020

  March 6, 2020

  March 6, 2020

  March 6, 2020

  March 6, 2020

  March 6, 2020

  March 6, 2020

  March 6, 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
   
 
   
   
 
 
   
 
   
   
 
 
   
   
 
 
   
   
 
 
   
   
 
 
   
   
 
 
   
   
 
 
   
 
   
   
 
 
   
 
   
   
 
 
   
DESCRIPTION OF CAPITAL STOCK OF EL POLLO LOCO HOLDINGS, INC.

References to “we,” “us” and “our” refer to El Pollo Loco Holdings, Inc.

Exhibit 4.1

The following is a summary of the rights and preferences of our capital stock and preferred stock, related provisions of our certificate of

incorporation and bylaws, and certain applicable provisions of Delaware law. While we believe that the following description covers the material terms of
our capital stock, the description may not contain all of the information that is important to you. The following description is qualified by reference to our
certificate of incorporation and our bylaws, which are filed as exhibits to our Annual Report on Form 10-K for the year ended December 25, 2019 filed
with the Securities and Exchange Commission.

General

Our authorized capital stock consists of 200,000,000 shares of common stock, par value $0.01 per share, and 100,000,000 shares of preferred stock,
par value $0.01 per share. As of February 27, 2020, we had 35,089,983 shares of common stock outstanding, and no shares of preferred stock outstanding.

Common Stock

Under our certificate of incorporation, each outstanding share of common stock is entitled to one vote on all matters submitted to a vote of
stockholders. In the event of our liquidation, dissolution or winding up, holders of common stock will be entitled to share ratably in all assets remaining
after payment of liabilities and any amounts due to the holders of preferred stock. Holders of our common stock have no preemptive, conversion or
subscription rights. No redemption or sinking fund provisions apply to our common stock. Holders of our common stock do not have the right of
cumulative voting in elections of directors, which means that holders of a majority of the outstanding shares of our common stock can elect all of the
directors standing for election at any annual meeting of stockholders.

Subject to preferences that may be applicable to any outstanding shares of preferred stock, holders of our common stock are entitled to receive

ratably such dividends as may be declared from time to time by our board of directors out of legally available funds.

Preferred Stock

Our certificate of incorporation authorizes our board of directors, without stockholder approval, to issue up to 100,000,000 shares of preferred stock
in one or more series and to fix the rights, preferences, privileges and restrictions granted to or imposed upon each such series of preferred stock, including
voting rights, dividend rights, conversion rights, terms of redemption, liquidation preference, sinking fund terms, subscription rights and the number of
shares constituting any series or the designation of a series.

Our board of directors is able to issue, without stockholder approval, preferred stock with voting and conversion rights that could adversely affect the

voting power of the holders of common stock and reduce the likelihood that such holders will receive dividend payments or payments upon liquidation.
Such issuance could have the effect of decreasing the market price of the common stock.

Anti-Takeover Provisions of Delaware Law and Certain Charter and Bylaw Provisions

The following is a summary of certain provisions of the Delaware General Corporation Law (the “DGCL”), and our certificate of incorporation and

bylaws that may be deemed to have an anti-takeover effect and may delay, deter or prevent a tender offer or takeover attempt that a stockholder might
consider to be in its best interest, including those attempts that might result in a premium over the market price for the shares held by stockholders.

Exhibit 4.1

Classified Board of Directors

Our certificate of incorporation provides for our board of directors to be divided into three classes of directors, as nearly equal in number as possible,

serving staggered terms. Approximately one-third of our board of directors is to be elected each year. Under Section 141 of the DGCL, unless the
certificate of incorporation provides otherwise, directors serving on a classified board can only be removed for cause. Our certificate of incorporation
provides that our directors may only be removed for cause, by a majority of the voting power of the outstanding voting stock voting as a single class to
remove the director at an annual or special meeting. However, if Trimaran Pollo Partners, L.L.C. (“LLC”) beneficially owns more than 40% of our
common stock, our directors may be removed with or without cause, by a majority of the voting power of the outstanding stock voting as a single class.
The provision for our classified board of directors may be amended, altered or repealed only upon the affirmative vote of the holders of a majority of our
outstanding voting stock.

Number of Directors; Vacancies

Our certificate of incorporation provides that the number of directors on our board of directors is to be fixed exclusively pursuant to resolution
adopted by our board of directors. The exact number of members on our board of directors is to be determined from time to time by resolution of a majority
of our full board of directors.

Pursuant to our certificate of incorporation, each director is to serve until his or her successor is duly elected and qualified, unless he or she resigns,
dies, becomes disqualified or is removed. Our certificate of incorporation further provides that, generally, vacancies or newly created directorships in our
board of directors may only be filled by a resolution approved by a majority of our board of directors and any director so chosen will hold office until the
next election of the class for which such director was chosen.

Stockholder Meetings

Our certificate of incorporation and bylaws prohibit our stockholders from calling special meetings once LLC ceases to beneficially own more than
40% of our common stock, in which event, special meetings of stockholders will be able to be called only by (i) the Chairman of our board of directors or
(ii) our Secretary at the written request of a majority of the number of directors that we would have were there no vacancies on our board of directors.

Action by Stockholders Without a Meeting

The DGCL permits stockholder action by written consent unless otherwise provided by a corporation’s certificate of incorporation. Our certificate of

incorporation prohibits stockholder action by written consent when LLC ceases to beneficially own more than 40% of our common stock.

No Cumulative Voting

The DGCL provides that stockholders are not entitled to the right to cumulate votes in the election of directors unless a corporation’s certificate of

incorporation provides otherwise. Our certificate of incorporation does not provide for cumulative voting in the election of directors.

Stockholder Proposals and Nominations

Our bylaws provide that stockholders seeking to bring business before an annual meeting of stockholders or to nominate candidates for election as

directors at an annual meeting of stockholders must provide timely notice of such proposed business in writing. To be timely, a stockholder’s notice
generally must be delivered to or mailed and received at our principal executive office not less than 90 days or more than 120 days prior to the first
anniversary of the preceding year’s annual meeting.

Our bylaws also provide certain requirements as to the form and content of a stockholder’s notice. These provisions may preclude stockholders from
bringing matters before an annual meeting of stockholders or from making nominations for directors at an annual meeting of stockholders. A stockholder’s
notice must set forth, among other things, as to each business matter or nomination the stockholder proposes to bring before the meeting:

•

the name and address of the stockholder and the beneficial owner, if any, on whose behalf the proposal or nomination is made;

Exhibit 4.1

•

the class and number of shares that are owned of record and beneficially by the stockholder proposing the business or nominating the nominee;

•

a representation that the stockholder giving the notice is a holder of record of shares of our voting stock entitled to vote at such annual meeting
and intends to appear in person or by proxy at the annual meeting to propose the business or nominate the person or persons specified in the
notice, as applicable; and

• whether such stockholder or beneficial owner intends to deliver a proxy statement and forms of proxy to holders of at least the percentage of

shares of our voting stock required to approve such proposal or nominate such nominee or nominees.

If the stockholder is nominating a candidate for director, the stockholder’s notice must also include the name, age, business address, residence
address and occupation of the nominee proposed by the stockholder and the signed consent of the nominee to serve as a director on our board of directors if
so elected. The candidate may also be required to present certain information and make certain representations and agreements at our request.

In addition, a stockholder must also comply with all applicable requirements of the Securities Exchange Act of 1934, as amended (the “Exchange

Act”) and the rules and regulations under the Exchange Act with respect to matters relating to nomination of candidates for directors.

Supermajority provisions

The DGCL generally provides that the affirmative vote of a majority of the shares entitled to vote on any matter is required to amend a corporation’s
certificate of incorporation or bylaws, unless the corporation’s certificate of incorporation or bylaws require a greater percentage. Our amended and restated
certificate of incorporation and bylaws require that the affirmative votes of holders of at least 75% of the total votes eligible to be cast in the election of
directors are required to amend, alter, change or repeal specified provisions of our amended and restated certificate of incorporation on and after the date
LLC ceases to beneficially own at least 40% of the total votes eligible to be cast in the election of directors, including:

•

•

•

classified board of directors (the election and term of our directors);

the provisions regarding director liability;

the provisions regarding director and officer indemnification;

 
 
Exhibit 4.1

•

•

•

•

•

•

•

the provisions regarding competition and corporate opportunities;

the provisions regarding entering into business combinations with interested stockholders;

the provisions regarding stockholder action by written consent;

the provisions regarding calling special meetings of stockholders;

filling vacancies on our board of directors;

the advance notice requirements for stockholder proposals and director nominations; and

the amendment provision requiring that the above provisions be amended only with a 75% supermajority vote.

This requirement of a supermajority vote to approve amendments to our amended and restated certificate of incorporation and bylaws could enable a

minority of our stockholders to exercise veto power over any such amendments.

Delaware Anti-Takeover Statute

Section 203 of the DGCL, subject to certain exceptions, prohibits a publicly-held Delaware corporation from engaging in any business combination

with any interested stockholder for a period of three years following the date that such person or entity became an interested stockholder, unless:

•

•

•

prior to such date, the board of directors of the corporation approved either the business combination or the transaction which resulted in the
stockholder becoming an interested stockholder;

upon consummation of the transaction that resulted in the stockholder becoming an interested stockholder, the interested stockholder owned at
least 85% of the voting stock of the corporation outstanding at the time the transaction commenced, excluding specified shares; or

at or subsequent to such date of the transaction that resulted in a person or entity becoming an interested stockholder, the business combination is
approved by the board of directors and authorized at an annual or special meeting of stockholders, and not by written consent, by the affirmative
vote of at least 66 2/3% of the outstanding voting stock that is not owned by the interested stockholder.

In general, Section 203 defines an “interested stockholder” as any person that is:

•

owner of 15% or more of the outstanding voting stock of the corporation;

 
 
•

an affiliate or associate of the corporation and was the owner of 15% or more of the outstanding voting stock of the corporation at any time
within three years immediately prior to the relevant date; or

Exhibit 4.1

•

an affiliate or associate of the above.

A Delaware corporation may “opt out” of these provisions with an express provision in its original certificate of incorporation or an express
provision in its certificate of incorporation or bylaws resulting from a stockholders’ amendment approved by at least a majority of the outstanding voting
stock. We have opted out of these provisions. However, our certificate of incorporation provides that in the event that LLC ceases to beneficially own more
than 15% of our common stock, we will automatically become subject to Section 203 of the DGCL.

Limitations on Liability and Indemnification of Directors and Officers

Section 145 of the DGCL provides that a Delaware corporation may indemnify any persons who are, or are threatened to be made, parties to any

threatened, pending or completed action, suit or proceeding, whether civil, criminal, administrative or investigative (other than an action by or in the right
of such corporation), by reason of the fact that such person was an officer, director, employee or agent of such corporation, or is or was serving at the
request of such person as an officer, director, employee or agent of another corporation or enterprise. The indemnity may include expenses (including
attorneys’ fees), judgments, fines and amounts paid in settlement actually and reasonably incurred by such person in connection with such action, suit or
proceeding, provided that such person acted in good faith and in a manner he or she reasonably believed to be in or not opposed to the corporation’s best
interests and, with respect to any criminal action or proceeding, had no reasonable cause to believe that his or her conduct was illegal.

A Delaware corporation may indemnify any persons who are, or are threatened to be made, a party to any threatened, pending or completed action or

suit by or in the right of the corporation by reason of the fact that such person was a director, officer, employee or agent of such corporation, or is or was
serving at the request of such corporation as a director, officer, employee or agent of another corporation or enterprise. The indemnity may include
expenses (including attorneys’ fees) actually and reasonably incurred by such person in connection with the defense or settlement of such action or suit
provided such person acted in good faith and in a manner he or she reasonably believed to be in or not opposed to the corporation’s best interests except
that no indemnification is permitted without judicial approval if the officer or director is adjudged to be liable to the corporation. Where an officer or
director is successful on the merits or otherwise in the defense of any action referred to above, the corporation must indemnify him or her against the
expenses that such officer or director has actually and reasonably incurred. Our certificate of incorporation provides for the indemnification of our directors
and officers to the fullest extent permitted under the DGCL.

Expenses incurred by any officer or director in defending any such action, suit or proceeding in advance of its final disposition shall be paid by us

upon delivery to us of an undertaking, by or on behalf of such director or officer, to repay all amounts so advanced if it shall ultimately be determined that
such director or officer is not entitled to be indemnified by us.

Section 102(b)(7) of the DGCL permits a corporation to provide in its certificate of incorporation that a director of the corporation shall not be
personally liable to the corporation or its stockholders for monetary damages for breach of fiduciary duties as a director, except for liability for any:

•

•

transaction from which the director derives an improper personal benefit;

act or omission not in good faith or that involves intentional misconduct or a knowing violation of law;

 
Exhibit 4.1

•

•

unlawful payment of dividends or redemption of shares; or

breach of a director’s duty of loyalty to the corporation or its stockholders.

Our certificate of incorporation includes such a provision.

Section 174 of the DGCL provides, among other things, that a director who willfully or negligently approves of an unlawful payment of dividends or
an unlawful stock purchase or redemption may be held liable for such actions. A director who was either absent when the unlawful actions were approved,
or dissented at the time, may avoid liability by causing his or her dissent to such actions to be entered in the books containing minutes of the meetings of
the board of directors at the time such action occurred or immediately after such absent director receives notice of the unlawful acts.

Indemnification Agreements

We have entered into indemnification agreements with each of our current directors and executive officers. These agreements require us to indemnify

these individuals to the fullest extent permitted under Delaware law against liabilities that may arise by reason of their service to us and to advance
expenses incurred as a result of any proceeding against them as to which they could be indemnified. We also intend to enter into indemnification
agreements with our future directors and executive officers.

Transfer Agent

The registrar and transfer agent for our common stock is American Stock Transfer & Trust Company, LLC.

Listing

Our common stock trades on The Nasdaq Stock Market LLC under the symbol “LOCO.”

Exhibit 10.15

EL POLLO LOCO® FRANCHISE AGREEMENT

Dated: ____________________

Location:
Franchisee:
Franchisee Notice Address:
Franchisee Notice Facsimile Number:

(Disclosure Document Control No. 032619)

TABLE OF CONTENTS:

1.SCOPE AND PURPOSE OF AGREEMENT    4

2.THE EL POLLO LOCO® MARKS & SYSTEM    5

3.TERM    7

4.SITE DEVELOPMENT    7

5.IMPROVEMENTS, FIXTURES AND EQUIPMENT    8

6.FEES, TAXES AND OTHER CHARGES    11

7.FINANCIAL REPORTING, BILLING AND PAYMENT    13

8.ADVERTISING AND MARKETING    19

9.INSURANCE AND INDEMNIFICATION    21

10.VENDING MACHINES    24

11.COMPLIANCE WITH MANUAL AND WITH SYSTEM STANDARDS    24

12.RESTAURANT MAINTENANCE AND REPAIR    27

13.HOURS OF OPERATION    28

14.PERSONNEL STANDARDS    29

15.INSPECTIONS    29

16.TRAINING    31

17.ASSIGNMENT    33

18.DEFAULT AND TERMINATION    40

19.RIGHTS AND OBLIGATIONS UPON TERMINATION    44

20.RIGHTS TO A SUCCESSOR FRANCHISE    46

21.PROPRIETARY RIGHTS AND UNFAIR COMPETITION    47

22.DISPUTE RESOLUTION    52

23.MISCELLANEOUS PROVISIONS    53

24.EFFECTIVE DATE    58

25.ACKNOWLEDGMENTS    58

26.ANTI-TERRORISM LAW    59

27.SIGNATURES    61

EXHIBITS AND SCHEDULES:

EXHIBIT 1: MEMORANDUM OF OPENING DATE62

EXHIBIT 2: PERSONAL GUARANTEE OF FRANCHISE AGREEMENT63

EXHIBIT 3: INVESTOR COVENANTS REGARDING CONFIDENTIALITY AND NON-COMPETITION66

EXHIBIT 4: AUTHORIZATION AGREEMENT FOR PREARRANGED PAYMENTS (ACH)70

EXHIBIT 5: ADVERTISING ASSOCIATION DOCUMENTS71

EXHIBIT 6: EL POLLO LOCO® FINANCIAL REPORTING FORM    92

EXHIBIT 7: IT SUPPORT SERVICES AGREEMENT93

EXHIBIT 8: GENERAL RELEASE106

EXHIBIT 9: CONSENT TO AND ASSIGNMENT OF FRANCHISE RIGHTS108

EXHIBIT 10: AMENDMENT TO FRANCHISE AGREEMENT TO APPLY DEVELOPMENT FEE118

EXHIBIT 11: AMENDMENT TO SUCCESSOR FRANCHISE AGREEMENT120

EXHIBIT 12: REMODEL SCHEDULE PARTICIPATION AGREEMENT123

EL POLLO LOCO® FRANCHISE AGREEMENT SCHEDULE 1: PROTECTED AREA    127

EL  POLLO  LOCO®  FRANCHISE  AGREEMENT  SCHEDULE  2:  STATEMENT  OF  OWNERSHIP  OF

FRANCHISEE    128

EL POLLO LOCO® FRANCHISE AGREEMENT

This  Franchise  Agreement  ("Agreement"),  dated  for  identification  purposes  only  as  of  ____,  20__,  is  made  and
entered into by and between EL POLLO LOCO, INC., a Delaware corporation (the "Franchisor"), and , an individual
("Franchisee").

A.Franchisor operates and franchises others to operate a number of retail outlets for the sale of fire-grilled food items
and  related  products,  in  connection  with  the  "El  Pollo  Loco"  name  and  Franchisor's  distinctive  plan  of  food  service
operation.

B.Franchisee desires to operate a restaurant under Franchisor's name and to utilize Franchisor's plan of food service
operation, all in accordance with the terms, covenants and conditions of this Agreement.

C.Franchisee understands that the success of the business contemplated by this Agreement is subject to substantial
risks and depends in large part on the business ability of Franchisee and its active participation in the development
and management of the franchise business.

D.Franchisor  and  Franchisee  (as  Developer)  entered  into  a  Development  Agreement  dated  ________________
(“Development  Agreement”)  for  the  Territory  set  forth  on  Exhibit  A  of  the  Development  Agreement,  and  for
restaurants to be developed per the Development Schedule set forth on Exhibit B of the Development Agreement.

Exhibit D of Multi-State Disclosure Document Control No. 032619

Franchise Agreement - Page 1 of 1

1.

SCOPE AND PURPOSE OF AGREEMENT

1.1.    Franchisee desires and agrees to operate and manage an "El Pollo Loco" (or “EPL”) restaurant to be
located at ____________________________ City of , County of ___________, State of (the "Location"). Franchisor
owns certain proprietary and other property rights and interests in and to the "El Pollo Loco" trademark and service
mark, and such other trademarks, service marks, logo types, insignias, trade dress designs and commercial symbols
as Franchisor may from time to time authorize or direct Franchisee to use in connection with the operation of a "El
Pollo  Loco"  Restaurant  (the  "El  Pollo  Loco®  Marks").  Franchisor  has  a  distinctive  plan  for  the  operation  of  retail
outlets for the sale of fire-grilled food items and related products, which plan includes but is not limited to the El Pollo
Loco®  Marks  and  the  Operations  Manual  (the  "Manual"),  policies,  standards,  procedures,  recipes,  employee
uniforms,  signs  (including  traditional  or  digital  menu  boards)  and  related  items,  and  the  reputation  and  goodwill  of
Franchisor's  chain  of  restaurants  (collectively,  the  "El  Pollo  Loco®  System").  Therefore,  in  entering  into  this
Agreement,  Franchisee  fully  understands  and  agrees  that  this  Agreement  is  conditioned  upon  the  continued  strict
adherence  by  Franchisee  to,  and  Franchisee  agrees  to  comply  with,  all  standards,  policies,  procedures  and
requirements published or which may from time to time be published or otherwise brought to Franchisee's attention
by Franchisor for the operation, maintenance or improvement of "El Pollo Loco" restaurants under the El Pollo Loco®
System and the El Pollo Loco® Marks. Franchisee understands and agrees that strict adherence to these standards,
policies, procedures and requirements is essential to the value of the El Pollo Loco® System and the El Pollo Loco®
Marks.

1.2.        Franchisee  represents  that  it  is  experienced  in  and  has  independent  knowledge  of  the  nature  and
specifics of the restaurant  business.  Franchisee  understands  that  there  is  not,  nor  can  there  be,  any  assurance  or
guarantee  of  success  in  the  franchise  business  and  that  Franchisee's  business  ability  and  attitude  are  primary  in
determining Franchisee's success. Franchisee represents that, in entering into this Agreement, it has relied solely on
its  personal  knowledge  and  understanding  and  has  not  relied  on  any  representation  of  Franchisor  or  any  of  its
officers,  directors,  employees  or  agents,  except  those  representations  contained  in  any  legally  required  Franchise
Disclosure Document delivered to Franchisee.

a.        In  consideration  of  the  foregoing  representations  and  agreements  of  Franchisee  and  other
consideration  as  set  forth  herein,  and  subject  to  all  of  the  terms,  covenants  and  conditions  of  this  Agreement,
Franchisor hereby grants to Franchisee, and Franchisee hereby accepts from Franchisor, the right and franchise to
operate one (1) “El Pollo Loco” restaurant under the El Pollo Loco® Marks and in accordance with the El Pollo Loco®
System (the “Restaurant”) at the Location.

Exhibit D of Multi-State Disclosure Document Control No. 032619

Franchise Agreement - Page 2 of 2

1.3.    Except as otherwise provided in this Agreement, after the date of this Agreement and during the term of
this  Agreement,  and  so  long  as  Franchisee  is  in  compliance  with  its  obligations  under  this  Agreement,  Franchisor
shall not, without Franchisee’s prior written consent, establish or franchise any other person to establish, an El Pollo
Loco  restaurant  at  any  location  within  the  “Protected Area”  specified  in  Schedule  1  to  this  Agreement.  Franchisor
expressly  retains  all  other  rights  and  may,  among  other  things,  on  any  terms  and  conditions  Franchisor  deems
advisable, and without granting Franchisee any right therein:

a.    Establish and operate or franchise others to establish and operate El Pollo Loco® restaurants at any

location outside the Protected Area;

b.    Merchandise and distribute goods and services identified by the El Pollo Loco® Marks (including the
same or similar products as sold by Franchisee at the Restaurant) to customers at any retail location, regardless of its
proximity to the Location, through any method or channel of distribution, including, without limitation, at retail locations
such as grocery or convenience stores and via the Internet, telemarketing, and direct marketing means, through other
non-El Pollo Loco restaurants having the same or similar menu items or through any other distribution channel; and

c.        Establish  and  operate  and  franchise  other  restaurants  (not  using  the  Marks)  having  the  same  or

similar menu items, whether within or outside of the Protected Area.

1.4.        It  is  expressly  understood  and  agreed  by  the  parties  that  Franchisee  is  and  shall  be  an  independent
contractor, that Franchisee is not for any purpose an employee or agent of Franchisor, and that all of the personnel
employed by Franchisee at the Restaurant will be employees or agents of Franchisee as an independent contractor
and  will  not  be  employees  or  agents  of  Franchisor.  Franchisee  understands  and  agrees  that,  as  an  independent
contractor,  it  does  not  have  the  authority  to  do  anything  for  or  on  behalf  of  Franchisor  including,  but  not  limited  to,
holding itself out as Franchisor; signing contracts, notes or other instruments; purchasing, acquiring or disposing of
any property; or incurring any other obligation or liability. It is further understood and agreed by the parties hereto that
no fiduciary relationship is intended or created by this Agreement.

Exhibit D of Multi-State Disclosure Document Control No. 032619

Franchise Agreement - Page 3 of 3

2.

THE EL POLLO LOCO® MARKS & SYSTEM

2.1.    Upon the terms, covenants and conditions contained herein and during the term hereof, Franchisee shall
have the right to display and use the El Pollo Loco® Marks, but only for use in connection with retail sales and service
of  certain  food  products  which  Franchisee  is  required  to  prepare  and  sell  to  the  general  public  in  and  at  the
Restaurant.

2.2.    Nothing contained herein shall be construed as authorizing or permitting Franchisee to use the El Pollo
Loco®  Marks  or  the  El  Pollo  Loco®  System  at  any  location  other  than  the  Location  or  for  any  purpose  or  in  any
manner other than that authorized herein; or in connection with the sale of any products for resale, or any products
not required or approved by Franchisor, or any products prepared at any place other than at the Location; provided,
however,  that  catering  and  special  event  sales  may  be  undertaken  by  Franchisee  in  strict  adherence  with  the
limitations  and  procedures  set  forth  in  the  Manual.  Notwithstanding  anything  to  the  contrary  contained  herein,
Franchisor may require Franchisee to discontinue the preparation, offer or sale of any product or item which, in the
opinion of Franchisor or any of its representatives, does not conform to the quality standards or image of Franchisor
and its products.

2.3.    Nothing contained herein shall give Franchisee any right, title or interest in or to any of the El Pollo Loco®
Marks excepting only the privilege and license, during the term hereof, to display and use the same according to the
foregoing limitations. Any and all goodwill arising in connection with Franchisee's use of the El Pollo Loco® Marks and
the El Pollo Loco® System shall belong to Franchisor.

2.4.    The business franchised hereunder shall be named "El Pollo Loco" without any suffix or prefix attached
thereto. Franchisee shall use signs (including traditional or digital menu boards) (“Signs”) and other advertising which
denote that the Restaurant is named "El Pollo Loco" and which are approved by Franchisor in advance. If Franchisee
is transferred to an Entity (as defined below), the name of such corporation shall not contain any of the El Pollo Loco®
Marks.

2.5.    Except as Franchisor may otherwise permit in writing, Franchisee shall not display or use the trademark,
trade name, service mark, logo types, label, design or other identifying symbol or name of any other person, or Entity
in, on or at the Restaurant or the Location.

Exhibit D of Multi-State Disclosure Document Control No. 032619

Franchise Agreement - Page 4 of 4

2.6.    In all public records, in Franchisee’s relationship with other persons or companies, and in any offering
document,  prospectus  or  similar  document,  Franchisee  shall  indicate  clearly  that  Franchisee's  business  is
independently  owned  and  that  the  operations  of  said  business  are  separate  and  distinct  from  the  operation  of
Franchisor's  business.  Franchisee  shall  display  at  the  Restaurant,  in  such  locations  as  may  be  specified  by
Franchisor  and  in  all  correspondence  and  forms,  a  notification  that  the  Restaurant  is  operated  by  an  independent
operator and not by Franchisor.

2.7.    Franchisee shall not develop, create, generate, own, license, lease or use in any manner any computer
medium or electronic medium (including, without limitation, any Internet home page, e-mail address, website, domain
name, bulletin board, newsgroup or other Internet-related medium) which in any way uses or displays, in whole or in
part, the El Pollo Loco®  Marks,  or  any  of  them,  or  any  words,  symbols  or  terms  confusingly  similar  thereto  without
Franchisor’s  express  written  consent,  and  then  only  in  such  manner  and  in  accordance  with  such  procedures,
policies, standards and specifications as Franchisor may establish from time to time.

“crazychicken;” 

2.8.        Franchisor  is  the  owner  of,  and  will  retain  all  right,  title  and  interest  in  and  to  the  domain  names
“elpolloloco”  and 
the  URLs  and/or  websites:  www.elpolloloco.com,  www.elpolloloco.net,
www.elpolloloco.org,  www.myepl.net,  www.crazychicken.com,  www.eplmarketing.com,  www.eplportal.com,
www.eplfranchisee.com,  and  www.orderelpolloloco.com;  all  existing  and  future  domain  names,  URLs,  websites,
future addresses and subaddresses using the El Pollo Loco® Marks in any manner; all software; all content prepared
for, or used on, the above Websites; and all intellectual property rights in and to any of them.

2.9.    Franchisor reserves all rights to use the El Pollo Loco ® Marks in any manner.

3.

TERM

3.1.    The term of this Agreement shall commence on the date Franchisee first opens the Restaurant to the
public  (the  “Opening  Date”)  and  shall  end  on  the  date  which  is  the  20th  anniversary  of  the  Opening  Date,  unless
sooner terminated as provided herein (“Initial Term”). Should Franchisee lease the site of the Restaurant, the lease
or  sublease  must  be  for  a  term  which  with  renewal  options  is  not  less  than  the  Initial  Term  of  the  Franchise
Agreement, and contain the provisions required in Section 2 of the Development Agreement. Should Franchisee be
unable to lease the site of the Restaurant for a term equal to the Initial Term, then as our sole and absolute right to
determine, the Initial Term of the Franchise Agreement may be reduced to match the term of the lease or sublease
and  the  initial  franchise  fee  will  be  appropriately  pro-rated.  Promptly  following  the  Opening  Date,  the  parties  shall
execute  a  Memorandum  of  Opening  Date  attached  as  Exhibit  1  which  shall  confirm  the  Opening  Date;  provided,
however, if the parties fail to execute such Memorandum of Opening Date, the Opening Date shall be as determined
in  good faith by Franchisor. Upon  the  expiration  or  earlier  termination  of  this  Agreement,  Franchisee  shall  have  no
right  or  option  to  extend  the  term  of  this  Agreement.  The  sole  conditions  under  which  Franchisee  will  have  the
opportunity  to  obtain  a  successor  Franchise  Agreement  upon  the  expiration  of  the  term  of  this  Agreement  are  set
forth at Section 20.

4.

SITE DEVELOPMENT

4.1.    After execution of this Agreement, Franchisee will be required to achieve certain milestones to assure

the timely development of the Restaurant

a.        Within  six  (6)  months  following  the  date  of  Franchisor’s  execution  of  this  Agreement,  Franchisee
must have completed all of the site development work (including, but not limited to, engineering, architectural/design,
entitlements, and permitting) and commence construction of the Restaurant.

b.        Within  twelve  (12)  months  following  the  date  of  Franchisor’s  execution  of  this  Agreement,  or  the
date  specified  in  the  Development  Agreement,  if  earlier,  Franchisee  must  have  completed  construction  of  the
Restaurant at the Location and the Restaurant shall be open to the public.

4.2.        Franchisee  understands  and  acknowledges  that  in  accepting  Franchisee’s  Location,  or  by  granting  a
franchise  for  a  Location  (whether  or  not  formerly  operated  as  a  Franchisor  or  franchisee-owned  Restaurant),

Franchisor  does  not  in  any  way  endorse,  warrant  or  guarantee  either  directly  or  indirectly  the  suitability  of  such
Location or the success of the franchise business to be operated by Franchisee at such Location. The suitability of
the  Location  and  the  success  of  the  franchise  business  depends  upon  a  number  of  factors  outside  of  Franchisor's
control including, but not limited to, Franchisee’s operational abilities, site location, consumer trends and such other
factors that are within the direct control of Franchisee. Franchisor may require, as a condition to its approval of a site,
a “Market Study”, which shall include a site description and analysis, traffic and other demographic information and
an analysis of the impact of the proposed site on other franchise restaurants surrounding or within the vicinity of such
proposed site all in such format as the Franchisor may require. All such analyses, information and studies shall be
prepared at the sole cost and expense of Franchisee.

4.3.        If  Franchisee  purchases  a  currently  operating  Restaurant  from  Franchisor  (a  “Turnkey  Restaurant”),
then Franchisee shall begin operation of the Restaurant on the date possession of the Restaurant is transferred to
Franchisee  pursuant  to  the  agreement  entered  into  between  Franchisee  and  Franchisor  for  the  purchase  of  the
Restaurant. Failure to do so shall constitute a material default hereunder. With respect to non-Turnkey Restaurants,
failure  to  reach  each  milestone  described  in  Section  4.1  above  within  the  specified  time  frames  shall  constitute  a
material  default  hereunder.  Prior  to  opening  the  Restaurant,  Franchisee  shall  obtain  and  thereafter  maintain
throughout the term of this Agreement all necessary business licenses, permits and other documentation necessary
for the operation of an El Pollo Loco® restaurant.

5.

IMPROVEMENTS, FIXTURES AND EQUIPMENT

5.1.        If  the  Location  is  other  than  a  Turnkey  Restaurant,  then  this  Section  5  will  apply  to  the  building,
reconstruction, remodeling, or other changes necessary to conform the Location to the requirements set forth in this
Section or as provided and updated by Franchisor from time to time in accordance with this Section.

5.2.        Franchisee,  at  its  sole  expense,  shall  construct  or,  in  the  case  of  an  existing  building,  remodel  the
Location and install such Signs, fixtures, furniture and equipment at the Location as are required in accordance with
Franchisor's  current  requirements  and  specifications  for  same.  Franchisee  shall  be  responsible  for  obtaining  all
zoning  classifications  and  clearances  which  may  be  required  by  state  or  local  laws,  ordinances  or  regulations.
Franchisee shall obtain from applicable governmental authorities all permits, licenses and certifications required for
lawful  construction  or  remodeling  work  and  for  the  operation  of  the  Restaurant.  If  requested  by  Franchisor,
Franchisee  shall  submit  to  Franchisor  a  copy  of  all  such  required  permits,  licenses  and  certifications  for  the
construction or remodeling work prior to commencing the construction or remodeling of the Location.

5.3.    Franchisor shall provide Franchisee with standard plans and a sample layout for a typical El Pollo Loco®
restaurant and a set of typical construction, equipment and decor specifications (the "Plans"). At all times, Franchisee
shall use its best efforts to treat and keep the Plans and the information contained therein as confidential as possible
and limit access to the Plans to employees and independent contractors of Franchisee on a need to know basis only
(including preferred development professionals). Franchisee acknowledges that the unauthorized use or disclosure of
Franchisor's Plans and the confidential information contained therein will cause irreparable injury to Franchisor and
that damages are not an adequate remedy. Franchisee accordingly covenants that without Franchisor's prior written
consent,  Franchisee  shall  not  disclose  (except  to  such  employees,  agents,  contractors  or  subcontractors  as  must
have  access  to  such  Plans  in  order  to  construct  the  Restaurant  at  the  Location)  or  use  or  permit  the  use  of  such
Plans (except as may be required by applicable law or authorized by this Agreement), or copy, duplicate, record or
otherwise reproduce such Plans, in whole or in part, or otherwise make the same available to any person or source
not authorized in writing by Franchisor to receive such Plans or the information contained therein at any time during
the term of this Agreement or thereafter.

5.4.        Franchisee,  at  its  sole  expense,  shall  employ  licensed  architects,  designers,  engineers,  development
consultants or others as may be necessary to complete, substitute, adapt or modify the Plans for the Restaurant so
as to create a set of final plans and specifications. Creating a set of final plans and specifications may include, but is
not  limited  to,  adapting  plans  for  structural  engineering,  architectural  requirements,  interior  and  exterior  materials,
locally  available  building  materials,  local  weather  requirements  and  federal,  state  and  local  code  requirements.  In
some cases, these can lead to substantial changes and costs in the provided plans. FRANCHISEE SHALL SUBMIT
TO FRANCHISOR A COMPLETE SET OF FINAL PLANS AND SPECIFICATIONS, INCLUDING A SITE PLAN, AND
OBTAIN  FRANCHISOR'S  WRITTEN  APPROVAL  OF  SUCH  PLANS  AND  SPECIFICATIONS  PRIOR  TO

COMMENCING THE CONSTRUCTION OF THE RESTAURANT OR, IN THE CASE OF AN EXISTING BUILDING,
THE  REMODELING  WORK  FOR  THE  RESTAURANT.  Franchisor  shall  review  such  final  plans  and  specifications
promptly  and  approve  or  disapprove  the  same,  and  Franchisor  may  provide  comments  on  the  plans  and
specifications to Franchisee. Such review and approval by Franchisor will be limited to items and issues relating to
the El Pollo Loco®  System  only  and  is  not  intended  to  be  a  verification  or  approval  of  the  structure  of  the  building,
mechanical  systems  or  document  accuracy.  Examples  of  conceptual  areas  related  to  the  El  Pollo  Loco®  System
include  Signs,  logos,  finishes,  decor  and  aesthetics,  guest  comfort,  and  ability  to  serve  food  within  Franchisor's
standards for quality, timeliness and cleanliness.

5.5.       Franchisee shall use a qualified licensed general contractor to perform the construction or remodeling
work  at  the  Restaurant.  Franchisees  general  contractor  shall  provide  a  schedule  to  Franchisor  before  the  start  of
construction.  Franchisor  shall  not  be  responsible  for  delays  in  the  construction,  equipping  or  decoration  of  the
Restaurant or for any loss resulting from the Restaurant design or construction. All changes in the Restaurant plans
relating  to  the  El  Pollo  Loco®  System,  as  described  in  Section  5.4  above,  to  the  construction  or  remodeling  of  the
Restaurant or the implementation of such changes are subject to Franchisor’s prior written approval. FRANCHISEE
SHALL PROVIDE WRITTEN NOTICE TO FRANCHISOR OF THE DATE UPON WHICH CONSTRUCTION OF THE
RESTAURANT COMMENCED  WITHIN  SEVEN  (7)  DAYS  AFTER  COMMENCEMENT AND THEREAFTER SHALL
PROVIDE  TO  FRANCHISOR  MONTHLY  PROGRESS  REPORTS  OF  THE  STATUS  OF  THE  CONSTRUCTION
WORK  SIGNED  BY  FRANCHISEE'S  ARCHITECT  OR  GENERAL  CONTRACTOR.  Franchisee's  failure  to
commence the design, construction or remodeling, equipping and opening of the Restaurant promptly and with due
diligence  shall  be  grounds  for  the  termination  of  this  Agreement.  Franchisor  shall  make  a  final  inspection  of  the
completed  Restaurant  and  Location  and  may  require  such  corrections  and  modifications  as  it  deems  necessary  to
bring  the  Restaurant  and  the  Location  into  compliance  with  approved  final  plans  and  specifications.  FRANCHISEE
SHALL  NOTIFY  FRANCHISOR  OF  THE  DATE  OF  COMPLETION  OF  CONSTRUCTION  AND,  WITHIN  A
REASONABLE  TIME  THEREAFTER,  FRANCHISOR  SHALL  CONDUCT  THE  FINAL  INSPECTION  OF  THE
RESTAURANT  AND  ITS  PREMISES.  Franchisee  acknowledges  and  agrees  that  Franchisee  shall  not  open  the
Restaurant for business without the express written authorization of Franchisor and that Franchisor's authorization to
open shall be conditioned upon Franchisee's furnishing to Franchisor:

a.    A letter from the general contractor responsible for the construction or remodeling of the Restaurant
indicating that the Restaurant has been constructed or remodeled in substantial conformance with the approved final
plans  and  specifications,  including  any  changes  thereto  approved  by  Franchisor,  and  in  accordance  with  all
applicable state and local governmental laws, statutes and ordinances regulating such construction including, without
limitation, building, fire, health and safety codes; and

b.    A temporary or final Certificate of Occupancy issued by the applicable local governmental entity.

5.6.    Franchisee shall, at its sole expense, purchase all required Signs, fixtures, furniture and equipment for
the Restaurant and Location from a distributor listed on the Approved Brands and Distributors List (as defined below)
or another distributor approved pursuant to Section 11.4. The items purchased shall be installed in strict accordance
with the specifications of Franchisor and erected and displayed in the manner and at such locations as are approved
and authorized by Franchisor in writing. Franchisee shall maintain and display Signs which reflect the current image
of El Pollo Loco® restaurants and shall not place additional Signs at the Restaurant without the prior written consent
of  Franchisor.  Franchisee  shall  discontinue  the  use  of  and  remove,  or  modify,  as  applicable,  such  Signs  that  are
declared  obsolete  by  Franchisor  within  thirty  (30)  days  after  Franchisee’s  receipt  of  Franchisor’s  written  request,
subject  to  reasonable  extension  if  Franchisee  is  unable  after  using  reasonable  diligence  to  obtain  required
governmental approvals for modification of such Signs. Proper signage is fundamental to the El Pollo Loco® System
and Franchisee hereby grants to Franchisor the right to enter the Location, including the Restaurant and any nearby
areas where Signs are displayed, in order to remove and de-identify any unapproved or obsolete Signs in the event
Franchisee has failed to do so within the above-specified time frame.

5.7.    Franchisee is solely responsible for the acts or omissions of its contractors regarding compliance with all
of the provisions of this Section 5, and Franchisor shall have no responsibility for such acts or omissions. Franchisor
shall not be liable for any loss or damage arising from the design or plan of the Restaurant by reason of its approval
of  plans  and  specifications,  or  otherwise.  Franchisee  shall  indemnify  Franchisor  for  any  loss,  cost  or  expense,
including  attorneys'  fees,  that  may  be  sustained  by  Franchisor  because  of  the  acts  or  omissions  of  Franchisee's

contractors or arising out of the design, construction or remodeling of the Restaurant, except to the extent that any
such loss, cost or expense arises as a result of the grossly negligent acts or omissions of Franchisor, its employees
and/or agents.

5.8.    Franchisee shall give to Franchisor at least thirty (30) days prior written notice of the anticipated Opening
Date. Franchisee shall not open the Restaurant to the public until it has received written approval from Franchisor to
open.  If  Franchisee  did  not  deliver  to  Franchisor  a  final  Certificate  of  Occupancy  prior  to  the  Opening  Date,
Franchisee  shall  deliver  to  Franchisor  a  copy  of  an  unconditional  final  Certificate  of  Occupancy  issued  by  the
applicable local governmental entity no later than ninety (90) days following the Opening Date.

6.

FEES, TAXES AND OTHER CHARGES

6.1.    Franchisee shall pay to Franchisor during the term of this Agreement the following:

a.    An initial franchise fee of Forty Thousand Dollars ($40,000.00), in full within 30 days of delivery of
execution copies of this Agreement to Franchisee; provided, however, if the Restaurant is a Turnkey Restaurant the
initial franchise fee shall be payable upon execution of this Agreement. As our sole and absolute right to determine,
you may be offered an Initial Term of less than 20 years and as such, the initial franchise fee will be appropriately pro-
rated.  All  such  payments  shall  be  made  by  cashier's  check  or  other  form  of  payment  acceptable  to  Franchisor.
Franchisee  hereby  acknowledges  and  agrees  that  the  grant  of  this  franchise  constitutes  the  sole  and  only
consideration  for  the  payment  of  the  initial  franchise  fee  and  the  initial  franchise  fee  shall  be  fully  earned  by
Franchisor upon execution of this Agreement. In that regard, upon the payment of any portion of the initial franchise
fee,  the  entire  initial  franchise  fee  shall  be  deemed  fully  earned  and  non-refundable  in  consideration  of  the
administrative  and  other  expenses  incurred  by  Franchisor  in  granting  this  franchise  and  for  Franchisor's  lost  or
deferred opportunity to franchise to others.

b.    A monthly royalty fee equal to five percent (5%) of Franchisee's immediately prior month’s Gross

Sales (as defined in Section 7.1).

c.    A monthly advertising fee, which shall be used in accordance with Section 8, for advertising, public
relations  and  promotion  and  for  the  creation  and  development  of  advertising,  public  relations  and  promotional
campaigns  (“Advertising  Fee”),  in  the  amount  of:  (i)  five  percent  (5%)  of  Franchisee's  immediately  prior  month’s
Gross  Sales,  as  defined  in  Section  7.1  if  the  Restaurant  is  located  outside  of  the  Los  Angeles  (“LA”)  Designated
Market Area ("DMA") or (ii) four percent (4%) of Franchisee's immediately prior month’s Gross Sales, as defined in
Section 7.1 if the Restaurant is located within the Los Angeles DMA. If the Restaurant is located within the LA DMA,
the  Advertising  Fee  may  be  increased,  as  our  sole  and  absolute  right  to  determine,  to  not  more  than  one  percent
(1%)  above  your  original  Advertising  Fee  during  the  Initial  Term  of  your  Franchise  Agreement  and  upon  90  days
written notice to you. Some existing franchisees may pay lower Advertising Fees. Restaurants owned and operated
by us will contribute on the same basis as those existing franchisees within the same DMA. Franchisor also reserves
the  right  to  increase  the  Advertising  Fee  in  the  future  by  a  voting  mechanism.  Except  as  otherwise  provided  in
existing franchise agreements, each operating restaurant (both company-owned and franchised restaurants) located
in the geographical area that would be affected by such an increase in the Advertising Fee shall be entitled to one
vote. Franchisor  must  gain  an  approval  vote  of  fifty-one  percent  (51%)  of  all  such  operating  restaurants  within  the
applicable geographical area. The minimum geographical area that would be affected by such an increase would be
no smaller than a local DMA, although, multiple local DMAs may be involved.

d.    The amount of all sales taxes, use taxes and similar taxes imposed upon or required to be collected
or paid by Franchisor on account of goods or services furnished to Franchisee by Franchisor, whether such goods or
services  are  furnished  by  sale,  lease  or  otherwise.  Franchisee  shall  reimburse  Franchisor  for  the  invoice  amount
within seven (7) days after the invoice has been delivered to Franchisee.

e.    Monthly POP Fees for in-restaurant and drive-thru point-of-purchase materials.

f.    Monthly Gift Card Discount Fees associated with the sale of gift cards (charged to the restaurant that

redeemed the gift cards and earned the sales revenue)

g.    Franchisee’s pro-rata share of costs for the Customer Feedback Program(s).

h.        Re-inspection  fees  per  re-inspection  of  Franchisee’s  Restaurant,  (required  if  a  deficiency  or
unsatisfactory  condition  is  noted  and  a  subsequent  re-inspection  is  necessary  to  determine  if  the  deficiency  or
unsatisfactory condition has been cured) and a Coaching fees (required if Franchisee’s Restaurant has failed two (2)
consecutive inspections or as determined by Franchisor in our sole and absolute right in certain circumstances).

i.    A surcharge of twelve cents ($0.12) for each case of chicken (Whole Birds and Saddles) ordered by
franchise  and  company  operators  as  contributions  to  the  obsolete  inventory  fund  used  to  pay  for  pertinent,  unsold
inventory of qualified suppliers at the conclusion of limited time promotions and to expedite the delivery of products
for situations in which sales exceed prior forecasts. We periodically review the added cost per case and as our sole
and absolute right, determine whether to increase or decrease the cost per case.

6.2.    Franchisee shall pay interest to Franchisor on any amounts which may become due to Franchisor from
Franchisee, if such are not paid when due, at the rate of fifteen percent (15%) per annum (pro-rated) or the maximum
interest rate permitted by law, whichever is less.

7.

FINANCIAL REPORTING, BILLING AND PAYMENT

7.1.    The term "Gross Sales" as used in this Agreement shall mean the total revenues derived by Franchisee
in and from the Restaurant from all sales of food, goods, wares, merchandise and all services, rights, and anything
else of value, made in, upon, or from the Restaurant, whether for cash, check, credit or otherwise, without reserve or
deduction  for  inability  or  failure  to  collect  the  same,  including,  without  limitation,  all  revenues  derived  from  delivery,
catering, and special event sales, such sales and services where the orders therefor originate at and are accepted by
Franchisee  into  the  Restaurant  but  delivery  or  performance  thereof  is  made  from  or  at  any  other  place,  or  other
similar  orders  are  received  or  billed  at  or  from  the  Restaurant,  and  any  sums  or  receipts  derived  from  the  sale  of
meals to employees of the Restaurant. Gross Sales shall not include rebates or refunds to customers; or the amount
of  any  sales  taxes  or  other  similar  taxes  that  Franchisee  collects  from  customers  and  that  are  actually  paid  to  any
federal, state or local taxing authority.

7.2.    Franchisee shall deliver to Franchisor on or before the sixth (6th) calendar day after each close of the
sales month, a monthly Gross Sales statement ("Monthly T-Sheet"), in the form specified by Franchisor, setting forth
the  amount  of  Gross  Sales  for  the  preceding  month  and  a  calculation  of  the  monthly  fees  payable  on  such  sales.
Monthly  fees,  such  as  Royalty  Fees  and  Advertising  Fees,  in  addition  to  other  fees  such  as  POP  Fees,  Gift  Card
Discount  Fees,  Customer  Feedback  Costs  and  Re-Inspection  Fees  (hereinafter  collectively  will  be  referred  to  as
“Fees”) shall be due and payable on the tenth (10th) day after the close of the sales month, which closing shall be
designated by El Pollo Loco® as its sole and absolute right upon ten (10) days advance written notice to Franchisee
(“Sales  Month  Closing”).  Franchisee  shall  make  all  payments  due  hereunder  by  pre-arranged  draft  or  sweep  of
Franchisee’s  business  bank  operating  account  (“ACH”). Franchisee  will  give  Franchisor  authorization  in  the  format
set forth in the Authorization Agreement for Prearranged Payments, Exhibit 4 attached hereto for direct debits from
Franchisee’s  business  bank  operating  account  (the  “Operating  Account”).  Franchisee  acknowledges  it  is
Franchisee’s  responsibility  to  notify  Franchisor  of  any  changes  to  the  bank  operating  account  in  a  timely  fashion.
Franchisor may choose, as its sole and absolute right, to accept other forms of payment including check, cashier’s
check and Electronic Funds Transfer (“EFT”). Franchisee will contribute to the Obsolete Inventory Fund as described
above. Contributions are payable to the vendor at the time of inventory purchase.

7.3.    If Franchisee is delinquent in any payment of such Fees, or if Franchisee has not submitted the Monthly
T-Sheet for more than a two-month period when due, Franchisor may, as its sole and absolute right initiate an ACH
or/and EFT transfer from the Operating Account an estimated amount of Fees due Franchisor for such period which
shall be based on the average of the immediately preceding three (3) months’ Gross Sales. If, at any time, Franchisor
determines that Franchisee has under-reported the monthly Gross Sales of the Restaurant, or underpaid the monthly
royalty,  advertising  Fees,  DMA  Advertising  Fee,  or  other  amounts  due  to  Franchisor  under  this  Agreement,  or  any
other  agreement,  Franchisor  may,  in  addition  to  exercising  all  other  rights  and  remedies  available  to  it  under  this
Agreement,  initiate  an  immediate  transfer  from  the  Operating  Account  in  the  amount  equal  to  the  unpaid  Fees  in

accordance  with  the  foregoing  procedure,  including  interest  as  provided  in  Section  6.2  above.  Any  overpayment  of
Fees  will  be  credited  to  the  Operating  Account  effective  as  of  the  first  Due  Date  after  Franchisor  and  Franchisee
determine that such credit is due.

7.4.        In  connection  with  payment  of  the  monthly  Fees  by  ACH  or  EFT,  Franchisee  shall:  (1)  comply  with
procedures  specified  by  Franchisor  relating  to  ACH  or  EFT  transfers;  (2)  perform  those  acts  and  sign  and  deliver
those documents as may be necessary to accomplish payment by ACH or EFT as described in Section 7.2 and 7.4;
(3)  give  Franchisor  an  authorization  in  the  form  designated  by  Franchisor  to  initiate  debit  entries  and/or  credit
correction  entries  to  the  Operating  Account  for  payments  of  the  monthly  royalty  and  advertising  Fees,  or  other
amounts  due  to  Franchisor  under  this  Agreement,  or  any  other  agreement,  including  any  interest  charges;  and  (4)
make  sufficient  funds  available  in  the  Operating  Account  for  withdrawal  by  ACH  or  EFT  of  Fees  due  no  later  than
each Due Date.

7.5.    In addition to the sales data required to be provided in the Monthly T-Sheet to be delivered pursuant to
Section 7.2, Franchisee shall deliver (in the manner prescribed by Franchisor) to Franchisor on or before the tenth
(10th) day after the end of each sales month during the term of this Agreement any other sales and menu mix data
reasonably requested by Franchisor with respect to the preceding sales month, whether specified in the Manual or
otherwise.

7.6.    Thirty (30) days after the end of each calendar quarter and one hundred twenty (120) days after the end
of each calendar year during the term of this Agreement, Franchisee shall provide to Franchisor a financial statement
of the franchise business which shall include such information and data as specified in the financial reporting format
set  forth  in  Exhibit  6  attached  hereto  or  in  such  other  format  reasonably  approved  by  Franchisor.  Such  fiscal
year‑end  financial  statements  must  be  signed  by  Franchisee,  Franchisee's  treasurer  or  Franchisee's  chief  financial
officer  and  contain  a  representation  that  the  financial  statements  present  fairly  the  financial  position  of  Franchisee
and the results of operations of the franchise business during the period covered.

7.7.    Franchisee shall make all payments when due to third parties for obligations arising out of or in any way
connected  with  the  existence,  operation  or  maintenance  of  the  Restaurant,  including,  but  not  limited  to,  rental  and
mortgage payments and payments for utilities, services, products, equipment, supplies, goods, inventory, materials,
taxes, labor and other matters. In the event that Franchisee fails to make any such payment in accordance with the
foregoing and the nonpayment results or may reasonably result in a condition or event which threatens public safety
or  health  or  which  may  materially  and  adversely  affect  the  ownership,  condition  or  operation  of  the  Restaurant,  in
either case in the reasonable judgment of Franchisor, Franchisor shall have the sole and absolute right, after five (5)
days  written  notice  to  Franchisee,  but  not  the  obligation,  to  make  such  payment  on  behalf  of  Franchisee.  Such
payment shall be without prejudice and in addition to all other available rights and remedies. Any payment made by
Franchisor  pursuant  to  this  Section  7.7  shall  be  paid  by  Franchisee  to  Franchisor  as  an  additional  amount  for  the
monthly billing period in which such payment is made by Franchisor.

7.8.        Franchisee  shall  maintain  accurate  and  complete  books  and  records  pertaining  to  the  operation  and
maintenance of the  Restaurant  as  required  by  the  standards,  policies  and procedures established by Franchisor in
accordance with the Manual. Franchisee shall be solely responsible for performing all record keeping duties, and the
cost for all such services shall be borne solely by Franchisee.

7.9.        Franchisee  shall  obtain,  install,  and  use  the  computer  system  that  Franchisor  requires  or  approves  in
writing. The term “Computer System” means communications, computer systems, and hardware to be used by the
Restaurant, including (a) back office and point of sale systems, (b) cash register systems; (c) physical, electronic, and
other security systems; (d) printers and other peripheral devices; (e) archival back-up systems; and (f) internet access
mode (for example, Franchisee’s telecommunications connection). In connection with the Computer System:

a.        Franchisee  must  obtain,  install,  and  use  the  computer  software  programs  required  by  Franchisor
(the  “Required  Software”)  from  time  to  time.  Franchisee  must  utilize  any  proprietary  software  program  that
Franchisor may develop internally or with the assistance of outside suppliers or consultants or that Franchisor may
license for use by the El Pollo Loco® System.

b.    Franchisor may modify specifications for and components of the Computer System and Required
Software.  The  Computer  System  and  Required  Software  must  be  purchased  or  leased  from  Franchisor  or  from
suppliers  approved  by  Franchisor,  and  must  be  installed  by  Franchisor  or  by  suppliers  approved  by  Franchisor  at
Franchisee’s  expense.  (Franchisor  may  be  the  only  approved  supplier  of  the  Computer  System  and  Required
Software.)  All  Computer  System  components  must  be  installed  in  accordance  with  Franchisor’s  standards  and
procedures. Franchisor’s modification of specifications for the Computer System and Required Software may require
Franchisee, at Franchisee’s expense, to purchase, lease, and/or license new or modified computer hardware and/or
software and/or communications capabilities. Franchisee will not be required to replace the Computer System more
than  once  every  four  (4)  years  during  the  term  of  this  Agreement.  Franchisee  shall  be  required  to  enter  into  an  El
Pollo  Loco®  IT  Support  Services  Agreement  (a  “Support  Agreement”)  in  connection  with  the  operation  of  the
Computer System. The Support Agreement is attached to this Agreement as Exhibit 7.

c.        The  Computer  System  is  for  use  by  Franchisee  only  in  connection  with  operational  and
management  tasks  of  the  Restaurant.  Franchisee  may  not  use  the  Computer  System  for  email,  word  processing,
spreadsheets,  web  surfing,  or  any  other  personal  application  or  purpose  not  approved  in  writing  by  Franchisor
(“Personal  Applications”).  However,  Franchisee  may  run  such  Personal  Applications  on  a  separate  personal
computer  and  network  provided  by  Franchisee,  but  the  personal  computer  and  network  must  run  in  “stand  alone,
isolated  mode”  and  Franchisee  must  not  interconnect  such  computer(s)  with  the  Computer  System.  Franchisor
reserves  the  right  require  Franchisee  to  shut  down  Personal  Applications  interfaces  if  Franchisor  determines  that
such  interfaces  interfere  with  the  Computer  System  operations,  or  the  operation  of  the  Restaurant.  In  addition,
Franchisee will only install Franchisor approved Wi-Fi hardware to ensure security and controls are in place to protect
and segment networks.

d.    Franchisor shall have the right from time to time, and at any time, to retrieve data and information
from  Franchisee’s  Computer  System,  by  modem  or  other  means,  and  use  it  for  any  reasonable  business  purpose
both  during  and  after  the  term  of  this  Agreement.  Franchisor  may,  from  time  to  time,  specify  in  the  Manual  or
otherwise  in  writing  the  information  that  Franchisee  shall  collect  and  maintain  on  the  Computer  System,  and
Franchisee shall provide to Franchisor such reports as Franchisor may reasonably request from the data so collected
and maintained.

7.10.    All of the accounts, books, records and federal, state and local tax returns and reports of Franchisee, so
far  as  they  pertain  to  the  business  transacted  under  this  Agreement,  shall  be  open  to  inspection,  examination  and
audit  by  Franchisor  and  its  authorized  representatives  at  any  and  all  times,  and  copies  thereof  may  be  made  by
Franchisor and retained for its own use. All of such records shall be maintained and retained by Franchisee for seven
(7)  years,  and  following  the  termination  or  expiration  of  this  Agreement,  the  books  and  records  for  the  preceding
seven (7) years shall be maintained and retained by Franchisee for five (5) years. Franchisor may inspect, examine
audit and copy any and all books and records of the Franchisee’s business. Any such inspection, examination and
audit  shall  be  at  Franchisee's  cost  and  expense  as  a  result  of  Franchisee's  failure  to  prepare  and  deliver  its
transmittal  reports  to  Franchisor  as  required  herein,  or  to  maintain  books  and  records  as  hereinabove  provided,  or
unless any such transmittal report is determined to be in error to an extent of two percent (2%) or more for the period
audited.  Any  such  cost  and  expense  shall  be  set  forth  in  a  written  invoice  delivered  to  Franchisee  by  Franchisor.
Franchisee  shall  reimburse  Franchisor  for  the  invoice  amount  within  seven  (7)  days  after  the  invoice  has  been
delivered to Franchisee.

7.11.    Franchisee shall sell or otherwise issue the stored value cards or gift cards and certificates (together
“Gift Cards”) that have been prepared utilizing the standard form of Gift Card provided or designated by Franchisor,
and only in the manner specified by Franchisor in the Manual or otherwise in writing. Franchisee shall fully honor all
Gift Cards that are in the form provided or approved by Franchisor regardless of whether a Gift Card was issued by
Franchisee or another Restaurant or purchased at any other location including without limitation, retail stores, internet
sales or other means of distribution. Franchisee shall sell, issue, and redeem (without any offset against any royalty
fees)  Gift  Cards  in  accordance  with  procedures  and  policies  specified  by  Franchisor  in  the  Manual  or  otherwise  in
writing  (the  “Gift  Card  Program”),  including  those  relating  to  procedures  by  which  Franchisee  shall  request
reimbursement  for  Gift  Cards  issued  by  other  Restaurants  and  for  making  timely  payment  to  Franchisor,  other
operators of Restaurants, or a third-party service provider for Gift Cards issued from the Restaurant that are honored
by Franchisee, Franchisor or other Restaurant operators. Franchisee  acknowledges  and  agrees  that,  in  connection
with the Gift Card Program, Franchisee may be required to:

a.    Enter into a separate agreement with a third party provider of Gift Card services under the terms

and conditions as may reasonably be required by such third party for participation in the Gift Card Program;

b.    Purchase and maintain a sufficient number of Gift Cards, in a form approved by Franchisor, as may

reasonably be required for participation in the Gift Card Program;

c.    Purchase or upgrade, as applicable, such hardware, software and equipment as shall be necessary

to participate in the Gift Card Program;

d.        Promote  and  sell  the  Gift  Cards  in  Franchisee’s  Restaurants  using  only  marketing  methods  and

materials approved by Franchisor;

e.        Comply  in  all  material  respects  with  all  applicable  laws,  statutes  and  regulations  in  performing
Franchisee’s obligations under this Agreement and otherwise in connection with Franchisee’s participation in the Gift
Card Program; and

f.    Execute such forms or documents or take such other actions reasonably necessary or requested by

Franchisor to effectuate Franchisee’s participation in the Gift Card Program.

7.12.       Franchisee acknowledges and agrees that Franchisor reserves the right to discontinue or modify the
Gift  Card  Program  at  any  time,  as  its  sole  and  absolute  right.  Upon  receipt  of  written  notice  from  Franchisor  of  its
intent to discontinue or modify the Gift Card Program, Franchisee shall, as applicable, immediately cease offering and
accepting Gift Cards and/or make such modifications as Franchisor shall require.

7.13.        Franchisee  shall  participate  in  the  Remote  Ordering  Program,  Loyalty  Program,  Third  Party  Delivery
Program,  Self-Order  Kiosk  Program  and  Call  Center  Program  (collectively  referred  to  as  “Programs”)  Franchisee
shall  comply  with  procedures  and  policies  of  the  Programs  specified  by  Franchisor  in  the  Manual  or  otherwise  in
writing  including  those  relating  to  making  timely  payment  to  third-party  service  providers  for  such  Programs.
Franchisee acknowledges and agrees that, in connection with the Programs, Franchisee may be required to:

a.    Enter into a separate agreement with third party service providers of the Programs under the terms

and conditions as may reasonably be required by such third parties for participation in the Programs;

b.    Purchase or upgrade, as applicable, such hardware, software and equipment as shall be necessary

to participate in the Programs;

c.        Comply  in  all  material  respects  with  all  applicable  laws,  statutes  and  regulations  in  performing
Franchisee’s  obligations  under  this  Agreement  and  otherwise  in  connection  with  Franchisee’s  participation  in  the
Programs; and

d.    Execute such forms or documents or take such other actions reasonably necessary or requested by

Franchisor to effectuate Franchisee’s participation in the Programs.

7.14.       We may discontinue or modify the Programs at any time, and upon receiving notice from us that we

intend to do so, you must immediately cease the Programs or make the modifications that we require.

7.15.        Franchisee  acknowledges  and  agrees  that  it  is  in  the  best  interest  of  the  business  conducted  at  the
Restaurant and the System as a whole, to participate in the Payment Card Industry (“PCI”) Data Security Standard
(“DSS”)  Program  offered  through  a  third  party  vendor.  This  is  a  set  of  security  requirements  that  uses  current
technology and physical security best practices to protect credit cardholder data. The size of Franchisee’s business
and  the  number  of  transactions  processed  by  Franchisee  will  determine  Franchisee’s  specific  requirements  for
achieving PCI compliance. Currently, the monthly cost of quarterly firewall scans is included with the Micros Platinum

service monthly fees, however such monthly cost may increase as detailed in the El Pollo Loco® IT Support Services
Agreement,  attached  and  incorporated  herein  as  Exhibit  7.  If  Franchisee  is  found  to  be  non-compliant  with  the
PCI/DSS  and  remediation  is  required,  a  third  party  vendor  will  work  directly  with  Franchisee  to  resolve  any
outstanding issues and Franchisee may have to pay additional fees. All franchisees are required to participate in this
program from a third party vendor as to which we, as our sole and absolute right, may require approval. Franchisee
further promises that the results of the PCI review of Franchisee’s operations, in so far as they pertain to the business
transacted under this Agreement, shall be open to inspection, examination and audit by Franchisor and its authorized
representatives at any and all times, and copies thereof may be made by Franchisor and retained for its own use. All
of such records shall be maintained and retained by Franchisee as required by the PCI DSS. Franchisee understands
and agrees that Franchisee is solely responsible for meeting the requirements for the PCI DSS Program. Failure to
do so shall be considered grounds for termination of this Agreement as provided in Section 18 hereof.

8.

ADVERTISING AND MARKETING

8.1.        Recognizing  the  value  of  marketing  and  advertising  to  the  goodwill  and  public  image  of  the  El  Pollo
Loco® System, Franchisor administers funds for advertising, public relations, marketing research and promotion into
which  franchisees  contribute  an  “Advertising Fee”.  El  Pollo  Loco®  restaurants  owned  and  operated  by  Franchisor
contribute on the same basis as franchisees within the same DMA.

8.2.       The entire Advertising  Fee  will  be  deposited  into  the  Advertising  Fund to be allocated as Franchisor’s

sole and absolute right.

8.3.        Franchisor  shall  have  the  sole  and  absolute  right  to  determine  the  expenditures,  investments  and  all
aspects of activities funded by the Advertising Fund, including media plans and buying, creative concepts, materials,
endorsements and agency relationships. The Advertising Fund may be used to pay for production costs for materials
and programs Franchisor chooses, including advertising agency fees, market research, concept development, design
development (store prototypes and advertising), product research and development, video, audio, electronic, written
advertising  materials,  media  and  public  relations  programs.  The  Advertising  Fund  will  be  accounted  for  separately
from Franchisor’s other funds. Although it has been Franchisor’s practice to spend all advertising funds in the fiscal
year in which they are collected, Franchisor reserves the right to spend such advertising funds in the next fiscal year
to the extent Franchisor deems appropriate. Franchisor may spend in any fiscal year an amount greater or less than
the  aggregate  contributions  made  by  El  Pollo  Loco®  restaurants  to  the  Advertising  Fund  in  that  year,  and  the
Advertising Fund may borrow from Franchisor or from other lenders to cover deficits in the Advertising Fund or cause
the  Advertising  Fund  to  invest  any  surplus  for  future  use  by  the  Advertising  Fund.  Upon  request,  but  not  more
frequently than annually, Franchisor will  provide  Franchisee  with  a  written  description  of  the  expenditures  made  by
the Advertising Fund during the fiscal year immediately preceding the request of the advertising fees received from
franchisees. The statement of expenditures is not required to be audited.

8.4.    If Franchisee is located outside the Los Angeles DMA, as Franchisor’s sole and absolute right, a portion
of Franchisee’s Advertising Fee may be allocated to a Local Advertising Fund (“LAF”) pertaining to the Restaurant.
Franchisee  will  be  required  to  pay  the  Advertising  Fee  to  Franchisor  at  the  same  time  as  Franchisee’s  royalty
payments  pursuant  to  the  Authorization  Agreement  for  Prearranged  Payments  (Exhibit  4  to  the  Franchise
Agreement). Franchisee  must  use  current  approved  vendors  for  Franchisee’s  advertising  order,  and  Franchisor  will
pay the approved vendor directly upon approval of the order and confirmation of receipt of the order with Franchisee.
The  LAF  monies  will  also  be  used  to  reimburse  Franchisee  for  the  cost  of  implementing  local  marketing  plans
developed  by  Franchisee  and  approved  by  Franchisor  (up  to  an  amount  not  to  exceed  the  LAF  contributions
collected). The LAF monies will be used to reimburse Franchisee for the cost of implementing local marketing plans
developed  by  Franchisee  and  approved  by  Franchisor  in  writing.  For  these  purposes,  qualifying  LAF  expenditures
include, but are not limited to: (a) amounts contributed to Advertising Associations (defined below); and (b) amounts
spent  for  advertising  media,  such  as  television,  radio,  newspaper,  billboards,  posters,  direct  mail,  collateral  and
promotional items, advertising on vehicles (excluding the cost of any vehicle), and, if not provided by Franchisor, the
cost  of  producing  approved  materials  necessary  to  participate  in  such  media.  Non-qualifying  LAF  expenditures
include amounts spent for items which Franchisor, in its reasonable judgment, deems inappropriate for meeting the
minimum advertising requirement, including, but not limited to: permanent on-premises Signs and traditional or digital
menu  boards,  transportation  vehicles,  marketing  personnel  salaries,  public  relations  or  advertising  agency  retainer,
highway signs or any other signage for directional purposes only, store labor costs associated with the execution of
any marketing program, lighting, administrative costs, Yellow Pages advertising, discounts/coupons offers, free offers,
employee incentive programs, and any unapproved marketing or advertising materials.

8.5.        Franchisee  shall  not  engage  in  any  advertising  activities  without  Franchisor’s  prior  written  consent.
Should Franchisee submit advertising that is not approved by Franchisor, Franchisee will be required to revise and
resubmit  such  advertising  again  for  written  approval,  prior  to  use  of  such  advertising.  Franchisee  shall  submit  to
Franchisor  for  Franchisor’s  prior  approval,  at  least  thirty  (30)  days  prior  to  the  beginning  of  each  fiscal  year,  a
marketing plan for Franchisee’s DMA. This marketing plan may be submitted by all franchisees in Franchisee’s DMA
through an area advertising association. If Franchisee is using materials not prepared by Franchisor and which vary
from Franchisor’s standard advertising and promotional materials, such materials must be submitted to Franchisor for
approval no less than forty-five (45) days prior to the beginning of such promotion or program. Franchisor will review
any  materials  submitted  for  Franchisor’s  approval  within  ten  (10)  business  days  of  receipt  of  such  materials.
Franchisee shall not use any advertising or promotional materials that Franchisor has disapproved, or that Franchisor
has not approved.

8.6.    Franchisor shall have the right to establish local and/or regional advertising associations (“Advertising
Associations”) for El Pollo Loco® restaurants in Franchisee’s local or regional area, covering the geographic areas
Franchisor  may  designate  from  time  to  time.  Franchisor  has  the  right  to  form,  change,  dissolve  or  merge  the
Advertising Associations. If Franchisor has established an Advertising Association in Franchisee’s DMA, Franchisee
must  participate  in  the  Advertising  Association  and  its  programs  and  abide  by  its  by-laws.  Each  El  Pollo  Loco®
restaurant located within the area governed by the Advertising Association will have one (1) vote. Franchisee must
contribute the amounts to the Advertising Association(s) as determined by the Advertising Association members from
time  to  time  in  accordance  with  their  bylaws.  Any  El  Pollo  Loco®  Restaurant  owned  by  Franchisor  in  Franchisee’s
DMA  or  regional  market  area(s)  will  contribute  to  the  Advertising  Association  on  the  same  basis  as  Franchisee
contributes for its Restaurant. Contributions to the local and regional Advertising Associations are credited toward the
LAF  advertising  expenditures  required  pursuant  to  Section  8.4  above;  however,  if  Franchisor  provides  Franchisee
and Franchisee’s Advertising Association ninety (90) days’ notice of a special promotion, including, but not limited to,
any regional promotions, Franchisee must participate in the promotion and also pay Franchisor any special promotion
advertising  fees  assessed  in  connection  with  the  program,  beginning  on  the  effective  date  of  the  notice  and
continuing until the special promotion is concluded. Any special promotion advertising fees will be in addition to, and
not  credited  towards,  the  LAF  advertising  expenditure  required  pursuant  to  Section  8.4  above.  The  Advertising
Association  Membership  Agreement  is  attached  to  this  Agreement  as  Exhibit  5.  Franchisor  may  administer  the
Advertising  Associations  and  collect  Franchisee’s  Advertising  Association  contributions  by  automatic  electronic
withdrawal.

8.7.    Franchisor shall be under no obligation to use the Advertising Fund to advertise equally for all markets or
for  all  DMAs.  All  advertising  fee  contributions  from  Franchisor-operated  restaurants  shall  be  deposited  in  the
Advertising  Fund.  Franchisor  shall  be  under  no  obligation  to  determine  the  incremental  cost  of  franchise  sales
advertising and investor relations sections of any internet web sites established by Franchisor and funded in whole or
in part by the Advertising Fund.

8.8.        In  addition  to  Advertising  Fees  payable  pursuant  to  Section  6.1  of  this  Agreement,  Franchisee  shall
expend  $5,000.00  per  Restaurant  to  conduct  grand  opening  advertising  and  local  store  marketing  and  promotion
programs for Franchisee’s Restaurant, utilizing advertising and promotional materials approved by Franchisor. Such
grand  opening  advertising  shall  be  conducted  in  accordance  with  Franchisor’s  specifications  and  standards  and  in
accordance  with  a  grand  opening  plan  (which  will  cover  advertising  and  promotion  for  the  15  days  prior  to  the
Opening  Date  and  45  days  following  the  Opening  Date)  which  Franchisee  prepares  and  submits  to  Franchisor  for
approval at least 30 days prior to the anticipated Opening Date. Franchisee shall submit to Franchisor not later than
15  days following  the  conclusion  of such  grand  opening  promotion,  written receipts and other evidence reasonably
satisfactory to Franchisor evidencing all amounts spent by Franchisee to conduct the grand opening promotion.

9.

INSURANCE AND INDEMNIFICATION

9.1.        Throughout  the  term  hereof,  Franchisee  shall  obtain  and  maintain  insurance  coverage  with  insurance
carriers  acceptable  to  Franchisor  in  accordance  with  Franchisor's  current  insurance  requirements  as  modified  from
time to time. The coverage shall commence when the Location is secured by Franchisee by executed deed or lease
and shall comply with the requirements of Franchisee's lease, if any, for product liability and broad form contractual
liability coverage in the amount of at least two million dollars ($2,000,000.00) combined single limit and not less than
$1,000,000.00  per  occurrence.  Franchisee  shall  also  carry  property  and  extended  coverage  insurance  with  a
maximum  deductible  of  $10,000.00  and  with  endorsements  for  vandalism  and  malicious  mischief,  covering  the

building,  structures,  equipment,  improvements  and  the  contents  thereof  in  and  at  the  Restaurant,  on  a  full
replacement  cost  basis,  insuring  against  all  risks  of  direct  physical  loss  (except  for  unusual  perils  such  as  nuclear
attack,  earth  movement  and  war),  and  business  interruption  insurance  sustained  form  covering  the  rental  of  the
Location, previous profit margins, maintenance of competent personnel and other fixed expenses. Franchisee shall
also carry such worker's compensation insurance as may be required by applicable law. In connection with and prior
to  commencing  any  construction,  reimage  or  remodeling  of  the  Restaurant,  Franchisee  shall  maintain  Builder's  All
Risks Insurance and performance and completion bonds in forms and amounts, and written by a carrier or carriers,
acceptable to Franchisor. As proof of such insurance, a certificate of insurance shall be submitted by Franchisee for
Franchisor's approval  prior  to  Franchisee's  commencement  of  any  activities or services to be performed under this
Agreement.  Franchisee  shall  deliver  a  complete  copy  of  Franchisee's  then‑prevailing  policies  of  insurance  to
Franchisor within thirty (30) days following the delivery of the certificate of insurance.

9.2.        Franchisor  shall  be  named  as  an  additional  insured  on  all  of  such  policies  referenced  in  Section  9.1
above to the extent of its interests and shall be provided by Franchisee with certificates of insurance evidencing such
coverage prior to the Opening Date and promptly following the date any policy of insurance is renewed, modified or
replaced during the term of this Agreement. All policies must contain provisions denying to the insurer acquisition of
rights of recovery against any named insured by subrogation. All coverages shall be placed with a financially stable
insurer  with  a  minimum  AM  Best  Ratings  of  A-VII.  All  public  liability  and  property  damage  policies  shall  contain  a
provision that Franchisor,  although  named  as  an  additional  insured,  shall nevertheless be entitled to recover under
such policies on any loss occasioned to it, its affiliates, officers, agents and employees by reason of the negligence of
Franchisor, Franchisee,  or  their  respective  principals,  contractors,  agents or employees. All  policies  shall  extend  to
and provide indemnity for all obligations assumed by Franchisee hereunder and all other items for which Franchisee
is required to indemnify Franchisor under the provisions of this Agreement, whether or not the liability arose from the
negligence of Franchisor, its principals, contractors, agents or employees, and shall provide Franchisor with at least
thirty (30) days prior written notice of cancellation, termination or material reduction of coverage. Franchisor reserves
the  right  to  specify  reasonable  changes  (which  may  include  increases)  in  the  types  and  amounts  of  insurance
coverage  required  by  this  Section  9.  Should  Franchisee  fail  or  refuse  to  procure  the  required  insurance  coverage
from an insurance carrier acceptable to Franchisor or to maintain it throughout the term of this Agreement, Franchisor
may as its sole and absolute right, but without any obligation to do so, obtain such coverage for Franchisee, in which
event Franchisee shall pay on demand the required premiums and any related fees or costs (such as, but not limited
to, broker’s fees, taxes or service fees) or reimburse Franchisor therefore. The  amount  of  such  premiums  and  any
related  fees  or  costs  shall  be  set  forth  in  a  written  invoice  delivered  to  Franchisee  by  Franchisor.  Franchisee  shall
reimburse Franchisor for the invoice amount within seven (7) days after the invoice has been delivered to Franchisee
pursuant  to  Section  23.3  of  this  Agreement.  Failure  to  maintain  the  required  insurance  or  to  promptly  reimburse
Franchisor for any premiums and any related fees or costs paid on behalf of Franchisee by Franchisor shall constitute
a  default  hereunder.  Should  Franchisor  elect  to  obtain  such  coverage  for  Franchisee,  then  Franchisee  will  assist
Franchisor  by  providing  the  necessary  information  and  access  to  enable  Franchisor  to  obtain  coverage  for
Franchisee.  In  the  event  of  any  claim,  lawsuit,  complaint,  cross  complaint,  arbitration,  demand,  allegation,  or  liens
and  damages  (collectively  “Claim”),  Franchisee  shall  immediately  notify  Franchisor  in  writing  of  the  Claim  and  the
facts surrounding such Claim pursuant to Section 23.3 of this Agreement.

9.3.    Franchisee shall defend immediately upon tender of defense, at its own cost, Franchisor, its subsidiaries,
parent and affiliates, shareholders, directors, officers, employees and agents (collectively referred to, for this Sections
9.3  and  9.4  only,  as  “Franchisor”),  from  and  against  any  and  all  claims,  lawsuits,  complaints,  cross  complaints,
arbitrations,  demands,  allegations,  costs  embraced  by  indemnity,  loss,  costs,  expenses  (including  attorneys’  fees),
liens  and  damages  (collectively  referred  to,  for  Sections  9.3  and  9.4  only,  as  “Losses”),  however  caused,  and
reimburse Franchisor for all costs and expenses (including attorneys’ fees) incurred by Franchisor in defense of any
Losses, resulting directly or indirectly from or pertaining to or arising out of, or alleged to arise out of, or in connection
with the use, operation, maintenance, condition, construction, equipment, decorating, signage (including traditional or
digital  menu  boards),  sidewalks,  exterior,  interior,  parking  lot,  food  preparation,  sales  and  service  of  Franchisee’s
restaurant,  including  any  labor,  any  employee  related  claims  whatsoever,  including,  without  limitation  any  claims
made  by  an  employee  of  Franchisee  resulting  from  the  employee’s  training  in  a  Franchisor  operated  facility  or
restaurant,  and  including  Franchisee’s  failure  for  any  reason  to  fully  inform  any  third  party  of  Franchisee’s  lack  of
authority to bind Franchisor for any purpose. Such Losses shall include, without limitation, those arising from latent or
other defects in the restaurant whether or not discoverable by Franchisor, and those arising from the death of or injury
to  any  person  or  arising  from  damage  to  the  property  of  Franchisee  or  Franchisor,  or  any  third  person,  firm  or
corporation, whether or not resulting from any strict liability imposed by fact, law, statute, or ordinance, on Franchisor.
Franchisee  further  agrees  that  Franchisee’s  duty  to  defend  Franchisor  is  separate  from,  independent  of  and  free-
standing  of  Franchisee’s  duty  to  indemnify  Franchisor  and  applies  whether  the  issue  of  Franchisee’s  negligence,
breach of contract, or other fault or obligation has been determined. Franchisee’s duty to defend is regardless of the

outcome of liability even if Franchisee is ultimately found not negligent and not dependent on the ultimate resolution
of  issues  arising  out  of  any  claims,  lawsuits,  complaints,  cross  complaints,  arbitration,  demands,  allegations,  costs
embraced by indemnity, loss, costs, expenses (including attorneys’ fees), liens or damages.

9.4.    Franchisee shall indemnify and hold harmless Franchisor from and against any and all Losses, however
caused, resulting directly or indirectly from or pertaining to or arising out of or in connection with the use, operation,
maintenance,  condition,  construction,  equipment,  decorating,  signage  (including  traditional  or  digital  menu  boards),
sidewalks, exterior, interior, parking lot, food preparation, sales and service of Franchisee’s restaurant, including any
labor,  any  employee  related  claims  whatsoever,  including,  without  limitation  any  claims  made  by  an  employee  of
Franchisee  resulting  from  the  employee’s  training  in  a  Franchisor  operated  facility  or  restaurant,  and  including
Franchisee’s failure for any reason to fully inform any third party of Franchisee’s lack of authority to bind Franchisor
for  any  purpose.  Such  Losses  shall  include,  without  limitation,  those  arising  from  latent  or  other  defects  in  the
restaurant whether or not discoverable by Franchisor, and those arising from the death of or injury to any person or
arising from damage to the property of Franchisee or Franchisor, or any third person, firm or corporation, whether or
not resulting from any strict liability imposed by fact, law, statute, or ordinance, on Franchisor. Franchisee further shall
indemnify and hold harmless Franchisor from all said Losses and shall pay for and be responsible for all said Losses,
however caused, whether by any individual, employee, third person or party, vendor, visitor, invitee, trespasser or any
firm  or  corporation  whatsoever,  whether  caused  by  or  contributed  to  by  Franchisor,  the  combined  conduct  of
Franchisee  and  Franchisor,  or  active  or  passive  negligence  of  Franchisor,  but  for  the  sole  negligence  or  willful
misconduct of Franchisor.

10.

VENDING MACHINES

10.1.        Franchisee  shall  not  install  a  video  game  machine,  juke  box,  cigarette  machine,  public  telephone  or
other type of vending machine or device, whether or not coin operated in the Restaurant, or on its premises, without
prior written approval of Franchisor, which approval will be granted or denied as Franchisor’s sole and absolute right.
The revenues received by Franchisee from any approved machines shall be included in Franchisee's Gross Sales.

11.

COMPLIANCE WITH MANUAL AND WITH SYSTEM STANDARDS

11.1.        Franchisee  acknowledges  and  agrees  that  strict  and  continued  adherence  by  Franchisee  to
Franchisor's  standards,  policies,  procedures  and  requirements,  as  set  forth  in  this  Section  11,  is  required  and  that
failure  on  the  part  of  Franchisee  to  so  perform  will  be  grounds  for  termination  of  this  Agreement  as  provided  in
Section 18 hereof. Franchisee acknowledges that changes, modifications, deletions and additions to the standards,
specifications, procedures and menu items comprising the El Pollo Loco® System may be necessary and desirable
from  time  to  time.  Franchisor  may  make  such  modifications,  revisions,  deletions  and  additions,  including  without
limitation modifications, revisions, deletions and additions to the Manual and to the menu items required to be offered
by  Franchisee,  which  Franchisor,  in  good  faith  and  exercising  its  judgment  believes  to  be  desirable.  Franchisee
agrees  to  comply  with  any  such  modification,  revision,  deletion  or  addition  as  of  the  date  that  such  modification,
revision,  deletion  or  addition  becomes  effective.  Franchisee  acknowledges  that  it  shall  receive  one  (1)  copy  of  the
Manual for the Restaurant on loan from Franchisor and that the Manual shall at all times remain the sole property of
Franchisor. Franchisee  understands  that  Franchisor  has  entered  into  this  Agreement  in  reliance  upon  Franchisee's
representation  that  it  will  strictly  comply  with  all  the  provisions  of  the  Manual.  For  purposes  of  this  Agreement,  the
Manual  shall  be  deemed  to  include  all  written  directions  delivered  to  Franchisee  by  Franchisor  from  time  to  time
setting forth standards, specifications and procedures for the operation of Franchisee's El Pollo Loco® restaurant.

11.2.        Franchisee  acknowledges  and  agrees  that  it  is  in  the  best  interest  of  the  business  conducted  at  the
Restaurant to prepare and serve food in the Restaurant only from ingredients which meet the product specifications
as  communicated  by  Franchisor  to  Franchisee  from  time  to  time  (the  "Specifications"),  and  Franchisee  further
promises  that  all  products,  equipment,  goods,  inventory  and  supplies  used  in  connection  with  the  Restaurant  will
comply with the Specifications. Furthermore, Franchisee shall not offer or sell any product, service or other item at
the Restaurant except those prior approved in writing by Franchisor.

a.        All  menu  items  shall  be  made  in  strict  compliance  with  Franchisor's  written  recipes  and

requirements, which Franchisor may change from time to time by amendments to the Manual.

b.        Franchisee  acknowledges  and  agrees  that  all  proprietary  El  Pollo  Loco®  marinades,  marinade
mixes and marinated ingredients used in the preparation of the required and approved El Pollo Loco® food products
are unique. Their formulae and the process of their manufacture constitute trade secrets. Franchisee shall purchase
such marinades, marinade mixes and marinated ingredients exclusively from Franchisor or, as Franchisor's sole and
absolute right to determine, from Franchisor's designated distributor. The right to purchase and use such marinades,
marinade  mixes  and  marinated  ingredients  is  licensed  to  Franchisee  pursuant  to  this  Agreement,  and  such  right  is
restricted to use in the franchise business at the Restaurant and solely for the term of this Agreement.

11.3.    Throughout the term of this Agreement, Franchisee shall be actively engaged in the management and
day-to-day  operation  of  the  Restaurant.  Franchisee  may  appoint  an  Operations  Director  to  supervise  all  franchise
activities.  If  Franchisee  appoints  an  Operations  Director,  such  appointment  is  subject  to  Franchisor’s  prior  written
approval and the Operations Director must satisfactorily complete the EPL management training program and have
received the ServSafe® certification; and Franchisee must complete either the EPL management training program or
the Executive Franchisee Training Program. The Operations Director shall be actively engaged in the management
and  day  to  day  operations  of  the  restaurant  and  devote  full  time  and  best  efforts  to  the  supervision  of  EPL
Restaurant(s) owned by Franchisee. If at any time, for any reason, the Operations Director ceases to perform those
duties on behalf of the Restaurant(s), Franchisee shall appoint a new Operations Director within 30 days subject to
Franchisor’s prior written approval, and the newly appointed Operations Director must satisfactorily complete the EPL
management  training  program  within  90  days  of  appointment  and  have  received  the  ServSafe®  certification  at
Franchisee’s  expense;  or,  Franchisee  shall  assume  the  duties  of  the  Operations  Director  and  complete  the  EPL
management training program within 120 days (if not previously completed). Franchisee must also comply with any
applicable transfer provisions of this Agreement if the change in Franchisee’s Operations Director results in a change
in the equity ownership of the Restaurant.

11.4.        Franchisee  acknowledges  that  it  has  received  a  copy  of  Franchisor's  list  of  approved  brands  and
distributors (the "Approved Brands and Distributors List"). Franchisor has consulted with the distributors set forth
on  such  list  and  each  distributor  has  agreed  to  offer  products,  services,  equipment,  goods,  inventory,  supplies  or
paper  products  which  will  comply  with  Franchisor’s  Specifications.  Such  Approved  Brands  and  Distributors  List  is
furnished  to  Franchisee  and  Franchisee  must  purchase  only  those  products,  equipment,  goods,  inventory,  supplies
and paper products that comply with the Specifications and only those brands, and only from those distributors, that
are on the Approved Brands and Distributors List. If Franchisee desires to purchase any brands and/or products from
any  distributor  not  named  on  the  Approved  Brands  and  Distributors  List  (or  any  brand  and/or  product  not  on  the
Approved  Brands  and  Distributors  List  from  a  distributor  on  that  list),  Franchisee  shall  first  submit  to  Franchisor  a
written  request  for  approval  of  any  such  brand,  product  and/or  distributor  whichever  is  applicable,  prior  to
Franchisee's  purchase  of  such  product  from  such  distributor.  Franchisor  shall  have  the  right  to  require  that  its
representatives  be  permitted  to  inspect  the  distributor's  facilities  and  that  samples  from  the  distributor  be  delivered
either  to  Franchisor  or  to  an  independent  laboratory  designated  by  Franchisor  for  testing.  Upon  completion  of
Franchisor’s inspection or evaluation of the proposed distributor (including samples provided by such distributor), and
upon submission of any additional information or data required by Franchisor, Franchisor shall promptly approve or
reject such proposed distributor or services and goods. Franchisor reserves the right, at its option, to re-inspect the
facilities  and  products  of  any  such  approved  distributor  or  of  any  distributor  on  Franchisor's  Approved  Brands  and
Distributors  List  and  to  revoke  its  approval  upon  the  distributor's  failure  to  continue  to  meet  any  of  Franchisor's
then‑current Specifications and criteria. Nothing in the foregoing shall require Franchisor to approve any distributor.
Franchisor  agrees  to  evaluate  any  item  which  Franchisee  is  considering  procuring  to  determine  whether  such  item
complies with the Specifications. No charge shall be made by Franchisor for the services of Franchisor's employees
in  connection  with  such  evaluation;  however,  Franchisee  shall  reimburse  Franchisor  for  its  reasonable  cost  and
expenses in connection with such evaluation, including any amounts paid to independent laboratories or consultants
chosen by Franchisor as its sole and absolute right to assist in such evaluation. All such amounts shall be set forth in
a written invoice delivered to Franchisee by Franchisor. Franchisee shall reimburse Franchisor for the invoice amount
within seven (7) days after the invoice has been delivered to Franchisee pursuant to Section 23.3 of this Agreement.
The Approved Brands and Distributors List and any guide containing such list are proprietary information of El Pollo
Loco® and must be kept strictly confidential by Franchisee. Franchisee shall not copy, distribute, release or otherwise
provide any third party with all or any part of the information contained in the Approved Brands and Distributors List or
guide without first obtaining the prior written approval of Franchisor, which approval may be withheld as Franchisor’s
sole and absolute right. (Notwithstanding anything in this Agreement to the contrary, Franchisor may designate itself
the only approved distributor of some or all of the brands and/or products. Franchisor’s proprietary products must be
purchased from Franchisor or its designated distributor pursuant to Section 11.2.b.

11.5.    As uniformity of appearance and public recognition are important to the financial success of Franchisee

and Franchisor hereunder, Franchisee shall:

a.    Use only uniforms, Signs, cards, posters, notices, displays, decorations, table tents and other such
advertising  materials  which  are  identical  in  appearance  and  quality  to  those  furnished  or  approved  by  Franchisor.
Franchisor  may  make  available  its  menu‑stock  (pre-printed  as  to  all  matters  other  than  menu  prices),  including
specials  and  featured  items,  to  Franchisee  for  printing  in  the  event  that  Franchisee  elects  to  charge  prices  not
provided  for  in  Franchisor's  menu  codes.  Notwithstanding  anything  in  this  Agreement  to  the  contrary,  Franchisor
reserves  the  right,  to  the  fullest  extent  allowed  by  applicable  law,  to:  establish  maximum,  minimum  or  other  pricing
requirements  with  respect  to  the  prices  Franchisee  may  charge;  recommend  retail  prices;  advertise  specific  retail
prices for some or all products sold by Franchisee, which prices Franchisee will be compelled to observe; engage in
marketing,  promotional  and  related  campaigns,  which  Franchisee  must  participate  in  and  which  may  directly  or
indirectly impact Franchisee’s retail prices; and otherwise mandate, directly or indirectly, the prices which Franchisee
may charge.) Franchisee agrees that all specials or featured items designated by Franchisor shall be included as part
of the menu and shall be made available on the days and times designated by Franchisor; and

b.       Not authorize or permit in the Restaurant, or on behalf of the Restaurant, any advertising, Signs,
cards,  posters,  notices,  displays,  decorations  or  table  tents  other  than  those  described  in  Section  11.5(a),  nor
authorize  or  permit  in  or  around  the  Restaurant  any  products  or  services  which  are  not  authorized  by  Franchisor,
without the prior written consent of Franchisor.

c.        Franchisee  must  receive  written  approval  from  Franchisor’s  Marketing  Department  to  employ
delivery companies as described in the Manual. Notwithstanding the foregoing, under the System, and as described
in Section 7.13 above, Franchisor: has a Remote Ordering Program, a Loyalty Program, and a Third-Party Delivery
Program;  is  developing  a  Self-Order  Kiosk  Program  that  will  each  operate  with  Micros;  and  (iii)  may  develop  a
centralized Call Center Program. Franchisee shall be required to participate, offer and conduct such programs.

11.6.    Franchisor shall have the right to remove any unauthorized material at Franchisee’s expense.

11.7.    Franchisee shall submit copies of all government health inspections and food borne illness investigation
reports of the Restaurant to Franchisor, or Franchisor’s designated agent. Additionally, should Franchisee be subject
to Restaurant closure by health officials or receive a “B” or equivalent restaurant rating, Franchisee will immediately
notify Franchisor by the fastest means available.

12.

RESTAURANT MAINTENANCE AND REPAIR

12.1.    Maintenance and repair of the Restaurant are the sole responsibility and shall be done at the expense
of  Franchisee.  For  the  term  of  this  Agreement,  Franchisee,  at  its  sole  cost  and  expense,  shall  maintain  the
Restaurant  and  the  Location,  including,  but  not  limited  to,  the  Restaurant  building,  the  Location  and  parking  lot,
equipment, decor, furnishings, fixtures, wares, utensils, supplies, and inventory, in good working order and condition
and in compliance with all laws. Franchisee shall make all repairs within a reasonable time period not to exceed thirty
(30)  days  of  the  date  such  repairs  are  identified  as  needed  to  bring  the  Restaurant  into  a  first-class  condition.
Franchisee shall replace any of the Restaurant's equipment, furnishings and fixtures and repaint the Restaurant as
necessary to satisfy this Section 12. Without limiting the generality of the foregoing, upon notice from Franchisor of
any  change  required  or  recommended  by  applicable  law,  rule  or  regulation,  or  if  Franchisor  discovers  any
circumstance which is or may result in a danger to public health, Franchisee shall promptly, remove, repair, replace or
modify  any  equipment  or  fixtures  used  in  the  Restaurant  necessary  to  satisfy  or  rectify  the  same.  All  replacement
equipment, furnishings and fixtures shall comply with Franchisor's then-current requirements and specifications.

12.2.    Franchisee shall not make any addition to or change in the physical appearance, decor, characteristics
or style of the Restaurant without the prior written consent of Franchisor which consent may be withheld or granted as
Franchisor’s sole and absolute right.

12.3.        During  the  term  of  this  Agreement,  Franchisor  may  require  Franchisee,  at  Franchisee's  expense,  to
remodel the Restaurant to then current El Pollo Loco® standards, format, design and image, as designated pursuant
to plans and specifications provided by Franchisor; provided, however, Franchisee shall not be required to undertake
such remodeling more than once every seven (7) years during the term of this Agreement, except if such remodeling

is  required  in  connection  with  a  transfer  of  the  Restaurant  under  Section  17.6.c  of  this  Agreement  or  granting  of  a
successor franchise under Section 20 below.

12.4.        All  Signs  to  be  used  in  connection  with  the  Restaurant,  both  exterior  and  interior,  must  conform  to
Franchisor's  Sign  criteria  as  to  type,  color,  design  and  location  and  be  approved  in  writing  by  Franchisor  prior  to
installation  or  display.  Franchisee  shall  change  its  Signs  to  conform  with  updated  or  revised  requirements  of
Franchisor when Franchisor commits to implementing such revisions at twenty-five percent (25%) of the Franchisor's
then‑operated  El  Pollo  Loco®  restaurants  and  at  such  times  as  Franchisee  is  required  to  perform  remodeling  work
pursuant to Section 12.3.

12.5.        Franchisee  shall  at  all  times  operate  its  Restaurant  as  a  clean,  safe,  sanitary,  orderly,  legal  and
respectable place of business in accordance with the Manual, the lease or sublease, if any, for the Location and all
applicable  federal,  state  or  local  laws,  rules,  or  regulations.  Franchisee  shall  not  cause  or  allow  any  part  of  its
Location to be used for any immoral or illegal purpose.

13.

HOURS OF OPERATION

13.1.        Franchisee  shall  keep  the  Restaurant  fully  operational  and  open  to  the  public  upon  such  days  and
during such minimum number of hours as Franchisor shall prescribe from time to time in the Manual. Franchisee shall
supply to Franchisor prior to the commencement of the construction or remodeling work of the Restaurant proof that
the  Restaurant  is  allowed  to  be  open  to  the  public  during  such  required  hours  and  days  by  the  applicable  local
governmental  authorities  and  by  the  landlord  under  the  lease  for  the  Location.  In  the  event  that  the  Restaurant  is
closed for reasons beyond Franchisee's control, Franchisee will immediately notify Franchisor by the fastest means
available of the closing.

14.

PERSONNEL STANDARDS

14.1.        Franchisee  shall  hire,  train  and  supervise  Restaurant  employees  in  accordance  with  the  applicable
provisions  of  the  Manual.  Franchisee  shall  do  everything  necessary  to  ensure  that  all  employees  are,  at  all  times
during  employment  in  the  Restaurant,  neat,  clean  and  adequately  trained  and  supervised  in  connection  with  the
performance of their duties.

14.2.    Franchisee acknowledges that adequate training and supervision are necessary in order to ensure that
the Restaurant personnel provide service to the public in a courteous, efficient and skilled manner and in accordance
with the standards set forth in the Manual. Franchisee understands and agrees that Franchisee is solely responsible
for the performance of its Operations Manager and all other of its employees and that the acts and omissions of such
employees which are inconsistent with the provisions of this Agreement shall be considered grounds for termination
of this Agreement as provided in Section 18 hereof.

14.3.    Franchisee shall maintain wages, hours, working conditions and other benefits for all of its employees in

accordance with all federal, state and local laws and regulations.

14.4.    Franchisee shall maintain all employee time, payroll and tax records and to file required reports thereon

in accordance with all federal, state and local laws and regulations.

14.5.        It  is  mutually  understood  and  agreed  by  the  parties  that  Franchisee  retains  the  responsibility  and
independent  authority,  notwithstanding  any  provision  of  this  Agreement,  to  maintain  and  enforce  personnel  policies
and  procedures,  including,  but  not  limited  to,  hiring,  firing  and  disciplining  its  employees.  Nothing  contained  in  this
Agreement  shall  be  construed  or  interpreted  so  that  any  employee  of  Franchisee  becomes  or  is  deemed  to  be  an
employee  or  agent  of  Franchisor.  Franchisee  shall  be  solely  responsible  for  the  maintenance  and  handling  of  all
employee  matters  and  Franchisee  shall  indemnify  and  hold  Franchisor  and  its  affiliates  and  subsidiaries  harmless
from any claims, losses, or liabilities resulting from any failure by Franchisee to act in such a manner.

15.

INSPECTIONS

15.1.        Franchisor  and  its  authorized  representatives  shall  have  the  right  to  inspect  the  Restaurant  and  the
supplies  and  inventory  of  Franchisee.  Franchisor's  personnel  and  representatives  shall  have  the  right  to  enter  the
Restaurant  at  any  reasonable  time,  and  from  time  to  time,  with  or  without  notice,  for  the  purposes  of  examination,
conferences  with  Franchisee  and  personnel  of  Franchisee,  observation  and  evaluation  of  the  operations  being
conducted  at  the  Restaurant,  and  for  all  other  purposes  in  connection  with  a  determination  that  the  Restaurant  is
being operated in accordance with the terms of this Agreement, the Specifications and Manual and other applicable
laws and regulations.

15.2.        Franchisor  may  conduct  quality  control  and  evaluation  programs,  as  Franchisor  shall  determine
(including a “mystery shopper” program or “accuracy guarantee” program or other similar programs). Franchisee shall
allow  and  participate  in  such  program(s),  as  required  by  Franchisor.  Franchisor  shall  have  the  right  to  require
Franchisee  to  pay  its  pro-rata  share  of  the  costs  incurred  in  establishing  and  maintaining  such  program(s)  and
Franchisee shall promptly pay such charges. Franchisee  acknowledges  that  Franchisor  shall  have  the  right,  in  any
manner  Franchisor  may  deem  appropriate,  to  publish  or  disclose  to  other  franchisees  under  the  El  Pollo  Loco®
System,  or  to  third  parties  outside  the  El  Pollo  Loco®  System  on  an  anonymous  basis,  any  information  that  is
collected, produced or maintained under any program(s) implemented pursuant to this Section 15.2.

15.3.    In connection with inspections conducted pursuant to Sections 15.1 and 15.2 above, Franchisor and its
authorized  representatives  may  deliver  to  Franchisee  an  inspection  report  in  such  form(s)  as  may  be  adopted  by
Franchisor from time to time (the "Inspection Report(s)"). The Inspection Report(s) shall indicate the principal items
inspected, observed and evaluated.

15.4.        In  the  event  that  any  such  Inspection  Report  indicates  a  deficiency  or  unsatisfactory  condition  with
respect  to  any  item  listed  thereon,  Franchisee  shall  promptly  commence  to  correct  or  repair  such  deficiency  or
unsatisfactory  condition  and  thereafter  diligently  pursue  the  same  to  completion.  In  the  event  of  a  failure  by
Franchisee  to  comply  with  the  foregoing  obligation  to  correct  or  repair,  Franchisor,  in  addition  to  all  other  available
rights and remedies, including the right to terminate this Agreement pursuant to Section 18 below, shall have the sole
and absolute right, but not the obligation, to forthwith make or cause to be made such correction or repair, and the
expenses thereof, including, without limitation, meals, lodging, wages and transportation for Franchisor's personnel, if
so utilized as Franchisor's sole and absolute right to determine, shall be promptly reimbursed by Franchisee. Should
any  deficiency  or  unsatisfactory  condition  be  reported  more  than  once  within  any  thirty  (30)  day  period,  Franchisor
shall  have  the  right,  in  addition  to  all  other  available  rights  and  remedies,  to  place  a  Franchisor  representative  in
charge of the Restaurant for a period of up to thirty (30) days in each such instance, and the wages and expenses of
meals,  lodging  and  transportation  of  said  representative,  which  shall  be  commensurate  with  that  provided  for
managers  of  other  Franchisor-owned  El  Pollo  Loco®  restaurants,  shall  promptly  be  reimbursed  by  Franchisee.  All
such  expenses  incurred  by  Franchisor  pursuant  to  this  Section  shall  be  set  forth  in  a  written  invoice  delivered  to
Franchisee by Franchisor. Franchisee shall reimburse Franchisor for the invoice amount within seven (7) days after
the invoice has been delivered to Franchisee upon demand.

15.5.        Notwithstanding  Section  15.4  above,  should  the  Inspection  Report  indicate  a  deficiency  or
unsatisfactory condition with respect to any item listed thereon, and Franchisor or Franchisor’s agent are required to
return to the Restaurant to re-inspect the Restaurant, Franchisor will charge Franchisee for each subsequent visit to
Franchisee’s  restaurant  after  the  initial  inspection.  Franchisee  will  give  Franchisor  authorization  to  pay  the  re-
inspection visit charge as a direct debit from Franchisee’s Operating Account. Should there be two (2) consecutive
Inspection Reports both indicating a deficiency or unsatisfactory condition with respect to any item listed thereon, and
Franchisor  or  Franchisor’s  agent  are  required  to  return  to  the  Restaurant  to  provide  a  Coaching  session  to
Franchisee; or should Franchisor determine in our sole and absolute right that a Coaching session is required at the
Restaurant  due  to  certain  circumstances,  Franchisor  will  charge  Franchisee  for  each  Coaching  session  at
Franchisee’s restaurant. Franchisee will give Franchisor authorization to pay each Coaching session visit charge as a
direct debit from Franchisee’s Operating Account.

16.

TRAINING

16.1.        Franchisee  acknowledges  and  agrees  that  it  is  important  to  the  operation  of  the  Restaurant  that

Franchisee and its employees receive such training as Franchisor may require from time to time. Therefore:

a.       The  Restaurant  must  be  managed  by  not  less  than  four  (4)  individuals  as  a  General  Manager  or
Assistant  Manager  who  have  successfully  completed  the  EPL  management  training  program;  or  a  Shift  Leader
trained  by  your  General  Manager  and  Assistant  Manager  at  your  Restaurant  and  such  Restaurant  is  certified  as  a
training restaurant prior to any training taking place; and who have received the ServSafe® certification and who will
assume responsibility for the day to day management of the operations of the Restaurant, including the preparation of
food products, accounting, and the supervision and training of personnel (“Managers”) The Managers may consist of
a combination of the following: a General Manager or Assistant Manager, each who has successfully completed the
EPL  management  training  program  or  a  Shift  Leader.  The  Managers  may  be  required  to  sign  a  confidentiality
agreement in a form approved by Franchisor. Each and every shift during operating hours must have a Manager in
charge that is certified and trained in Franchisor’s initial training program and is ServSafe® certified.

b.    If at any time, for any reason, the General Manager ceases to perform those duties on behalf of the
Restaurant,  Franchisee  must  promptly  designate  a  substitute  General  Manager  who  does  meet  the  above-stated
qualifications.

c.    If this is Franchisee’s first EPL Restaurant, Franchisee must also attend and satisfactorily complete
the  EPL  management  training  program  provided  by  Franchisor.  If  Franchisee  appoints  an  Operations  Director  to
oversee  franchise  activities,  this  Operations  Director  is  subject  to  Franchisor’s  prior  written  approval  and  must
satisfactorily  complete  the  EPL  management  training  program  and  Franchisee  must  complete  either  the  EPL
management training program or the Executive Franchisee Training Program. Such training shall be completed prior
to the opening of the restaurant.

d.        Franchisee’s  Operations  Director  shall  be  actively  engaged  in  the  management  and  day  to  day
operations of the restaurant and devote full time and best efforts to the supervision of EPL Restaurant(s) owned by
Franchisee. If at any time, for any reason, the Operations Director ceases to perform those duties on behalf of the
Restaurant(s),  Franchisee  shall  appoint  a  new  Operations  Director  within  30  days,  and  the  newly  appointed
Operations  Director  must  satisfactorily  complete  the  EPL  management  training  program  within  90  days  of
appointment  at  Franchisee’s  expense;  or,  Franchisee  shall  assume  the  duties  of  the  Operations  Director  and
complete the EPL management training program within 120 days (if not previously completed).

e.        Franchisee  shall  implement  a  training  program  for  Franchisee's  employees  in  accordance  with
training standards and procedures prescribed by Franchisor and shall staff the Restaurant at all times during the term
of this Agreement with a sufficient number of trained employees.

f.        Franchisor  may  provide  continuing  operations  training  from  time  to  time  to  reinforce  operational
standards, and new product roll-outs. The required frequency, duration, subject matter and required attendees shall
be as determined by Franchisor from time to time.

g.        In  addition  to  the  initial  management  training  session  described  above,  Franchisor  may,  at
Franchisor's  sole  option  (and  if  the  Restaurant  is  Franchisee's  or  its  affiliate's  first  El  Pollo  Loco®  restaurant,
Franchisor shall) assist Franchisee in the initial opening of the Restaurant by sending to the Restaurant a member of
Franchisor's personnel who shall assist in the scheduled opening of the Restaurant.

h.    The Restaurant shall not be opened until Franchisor is satisfied that Franchisee and Franchisee's

Managers and other restaurant personnel have been adequately trained in the El Pollo Loco® System.

16.2.    Franchisor shall provide training as described in Section 16.1 without additional charge to Franchisee,
provided that Franchisee does not request Franchisor to provide the EPL management training program to more than
four  Managers  for  the  first,  second  and  third  Restaurants  owned  by  Franchisee,  or  more  than  one  Executive
Franchisee  Training  Program,  or  more  than  one  EPL  management  training  program  for  franchisee  or  Operations
Director  in  total.  Franchisor  shall  charge  franchisee  a  training  fee  of  $2,000  per  Manager  for  the  fifth  and  each
subsequent Manager for the first, second and third Restaurants owned by Franchisee and for each Manager trained
for the fourth and subsequent Restaurants owned by Franchisee, and up to $2,000 per Executive Franchisee Training
Program beyond one executive in total, or EPL management training program for franchisee or Operations Director
beyond one franchisee or Operations Directors in total. Franchisee understands and agrees that Franchisee and any
Manager  shall  be  solely  responsible  for  any  and  all  costs  incurred  by  them  with  respect  to  such  training,  including
costs  for  compensation,  wages  (including  compensation  of  and  worker’s  compensation  insurance),  lodging,  travel

expenses or any other expenses incurred in connection with any initial training sessions, EPL management training
program, Executive Franchisee Training Program, refresher courses or optional or required training program, and any
such Manager shall not be considered an employee or agent of Franchisor.

17.

ASSIGNMENT

17.1.        Assignment  by  Franchisor.  Franchisor  shall  have  the  right  to  assign  or  transfer  any  of  its  rights  or
delegate any of its obligations under this Agreement in whole or in part to any person, firm or corporation without any
consent  or  approval  from  Franchisees;  provided,  however,  that  with  respect  to  any  assignment  resulting  in  the
subsequent performance by the assignee of the obligations of Franchisor hereunder:

a.    The assignee shall expressly assume and agree to perform such obligations of Franchisor in writing;

and

b.        From  and  after  the  date  of  any  such  assignment,  Franchisor  shall  have  no  further  obligation  or

liability under this Agreement.

17.2.        Assignment  by  Franchisee.  The  rights  and  duties  created  by  this  Agreement  are  personal  to
Franchisee. Franchisee acknowledges that Franchisor has entered into this Agreement in reliance on the individual or
collective character, skill, aptitude, business ability, and financial capacity of Franchisee and its owners. Franchisee
and each owner of an interest in this Agreement represent, warrant, and agree that all “Interests” in Franchisee are
owned  in  the  amount  and  manner  in  which  Franchisee  has  disclosed  them  to  Franchisor,  as  more  particularly  set
forth in Schedule 1 to this Agreement. (An “Interest” means any shares or partnership interests in Franchisee and
any other legal or equitable right in any of Franchisee’s stock, revenues, profits, rights or assets. When referring to
Franchisee’s rights or assets, an “Interest” also includes this Agreement and Franchisee’s rights under and interest in
this Agreement, the Restaurant and the revenues, profits or assets of the Restaurant.) Franchisee and each owner
also represent, warrant and agree that no change will be made in the ownership of an Interest other than as permitted
by this Agreement or as Franchisor may otherwise approve in writing. Franchisee and each owner agree to furnish
Franchisor with evidence as Franchisor may request from time to time to assure that the Interests of Franchisee and
each owner remain as permitted by this Agreement, including a list of all persons or entities owning any Interest. If
Franchisee  is  a  Business  Organization,  Franchisee  shall  cause  each  of  the  owners  of  any  equity  ownership  in
Franchisee  to  execute  an  agreement  granting  Franchisor  an  option  to  purchase  each  of  such  owner’s  Interest  in
Franchisee upon an Assignment as provided in this Section 17.

17.3.        Neither  this  Agreement  nor  any  Interest  herein  nor  any  Interest  of  Franchisee  or  any  owner  may  be
indirectly  or  directly,  sold,  transferred,  assigned,  conveyed,  gifted,  pledged,  mortgaged,  or  otherwise  encumbered
(“Assignment”) without Franchisor’s prior written approval. Any such purported Assignment occurring by operation of
law or otherwise without Franchisor’s prior written consent shall constitute a default of this Agreement by Franchisee,
and shall be null and void. Except in the instance of Franchisee advertising to sell its Restaurant and assigning this
Agreement  in  accordance  with  the  terms  thereof,  Franchisee  shall  not,  without  Franchisor’s  prior  written  consent,
offer for sale or transfer at public or private auction or advertise publicly for sale or transfer, the furnishings, interior
and exterior décor, items, supplies, fixtures, equipment, Franchisee’s lease or the real or personal property used in
connection with the Restaurant. This Agreement may not be transferred by Franchisee to a publicly-held entity, or to
any entity whose direct or indirect parent’s securities are publicly traded and no shares of Franchisee or any direct or
indirect owner of Franchisee may be offered for sale through the public offering of securities.

17.4.    In the event that Franchisee desires to make an Assignment including assigning all or any part of its
rights,  privileges  and  interests  under  this  Agreement,  Franchisee  shall  first  offer  such  Assignment  to  Franchisor  by
notifying  Franchisor  in  writing  of  the  material  terms  and  conditions,  including  price  and  identity  of  transferee  upon
which  Franchisee  would  be  willing  to  make  such  an  Assignment.  Franchisee  shall  also  concurrently  provide
Franchisor with the estoppel certificate identified in Section 17.7 below and such other information as determined by
Franchisor  to  enable  Franchisor  to  evaluate  the  offer.  Franchisor  shall  have  the  first  right  to  acquire  said  rights,
privileges  and  interests  of  Franchisee  by  accepting  the  offer  in  accordance  with  said  terms  and  conditions  or
equivalent cash, as determined by Franchisor in its reasonable business judgment.

a.        If  the  Assignment  will  be  in  the  aggregate  more  than  fifty  percent  (50%)  of  any  one  class  of
outstanding capital stock, the voting power, membership interests, partnership interest or other Interest in Franchisee
occurring  within  thirty-six  (36)  months  prior  to  the  date  of  the  Assignment,  (a  “Majority Interest”),  then  Franchisor
shall have the option to purchase not only the Majority Interest being transferred, but also the remaining Interest, so
that the ownership of Franchisor will be one hundred percent (100%). Any purchase of such remaining Interest shall
be valued on a basis proportionate to the price of the Interest initially being offered.

b.    If, within thirty (30) days after receipt of Franchisee's notice, Franchisor advises Franchisee of its
acceptance of the offer as stated in the notice, Franchisee shall promptly make the Assignment to Franchisor on the
stated terms and conditions. Should Franchisor elect to exercise its right of first refusal, Franchisee shall, if requested
by  Franchisor,  cause  Franchisee's  lease  or  sublease,  if  any,  with  the  lessor  for  the  Location  to  be  assigned  to
Franchisor  (or,  if  the  Location  is  owned  by  Franchisee,  Franchisee  shall  lease  the  Location  to  Franchisor  on
commercially  reasonable  terms  applicable  in  that  market).  Notwithstanding  the  foregoing,  Franchisor  shall  have  at
least sixty (60) days from the date of its notice of exercise to Franchisee to close the transaction and Franchisor shall
also  be  entitled  to  all  customary  and  reasonable  representations  and  warranties  from  Franchisee  regarding  the
Franchisee’s business or any other interest being conveyed.

c.    Notwithstanding the provisions of this Section 17.4, Franchisor will waive Franchisor’s right of first
refusal  if  the  assignee  is  a  revocable  family  trust  for  which  Franchisee  is  the  controlling  trustee  and  Franchisee’s
immediate  family  members  are  beneficiaries  provided  such  Assignment  is  not  considered  a  Majority  Interest.  An
immediate family member is defined as a parent; sibling; child by blood, adoption, or marriage; spouse or significant
other; grandparent or grandchild.

17.5.    If, within thirty (30) days after receipt of Franchisee's notice, Franchisor does not indicate its acceptance
of the offer as stated in the notice, Franchisee shall thereafter have the right, subject to the prior written consent of
Franchisor, to make the Assignment to the proposed transferee on the same terms and conditions as stated in the
notice.  Should  Franchisor  not  exercise  its  right  of  first  refusal  and  should  the  contemplated  Assignment  not  be
completed within one hundred (120) days from the date of Franchisee's notice, or should the terms and conditions
thereof (including the proposed transferee or the ownership therein) be altered in any material way, this right of first
refusal  shall  be  reinstated  and  any  such  subsequent  proposed  Assignment  or  altered  terms  and  conditions  of  the
current transaction must again be offered to Franchisor in accordance with the terms of these Sections 17.4 and 17.5.

17.6.        Franchisee  shall  notify  Franchisor  in  writing  of  any  proposed  assignee  and  shall  promptly  furnish
Franchisor with such other information and documentation as Franchisor may request for the purpose of considering
whether  to  grant  its  written  consent.  Franchisee  acknowledges  and  agrees  that  Franchisor  shall  be  entitled,  at  its
election and without liability to Franchisee, to provide assignee with information relating to the Restaurant, including
information in Franchisor's possession relating to operations and sales. Franchisor shall not unreasonably withhold its
consent to an Assignment provided that Franchisee and the assignee satisfy such reasonable terms and conditions
which  may  be  imposed  by  Franchisor  as  a  condition  to  obtaining  Franchisor's  consent,  which  may  include,  without
limitation, the following:

a.    The assignee (and its partners or the officers, directors, principal shareholders, or members of the

assignee, as the case may be) shall be subject to the determination by Franchisor:

character, and aptitude necessary to operate and maintain the Restaurant;

i.    To have the appropriate business qualifications, restaurant operations experience, reputation,

Restaurant;

ii.        To  have  the  ability  to  devote  full  time  and  best  efforts  to  operating  and  maintaining  the

carrying on the Restaurant business and have sufficient net worth as required by Franchisor for new franchisees;

iii.    To be financially responsible, possess a favorable credit rating, be economically capable of

ownership of the Restaurant or of any felony;

iv.        To  not  have  been  convicted  of  criminal  misconduct  that  is  relevant  to  the  operation  or

v.    Shall neither directly nor indirectly own, operate, control or have any financial interest in any
other  business  which  would  constitute  a  "Competitive  Business"  (as  such  term  is  defined  in  Section  21.7  of  this
Agreement); and

vi.    Shall have demonstrated to Franchisor’s satisfaction that assignee meets all of Franchisor’s
then-current  requirements  for  new  El  Pollo  Loco®  franchisees,  which  requirements  are  subject  to  change  by
Franchisor from time to time as its sole and absolute right.

b.    The assignee shall expressly assume in writing, via the Consent to and Assignment of Franchise
Rights attached hereto as Exhibit 9 of the Franchise Agreement, all of the obligations and liabilities of and enter into
Franchisor's  then-current  form  of  Franchise  Agreement,  which  may  contain  provisions  including  royalty  and
advertising  fees,  materially  different  from  those  contained  herein;  provided,  however,  that  the  term  of  such  new
agreement shall be equal to the then-remaining term of this Agreement and assignee shall not be required to pay a
new initial franchise fee. If  the  assignee  is  a  partnership,  corporation,  limited  liability  company  or  other  legal  entity,
then  all  partners,  shareholders,  and  members  of  assignee  that  (i)  hold  at  least  a  ten  percent  (10%)  interest  in
assignee and/or (ii) upon whose net worth Franchisor is relying in determining that the assignee has met Franchisor’s
financial minimum requirements for approval must sign the Personal Guarantee and any related documents in their
individual  capacity,  agreeing  to  guarantee  the  obligations  and  liabilities  of  the  assignee  under  the  Franchise
Agreement  and  to  be  individually  bound  by  the  terms  of  the  Franchise  Agreement  as  if  they  were  a  party  to  the
Franchise  Agreement.  If  a  new  partnership,  corporation,  limited  liability  company  or  other  legal  entity,  at  any  time
(including  after  an  assignment),  becomes  the  Franchisee  or  part  of  the  Franchisee,  that  partnership,  corporation,
limited liability company or legal entity, as well as all holders of ten percent (10%) interest or more in assignee, as
applicable, shall execute a Personal Guarantee, guaranteeing each of Franchisee’s obligations and liabilities under
the Franchise Agreement and agreeing to be individually bound by the terms of the Franchise Agreement as if they
were a party to the Franchise Agreement. If the assignee is a corporation, partnership or limited liability company, it
also  shall  demonstrate  to  the  reasonable  satisfaction  of  Franchisor  that  it  has  established  transfer  instructions
prohibiting the transfer on its records of any equity securities, partnership interests or ownership interests in violation
of the requirements set forth in this Section 17 and that each stock, partnership or ownership certificate of Franchisee
shall have conspicuously endorsed upon its face a statement in form satisfactory to Franchisor that the assignment or
transfer is subject to all of the restrictions imposed upon assignments by this Agreement;

c.        The  assignee  or  the  assignor  agrees  to  the  reimage  and/or  remodel  of  the  Restaurant  to
Franchisor's  then-current  standards,  format,  design  and  image,  as  designated  pursuant  to  plans  and  specifications
provided  by  Franchisor.  Franchisee  will  have  a  specified  period  of  time  to  complete  the  required  reimage  and/or
remodel  of  the  Restaurant.  The  required  reimage  and/or  remodel  of  the  Restaurant  must  be  completed  to
Franchisor’s  satisfaction.  Should  the  required  reimage  and/or  remodel  of  the  Restaurant  not  be  completed  to
Franchisor’s satisfaction, then Franchisor may terminate the Franchise Agreement under Section 18, entitled Default
and Termination;

d.    A copy of the Personal Guarantee required to be executed pursuant to this Section 17 is attached
hereto as Exhibit 2. All other individuals with an ownership interest in the entity (who are not required to execute the
Personal  Guarantee)  will  be  considered  “Investors”  and  will  be  required  to  execute  the  “Investor  Covenants
Regarding Confidentiality and Non-Competition” which is attached hereto as Exhibit 3;

e.    The assignee shall represent and warrant to Franchisor in writing that the assignee:

i.    Has conducted an independent study of the Restaurant and the business therein;

ii.    Has not in any way relied upon statements or representations of Franchisor or its employees
or agents except as may be contained in an Disclosure Document or other comparable Disclosure Document which
may be required to be delivered to such assignee in accordance with applicable law; and

iii.    Acknowledges and understands that the assignee's rights upon assignment are conditioned
on  full  performance  of  Franchisee's  obligations  hereunder  and  are  limited  to  those  expressly  provided  for  in  this
Agreement.

f.    As of the date of such assignment, Franchisee shall have fully performed and complied with all of its
obligations to Franchisor, whether under this Agreement or any other agreement, arrangement or understanding with
Franchisor;

g.        Franchisee  shall  pay  and  discharge  all  outstanding  obligations  to  Franchisor  and  to  third  parties
arising from the existence, operation or maintenance of the Restaurant including, without limitation, amounts owing
under  this  Agreement,  the  lease,  if  any,  for  the  Location  or  to  employees,  suppliers,  taxing  authorities,  utility
companies and others as of the assignment date;

h.    Franchisee shall pay to Franchisor a transfer fee to reimburse Franchisor for costs and expenses
incurred  in  connection  with  such  Assignment,  including,  without  limitation,  the  cost  of  credit  investigations  and  the
preparation of Assignment agreements and Franchise Disclosure Documents which may be required to be delivered
to such assignee under applicable federal or state law. If the Assignment is to a new franchisee under the El Pollo
Loco®  System,  the  transfer  fee  shall  be  forty  percent  (40%)  of  the  then-current  Initial  Fee  being  charged  to  new
franchisees  entering  the  El  Pollo  Loco®  System.  If  the  Assignment  is  to  an  existing  franchisee  under  the  El  Pollo
Loco® System, the transfer fee shall be twenty-five percent (25%) of the then-current Initial Fee being charged to new
franchisees entering the El Pollo Loco® System. If the assignee is a revocable family trust for which Franchisee is the
controlling trustee and Franchisee’s immediate family members are beneficiaries, no transfer fee will be payable to
Franchisor, although Franchisee must reimburse Franchisor for Franchisor’s reasonable expenses in the amount of
$500.00; and

i.    In conjunction with granting the consent of Franchisor to any Assignment, Franchisee shall execute
a general release, in form and substance satisfactory to Franchisor, of all claims against Franchisor and any affiliates
of Franchisor.

17.7.        Upon  Franchisor’s  request,  Franchisee  shall,  concurrently  with  any  offer  submitted  to  Franchisor  by
Franchisee  regarding  a  transfer  or  purported  Assignment  or  at  any  other  time  at  Franchisor’s  request,  furnish
Franchisor  with  an  estoppel  agreement  indicating  any  and  all  claims,  demands  and  causes  of  action,  if  any  that
Franchisee may have against Franchisor or if none so exist, so stating, and a list of all owners having an interest in
this Agreement or in Franchisee, the percentage interest of each owner and a list of all officers, directors, members
and/or shareholders in such form as Franchisor may require.

17.8.    Any Assignment including any encumbrance, assignment or purported encumbrance or assignment of
Franchisee's rights, privileges or interests under this Agreement without Franchisor's written consent shall be null and
void, of no force and effect, and shall constitute grounds for termination of this Agreement as provided in Section 18
hereof.

17.9.        Any  assignment  based  upon  the  legal  incapacity  of  Franchisee,  whether  by  operation  of  law  or

otherwise, shall be subject to Franchisor's written consent and right of first refusal as provided herein.

17.10.    If this Agreement is assigned, Franchisee shall remain liable to Franchisor for the obligations under
this  Agreement  and  the  obligations  of  the  assignee  hereunder  and  which  arise  as  a  result  of  acts,  events  or
omissions  which  occur  prior  to  the  effective  date  of  the  assignment  or  within  the  initial  term  of  this  Agreement;
provided,  however,  that  the  foregoing  limitation  on  liability  shall  not  reduce  Franchisee's  continuing  liability  to  the
extent that Franchisee is a partner, shareholder or owner of an interest in the assignee. Franchisor's consent to any
transfer  hereunder  shall  not  constitute  a  waiver  or  release  of  any  claims  it  may  have  against  Franchisee  as  of  the
date of the assignment.

17.11.        Any  transfer  of  this  Agreement,  or  any  interest  in  this  Agreement,  or  franchisee  by  will  or  intestate
succession, or the sale of this franchise, or any interest in Franchisee constituting a Majority Interest by the executor
or  administrator  of  Franchisee's  or  such  shareholder's  or  person's  estate,  shall  be  considered  to  be  a  transfer
requiring  compliance  with  the  provisions  of  this  Section  17,  including  the  requirements  concerning  Franchisor's
written approval of the assignee, the assignee's qualifications and training, and the execution of agreements. In the
event  Franchisor  does  not  approve  the  qualifications  of  any  heir  or  beneficiary  to  operate  the  Restaurant,  the
executor  or  administrator  of  Franchisee's  estate  shall  have  a  period  of  twelve  (12)  months  following  written

disapproval to sell the franchise business to an assignee acceptable to Franchisor, during which twelve (12) month
period the Restaurant shall be operated in accordance with all the terms and provisions of this Agreement. Such sale
shall be subject to Franchisor's right of first refusal pursuant to this Section 17. If such a sale is not concluded within
that period, Franchisor may terminate this Agreement.

17.12.        If,  for  convenience  of  ownership,  Franchisee  desires  to  assign  this  Agreement  to  a  Business
Organization to hold its interest in this Agreement, Franchisor will consent to the assignment of this Agreement to a
Business  Organization,  provided  that  (i)  none  of  the  securities  of  an  Business  Organization  shall  be  traded  on  any
public  exchange  or  over  the  counter  market;  (ii)  the  certificates  or  other  evidence  of  ownership  held  by  the  owner
thereof shall contain a restriction on transfer referencing this Franchise Agreement, in a form required by Franchisor;
(iii)  the  ownership  of  the  assignee  Business  Organization  shall  be  in  the  same  proportion  as  the  ownership  of
Franchisee  immediately  prior  to  the  transfer;  and  (iv)  none  of  the  shares  of  stock,  membership  interests,  voting
power,  equity  or  ownership  interests  in  the  assignee  Business  Organization  shall  be  held  by  or  for  the  benefit  of  a
business  competitor  of  Franchisor.  Franchisee  shall  pay  an  administrative  fee  of  Five  Hundred  Dollars  ($500)  per
transfer  for  each  transfer  to  a  Business  Organization,  or  for  each  transfer  of  ownership  amongst  existing  owners
where such transfer is for the convenience of ownership only. At the time of request for a transfer for the convenience
of  ownership,  Franchisee  shall  submit  the  following  documents  to  Franchisor  and  Franchisor  shall  review,  approve
and/or disapprove such documents within thirty (30) days thereafter:

a.    For an assignment to a corporation, Franchisee shall provide to Franchisor a (i) file stamped copy of
the  Articles  of  Incorporation  (or  comparable  organizational  document)  and  By-laws  of  the  proposed  assignee
corporation, (ii) a sample stock certificate, (iii) a Certificate of Good Standing in the state in which the corporation is
authorized to do business and the state in which the corporation will conduct the restaurant business pursuant to this
Franchise  Agreement,  and  (iv)  a  list  of  directors,  shareholders  and  officers  and  their  percentage  ownership  of  the
stock  of  the  corporation.  Each  share  certificate  of  a  corporation  shall  contain  a  restriction  on  transfer  in  a  form
designated by Franchisor.

b.    For an assignment to a partnership, Franchisee shall provide to Franchisor a (i) file stamped copy of
the  Certificate  of  Limited  Partnership  (if  applicable)  or  the  Statement  of  Partnership,  and  (ii)  a  copy  of  the  fully
executed Partnership Agreement, containing an exhibit showing the percentage of ownership in the partnership by all
partners. The partnership agreement shall contain a restriction on transfer in a form designated by Franchisor.

c.    For an assignment to a limited liability company, Franchisee shall provide to Company (i) Certificate
of Formation (or comparable organizational document) of Limited Liability Company; (ii) a fully executed copy of the
Operating  Agreement,  containing  an  exhibit  showing  the  percentage  of  ownership  of  all  members  in  the  limited
liability  company;  and  (iii)  the  name  of  the  Manager  or  Managers  of  the  limited  liability  company.  The  operating
agreement shall contain a restriction on transfer in a form designated by Franchisor.

d.        Franchisee  acknowledges  that  the  purpose  of  the  restrictions  on  transfer  referenced  in  Sections
17.12(a)  through  17.12(c)  above  is  to  protect  Franchisor’s  trademarks,  service  marks,  trade  secrets,  and  operating
procedures as well as the Franchisor’s general high reputation and image, and is for the mutual benefit of Franchisor,
Franchisee  and  other  franchisees  of  the  Franchisor.  Franchisor  shall  not  unreasonably  restrict  the  issuance  or
transfer of stock or interests in a partnership or limited liability company, provided that, in no event, shall any share of
stock of such assignee corporation, or an interest in a partnership or limited liability be sold, assigned or transferred
to a business of a competitor of Franchisor or anyone of ill repute.

17.13.        Where  Franchisee  desires  to  add  new  principals  to  the  Franchisee  entity,  Franchisee  shall  pay  to
Franchisor  an  additional  Two  Thousand  Five  Hundred  Dollars  ($2,500)  per  new  principal  to  cover  Franchisor’s
administrative costs for reviewing the application and suitability of each new principal as participants in the franchise
business.

17.14.        In  connection  with  a  sale  by  Franchisee  of  all  or  substantially  all  of  the  assets  relating  to  the
Restaurant business, Franchisee may take a security interest in the Restaurant and the purchaser’s rights under this
Agreement  in  order  to  secure  any  financing  that  Franchisee  provides  to  the  purchaser  for  the  purchase  of  the
Restaurant. In the event of a default under such financing arrangement and the exercise by Franchisee of its rights
under such security interest, Franchisee or the individual(s) purchasing the Restaurant out of a foreclosure sale may

become the franchisee under this Agreement, subject to its compliance with each of the requirements set forth in this
Section 17.

18.

DEFAULT AND TERMINATION

18.1.    In addition to all other available rights and remedies, Franchisor shall have the right to terminate this
Agreement  only  for  "cause".  "Cause"  is  hereby  defined  as  a  material  breach  of  this  Agreement,  including  but  not
limited to any of the facts or circumstances specified in Sections 18.2, 18.3, or 18.4.

18.2.        In  addition  to  all  other  available  rights  and  remedies,  Franchisor  shall  have  the  right  upon  the
occurrence  of  any  of  the  following  events  to  immediately  terminate  this  Agreement  by  giving  written  notice  to
Franchisee.

a.    Abandonment of the Restaurant by Franchisee by failing to operate the Restaurant business for five
(5)  consecutive  days  or  any  shorter  period  of  time  after  which  Franchisor  reasonably  determines  that  Franchisee
does  not  intend  to  continue  to  operate  the  business,  unless  such  failure  is  due  to  fire,  flood,  earthquake  or  other
similar cause beyond Franchisee's control, in which case Franchisee shall comply with each of the requirements set
forth in Section 23.17;

b.    Franchisee admits to an inability to pay its debts as the same become due, is declared bankrupt or
judicially determined to be insolvent, or all or a substantial part of the assets thereof are assigned to or for the benefit
of any creditor, or Franchisee admits its inability to pay its debts as they come due;

c.    A levy of execution is made upon the Restaurant, the license granted by this Agreement or upon

any property used in the Restaurant business, and it is not discharged within five (5) days of such levy;

d.    The Restaurant business, equipment or premises are seized, taken over or foreclosed by a creditor,
lienholder or lessor, or a final judgment rendered against Franchisee remains unsatisfied for at least thirty (30) days
and a supersedeas or other appeal bond has not been filed;

e.    The right to occupy or lease the Location is lost or terminated and Franchisee has not relocated the

Restaurant, if permitted, pursuant to Section 23.17;

f.        Franchisee  or  any  of  its  partners,  officers,  directors  or  principal  shareholders  is  convicted  of  any

criminal misconduct that is relevant to the operation or ownership of the Restaurant or any felony;

g.        The  failure  of  Franchisee  to  reach  each  milestone  and  to  open  and  operate  the  Restaurant  in

accordance with and by the time set forth in Section 4.1;

h.        Any  purported  Assignment,  including  the  transfer  or  sublicense  of  this  franchise,  or  any  right

hereunder, without the prior written consent of Franchisor;

i.        Any  material  misrepresentation  is  made  by  Franchisee  in  connection  with  the  acquisition  of  the

franchise herein;

j.        Franchisee  engages  in  conduct  which  reflects  materially  and  unfavorably  upon  the  operation,  the
reputation of the Restaurant business, the El Pollo Loco® System, or the goodwill associated with the El Pollo Loco®
Marks;

k.    Franchisee on three or more occasions fails to comply with one (1) or more material standards or

requirements of this Agreement (or as specified in the Manual), whether or not corrected after notification thereof;

l.    A repetition within a one-year period of any default (whether or not that earlier default was corrected
after  notification  thereof)  shall  justify  Franchisor  in  terminating  this  Agreement  upon  written  notice  to  Franchisee
without allowance for any curative period;

m.    Failure of Franchisee, for a period of ten (10) days after notification of noncompliance, to comply
with  any  federal,  state  or  local  law  or  regulation  applicable  to  the  operation  and  maintenance  of  the  Restaurant,
including, but not limited to, public health and safety requirements;

n.    Reasonable determination on the part of Franchisor that continued operation of the Restaurant by

Franchisee will result in an imminent danger to public health or safety;

o.        Except  for  noncompliance  otherwise  covered  by  Section  18.2.k  above,  failure  of  Franchisee  to
correct a deficiency or unsatisfactory condition referred to in an Inspection Report (discussed in Section 15 hereof)
which  Franchisor  reasonably  determines  may  have  a  material  adverse  effect  on  the  ownership  or  operation  of  the
Restaurant after having received a reasonable opportunity to cure such deficiency or unsatisfactory condition, which
in no event need be more than thirty (30) days;

p.    In the event that Franchisee leases or subleases the Location and/or the leasehold improvements
thereon from a third party, the failure of Franchisee to cure any and all defaults under the terms and provisions of any
such lease or sublease within the time provided for the curing of any such default(s) in any such lease or sublease;

q.    Any misrepresentation by Franchisee or any violation of the Anti-Terrorism Laws by Franchisee or
its  employees  shall  constitute  grounds  for  immediate  termination  of  this  Agreement  and  any  other  agreement
Franchisee has entered into with Franchisor or one of Franchisor's Affiliates.

18.3.        Except  for  any  default  by  Franchisee  under  Section  18.2,  or  as  otherwise  expressly  provided  in  this
Agreement, Franchisee shall have 10 days (5 days in the case of any default in the timely payment of sums due to
Franchisor  or  its  affiliates  or  to  vendors  for  any  products,  services  or  required  fees  due  to  such  vendors),  after
Franchisor's  written  notice  of  a  material  default  within  which  to  remedy  any  material  default  under  this  Agreement,
and to provide evidence of such remedy to Franchisor. If any such default is not cured within that time period, or such
longer time period as applicable law may require or as Franchisor may specify in the notice of default, this Agreement
and all rights granted by it shall thereupon automatically terminate without further notice or opportunity to cure.

18.4.        Franchisee  shall  be  in  material  default  under  this  Section  for  any  failure  to  comply  with  any  of  the
requirements imposed by this Agreement. Such material defaults shall include, but are not limited to, the occurrence
of any one or more of the following events:

a.    Failure of Franchisee to pay to Franchisor, its affiliates or any third-parties any fees, costs, charges

or other amounts due;

b.        Failure  of  Franchisee  to  pay  when  due  any  rent,  taxes  or  other  payments  required  under  any

sublease with Franchisor for the Location;

c.        Failure  of  Franchisee  to  cure  any  default  by  Franchisee  under  any  loan,  note  or  other  obligation
which is obtained to assist Franchisee to make any payment due Franchisor hereunder or which is secured by all or
any  part  of  Franchisee's  interest  in  the  Restaurant,  the  Location,  and/or  the  improvements  or  furniture,  fixtures  or
equipment therein;

d.     The attachment of any involuntary lien in the sum of One Thousand Dollars ($1,000.00) or more
upon any of the business assets or property of Franchisee, which lien is not removed, or for which Franchisee does
not post a bond sufficient to satisfy such lien, within thirty (30) days of the filing of such lien;

e.        The  failure  of  Franchisee  and/or  its  affiliates  to  cure  any  and  all  defaults  under  the  terms  and
provisions  of  any  other  agreement  with  Franchisor,  or  any  third  party  relating  to  this  franchise  or  the  operation  or
ownership of the Restaurant, including any other Franchise Agreement, lease or promissory note between Franchisor

or  its  affiliate  and  Franchisee  within  the  time  provided  for  the  curing  of  any  such  defaults  in  any  such  other
agreement, lease or promissory note;

f.    Franchisee’s misuse or unauthorized use of the El Pollo Loco® Marks;

g.       Failure of Franchisee to comply with any standard or requirement of this Agreement which is not

otherwise covered in this Section 18.

18.5.    Notwithstanding anything to the contrary contained in this Section 18, in the event any valid, applicable
law of a competent governmental authority having jurisdiction over this Agreement and the parties hereto shall limit
Franchisor’s  rights  of  termination  hereunder  or  shall  require  longer  notice  periods  than  those  set  forth  above,  this
Agreement  shall  be  deemed  amended  to  conform  to  the  minimum  notice  periods  or  restrictions  upon  termination
required  by  such  laws  and  regulations.  Franchisor  shall  not,  however,  be  precluded  from  contesting  the  validity,
enforceability or application of such laws or regulations in any action, hearing or dispute relating to this Agreement or
the termination thereof.

18.6.    Franchisor shall not, and cannot be held in breach of this Agreement until (i) Franchisor has received
written  notice  from  Franchisee  describing  in  detail  any  alleged  breach;  and  (ii)  Franchisor  has  failed  to  remedy  the
breach within a reasonable period of time after such notice, which period shall not be less than 60 days plus such
additional  time  as  reasonably  required  by  Franchisor  if  because  of  the  nature  of  the  alleged  breach  it  cannot
reasonably be cured within said 60 days, provided Franchisor promptly commences and continues diligently to cure
such  alleged  breach.  Except  for  breach  hereof  by  Franchisor  (subject  to  the  preceding  sentence)  or  as  permitted
under Section 23.17 hereof, Franchisee shall have no right to terminate this Agreement.

19.

RIGHTS AND OBLIGATIONS UPON TERMINATION

19.1.    In the event of expiration or earlier termination of this Agreement:

a.    Franchisee shall promptly cease to use, in any manner and for any purpose, directly or indirectly,
the  El  Pollo  Loco®  Marks,  the  El  Pollo  Loco®  System,  Franchisor’s  trade  secrets,  proprietary  information,  policies,
procedures, techniques, methods and materials used by Franchisee in connection with the franchise relationship and
shall immediately return to Franchisor, or certify as destroyed any and all (including electronic) copies of any of the
foregoing, including, but not limited to:

i.    Specifications, recipes and descriptions of food products;

ii.    The Manual, memoranda, bulletins, forms, reports, instructions and supplements thereto;

iii.    Training methods and materials provided by Franchisor hereunder;

iv.    Brochures, posters and other advertising materials; and

v.        All  items  bearing  or  containing  the  El  Pollo  Loco®  Marks,  including  without  limitation,  all
trademarks,  trade  names,  service  marks,  logotypes,  designs  and  other  identifying  symbols  and  names  pertaining
thereto.

b.    Franchisee shall immediately remove, obliterate or destroy all Signs and advertisements identifiable
in any way with Franchisor's name and perform such reasonable redecoration and remodeling of the Restaurant and
the Location as may be necessary, in Franchisor's judgment, to distinguish it from an El Pollo Loco® restaurant. To
the extent that Franchisor is required under applicable law to repurchase certain goods from Franchisee, Franchisee
hereby  grants  to  Franchisor  the  option  to  purchase  all  paper  goods,  containers  and  all  other  items  containing
Franchisor's name or the El Pollo Loco® Marks which are in re-saleable or reusable condition at the lower of their cost
or fair market value at the time of termination;

c.    Franchisor may retain all fees paid pursuant to this Agreement;

d.        On  any  termination  or  expiration  of  this  Agreement,  whether  due  to  a  default  of  Franchisee  or
otherwise, Franchisor shall have the right, at its option, for thirty (30) days after such termination or expiration to elect
to purchase Franchisee's interest in the leasehold improvements and furniture, fixtures, equipment, and any or all of
the other tangible Restaurant assets (collectively, “Assets”) at a purchase price equal to the lesser of Franchisee's
cost or the fair market value of such Assets, and to purchase Franchisee's inventory at Franchisee's cost thereof. If
the parties hereto cannot agree on the fair market value for the Assets within forty-five (45) days of any such date of
termination or expiration, Franchisor shall designate an independent appraiser whose determination shall be binding.
If Franchisor elects to exercise any option to purchase as herein provided, it shall have the right to set off all amounts
due from Franchisee and the costs of the appraisal, if any, against any payment therefor;

e.    Should Franchisee fail to perform any of these tasks, the Franchisor’s personnel and representative
shall  have  the  right  to  enter  the  Restaurant  at  any  time,  with  or  without  notice,  for  the  purposes  of  removing  all
trademarks, trade names, service marks, logotypes, designs and other identifying symbols and names pertaining to
El  Pollo  Loco  brand  and  to  remove,  obliterate  or  destroy  all  Signs  and  advertisements  identifiable  in  any  way  with
Franchisor's name and perform such reasonable redecoration and remodeling of the Restaurant and the Location as
may  be  necessary,  in  Franchisor's  judgment,  to  distinguish  it  from  an  El  Pollo  Loco®  restaurant.  The  cost  of
performing this will be billed to Franchisee and payable within five (5) days of receipt of invoice; and

f.    Franchisee shall comply with the covenants set forth in Section 21.7 of this Agreement.

19.2.    Upon the expiration or termination of this Agreement, Franchisee shall promptly pay all sums owing to
Franchisor and its subsidiaries and affiliates. In the event of termination by reason of any default of Franchisee, such
sums shall include all damages (including, but not limited to, any lost future royalties and advertising fees), costs and
expenses, including reasonable attorneys' fees, incurred by Franchisor as a result of the default, which obligation to
pay all such sums shall give rise to and remain, until paid in full, a lien in favor of Franchisor against any and all of the
personal  property,  furnishings,  equipment,  Signs,  fixtures,  and  inventory  owned  by  Franchisee  located  in  the
Restaurant operated  hereunder  at  the  time  of  any  such  default. Franchisee shall pay interest to Franchisor on any
amounts which may become due to Franchisor from Franchisee, if such are not paid when due, at the rate of fifteen
percent (15%) per annum or the maximum interest rate permitted by law, whichever is less.

19.3.    The expiration or termination of this Agreement shall be without prejudice to the rights and remedies of
Franchisor against Franchisee. Furthermore, such expiration or termination shall neither release Franchisee or any of
its obligations and liabilities to Franchisor existing at the time thereof nor terminate those obligations and liabilities of
Franchisee which, by their nature, survive the expiration or termination of this Agreement.

19.4.        Upon  expiration  or  termination  of  this  Agreement,  Franchisor  may  remove  all  references  to  the

Franchise and/or to the Restaurant from its website(s).

19.5.    Franchisee expressly agrees that the existence of any claims it may have against Franchisor, whether
or  not  arising  from  this  Agreement,  shall  not  constitute  a  defense  to  the  enforcement  by  Franchisor  of  any  of  the
provisions  of  this  Section  19,  including  the  covenants  in  Section  21.7.  Franchisee  agrees  to  pay  all  costs  and
expenses  (including  reasonable  attorneys’  fees)  incurred  by  Franchisor  in  connection  with  the  enforcement  of  this
Section 19.

20.

RIGHTS TO A SUCCESSOR FRANCHISE

20.1.       Franchisee shall have the right, subject to the conditions contained in this Section 20.1, to acquire a
successor  franchise  for  the  Restaurant  on  the  terms  and  conditions  of  Franchisor's  then-current  form  of  Franchise
Agreement and for a term of ten (10) years (a "Successor Term") commencing on the expiration of the term of this
Agreement.  The  then-current  form  of  franchise  agreement  may  have  different  terms  and  conditions  such  as  a
different  protected  area,  higher  royalty  and/or  advertising  fees,  no  additional  successor  or  renewal  term  upon
expiration and other modifications to reflect that the then-current form of franchise agreement relates to the grant of a
renewal.  Franchisee's  right  to  a  successor  franchise  shall  be  conditioned  upon  the  satisfaction  of  each  of  the
following  conditions  prior  to  the  expiration  of  the  term  of  this  Agreement:  (a)  Franchisee  is  in  compliance  with  this

Agreement in all respects including financial and operational compliance and has been in substantial compliance with
this Agreement throughout the term; (b) Franchisee meets Franchisor’s then-current criteria for renewing franchisees,
which includes but is not limited to financial and operational standards; (c) Franchisor has not notified Franchisee of
its  decision  that  any  federal  or  applicable  state  legislation,  regulation  or  rule  which  is  enacted,  promulgated  or
amended  after  the  date  hereof  may  have  an  adverse  effect  on  Franchisor's  rights,  remedies  or  discretion  in
franchising El Pollo Loco® restaurants; (d) Franchisee maintains the right to possession of the Location for the term of
the successor Franchise Agreement; (e) Franchisee shall have paid the renewal fee described in the final sentence of
this  Section  20.1;  and  (f)  Franchisee  satisfies  each  of  the  conditions  and  executes  and  delivers  the  agreement
described  in  Sections  20.2,  20.3  and  20.4  below.  At  the  time  of  exercise,  Franchisee  will  be  obligated  to  pay  a
renewal fee equal to 50% of Franchisor's then-current standard initial franchise fee if Franchisee elects a Successor
Term. Solely as Franchisor’s sole and absolute right to determine, Franchisee may be offered a successor franchise
for a term different than the standard ten (10) years to run concurrent with the remaining term of the (sub)lease for
where  the  Restaurant  is  located.  This  pro-rated  term  successor  Franchise  Agreement  (“Pro-rated  Successor
Franchise  Agreement”)  will  use  the  then-current  form  of  Franchise  Agreement  (modified  as  described  above).  In
order to qualify for the Pro-rated Successor Franchise Agreement, Franchisee must meet the same conditions listed
above from (a) to (f) and Franchisee will be obligated to pay a renewal fee equal to 50% of Franchisor’s then-current
standard initial franchise fee pro-rated to the remaining (sub)lease term.

20.2.    Franchisee must give Franchisor written notice of Franchisee's desire to acquire a successor franchise
at  least  three  hundred  sixty  (360)  days  prior  to  the  expiration  of  this  Agreement.  Franchisor  will  give  Franchisee
notice, not later than sixty (60) days after receipt of notice, of Franchisor's decision as to whether or not Franchisee
has  the  right  to  acquire  a  successor  franchise  pursuant  to  Section  20.1.  Notwithstanding  notice  of  Franchisor's
decision  that  Franchisee  has  the  right  to  acquire  a  successor  franchise  for  the  Restaurant,  Franchisee's  right  to
acquire  a  successor  franchise  will  be  subject  to  Franchisee's  continued  compliance  with  all  of  the  terms  of  this
Agreement up to the date of its expiration.

20.3.        If  Franchisee  exercises  the  right  to  acquire  a  successor  franchise  in  accordance  with  Section  20.2
above, Franchisee shall enter into an agreement with Franchisor within sixty (60) days following delivery of the written
notice  pursuant  to  Section  20.2,  agreeing  to  remodel  the  Restaurant,  add  or  replace  improvements,  fixtures,
furnishings, equipment and Signs, and otherwise modify to upgrade the Restaurant to the specifications, image and
standards then applicable for new El Pollo Loco® restaurants. All such remodelings, additions and replacements must
be completed prior to the effective date of such successor Franchise Agreement.

20.4.        If  Franchisee  has  the  right  to  acquire  a  successor  franchise  in  accordance  with  Section  20.1  and
exercises  that  right  in  accordance  with  Section  20.2,  the  parties  must  execute  the  form  of  Franchise  Agreement
(which  may  contain  provisions,  including  royalty  and  advertising  fees,  materially  different  from  those  contained
herein)  and  all  ancillary  agreements  which  Franchisor  then  customarily  uses  in  granting  renewal  franchises  for  the
operation  of  El  Pollo  Loco®  restaurants,  and  Franchisee  must  execute  general  releases,  in  form  and  substance
satisfactory  to  Franchisor,  of  any  and  all  claims  against  Franchisor  and  its  affiliates,  officers,  directors,  employees,
agents, successors and assigns. Failure by Franchisee to sign such agreements and releases within thirty (30) days
after delivery thereof to Franchisee shall be deemed an election by Franchisee not to acquire a successor franchise.

21.

PROPRIETARY RIGHTS AND UNFAIR COMPETITION

21.1.    In the event of any claim of or challenge to Franchisee's use of the El Pollo Loco® Marks licensed under

this Agreement, Franchisee shall immediately notify Franchisor in writing of the facts of such claim or challenge.

a.        Franchisor  shall  protect  and  defend  Franchisee  against  any  claims  or  challenges  arising  out  of

Franchisee's proper use of the El Pollo Loco® Marks licensed hereunder.

b.        Franchisor  shall  reimburse  Franchisee  for  all  damages  for  which  it  is  held  liable  in  any  such
proceeding; however, the foregoing obligations of Franchisor to protect, defend and reimburse Franchisee will exist
only if Franchisee has used the name or mark which is the subject of the controversy in strict accordance with the
provisions of this Agreement and the rules, regulations, procedures, requirements and instructions of Franchisor and
has notified Franchisor of the challenge as set forth above.

c.    Any action to be taken in the event of a claim or challenge to any of the El Pollo Loco® Marks shall
be solely and absolutely within Franchisor’s right to determine. Franchisor shall have the sole and absolute right to
control any legal actions or proceedings resulting therefrom. Any actions taken to protect the El Pollo Loco® Marks
shall  also  be  within  the  sole  and  absolute  right  to  determine  and  control  of  Franchisor.  Franchisee shall cooperate
fully  with  Franchisor  in  the  prosecution  or  defense  of  any  claim  or  challenge  concerning  any  of  the  El  Pollo  Loco®
Marks.

21.2.        If  it  becomes  advisable  at  any  time,  as  the  sole  and  absolute  right  of  Franchisor,  to  modify  or
discontinue the use of any one or more of the El Pollo Loco® Marks or to use one  or  more  additional  or  substitute
names, marks or copyrights, Franchisee shall immediately comply with the instructions of Franchisor in that regard. In
such event, the sole obligation of Franchisor will be to reimburse Franchisee for the actual costs, such as replacing
sign faces, of physically complying with this obligation.

21.3.    Franchisee acknowledges and agrees that at all times and in all respects, the El Pollo Loco® Marks are
the sole property of Franchisor and that Franchisee has only a license to use such rights and marks according to the
provisions  hereof.  Franchisee  shall  make  no  application  for  registration  of  any  identifying  name  or  mark  licensed
herein  or  similar  thereto  without  the  prior  written  consent  of,  and  upon  terms  and  conditions  satisfactory  to,
Franchisor. Franchisee shall not register any of the El Pollo Loco® Marks, part thereof, or anything confusingly similar
thereto, as a domain name, or use, or permit the usage of, any of the same in connection with any Internet web site
or web page. Franchisee shall indicate the required trademark, service mark or copyright notices in the form specified
by  Franchisor  in  connection  with  its  use  of  the  El  Pollo  Loco®  Marks.  Franchisee  shall  take  no  action  which  will
interfere with any of Franchisor's rights in and to the El Pollo Loco® Marks. Franchisee shall not, without Franchisor's
prior written consent, sell, dispense or otherwise provide Franchisor's products or any El Pollo Loco products bearing
the El Pollo Loco® Marks, except by means of retail sales in, or delivered from, the Restaurant.

21.4.    Intranet.

a.        Franchisor  may,  at  its  option,  establish  and  maintain  an  Intranet  through  which  franchisees  of
Franchisor may communicate with each other, and through which Franchisor and Franchisee may communicate with
each  other  and  through  which  Franchisor  may  disseminate  the  Manuals,  updates  thereto  and  other  confidential
information.  Franchisor  shall  have  sole  and  absolute  right  to  determine  and  control  all  aspects  of  the  Intranet,
including the content and functionality thereof. Franchisor will have no obligation to maintain the Intranet indefinitely,
and  may  dismantle  it  at  any  time  without  Franchisor  having  any  liability  to  Franchisee.  (As  used  herein,  the  term
“Intranet”  shall  mean  an  intranet,  extranet  or  other  communication  network  between  and  among  Franchisor  and
Franchisee that is accessed by the Internet. As used herein, the term “Internet” shall mean collectively the myriad of
computer  and  telecommunications  facilities,  including  equipment  and  software,  which  comprise  the  interconnected
worldwide  network  of  networks  that  employ  the  TCP/IP  [Transmission  Control  Protocol/Internet  Protocol],  or  any
predecessor  or  successor  protocols  to  such  protocol,  to  communicate  information  of  all  kinds  by  fiber  optics,  wire,
radio or other methods of electronic communication.)

b.    If Franchisor establishes an Intranet, Franchisee shall have the privilege to use the Intranet, subject
to Franchisee’s strict compliance with the standards and specifications, protocols and restrictions that Franchisor may
establish from time to time. Such standards and specifications, protocols and restrictions may relate to, among other
things, (i) use of abusive, slanderous or otherwise offensive language in electronic communications; (ii) confidential
treatment  of  materials  that  Franchisor  transmits  via  the  Intranet;  (iii)  password  protocols  and  other  security
precautions;  (iv)  grounds  and  procedures  for  Franchisor’s  suspending  or  revoking  a  franchisee’s  access  to  the
Intranet;  and  (v)  a  privacy  policy  governing  Franchisor’s  access  to  and  use  of  electronic  communications  that
franchisees  post  to  the  Intranet.  Franchisee  acknowledges  that,  as  administrator  of  the  Intranet,  Franchisor  can
technically  access  and  view  any  communication  that  any  person  posts  on  the  Intranet.  Franchisee  further
acknowledges that the Intranet facility and all communications that are posted to it will become Franchisor’s property,
free of any claims of privacy or privilege that Franchisee or any other person may assert.

c.        Upon  receipt  of  notice  from  Franchisor  that  Franchisor  has  established  the  Intranet,  Franchisee
shall establish and continually maintain (during all times that the Intranet shall be established and until the termination
of  this  Agreement)  an  electronic  connection  (the  specifications  of  which  shall  be  specified  in  the  Manuals)  with  the
Intranet that allows Franchisor to send messages to and receive messages from Franchisee, subject to the standards
and specifications.

d.        Franchisee  shall  contribute  a  reasonable  amount,  not  to  exceed  $1,000.00  per  year  (which
maximum amount shall increase at a rate of 3% per calendar year during the term of this Agreement, toward the cost
of the Intranet’s maintenance. Such contribution shall be established by Franchisor by not later than March 1 of each
calendar year and shall be payable thirty (30) days thereafter.

e.    If Franchisee shall breach this Agreement or any other agreement with Franchisor or its Affiliates,
Franchisor  may  disable  or  terminate  Franchisee’s  access  to  the  Intranet  without  Franchisor  having  any  liability  to
Franchisee, and in which case Franchisor shall only be required to provide Franchisee a paper copy of the Manuals
and any updates thereto, if none have been previously provided to Franchisee, unless not otherwise entitled to the
Manuals.

21.5.        Franchisor  has  established  a  Website.  As  used  herein,  the  term  “Website”  shall  mean  one  or  more
Internet  websites  that  may,  among  other  things,  provide  marketing  development  operations  and  training  materials,
facilitate catering, take-out and delivery orders, provide information about the System and the products and services
which are offered on such Website and at restaurants operated under the El Pollo Loco® Marks.

a.    Franchisor may, as its sole and absolute right to determine, from time to time, without prior notice to
Franchisee: (i) change, revise, or eliminate the design, content and functionality of the Website; (ii) make operational
changes to the Website; (iii) change or modify the URL and/or domain name of the Website; (iv) substitute, modify, or
rearrange the Website, at Franchisor’s sole option, including in any manner that Franchisor considers necessary or
desirable  to,  among  other  things,  (1)  comply  with  applicable  laws,  (2)  respond  to  changes  in  market  conditions  or
technology, and (3) respond to any other circumstances; (v) limit or restrict end-users access (in whole or in part) to
the Website; and (vi) disable or terminate the Website without Franchisor having any liability to Franchisee.

b.    The Website may include one or more interior pages that identifies restaurants operated under the
El  Pollo  Loco®  Marks,  including  the  Restaurant,  by  among  other  things,  geographic  region,  address,  telephone
number(s), and menu items. The Website may also include one or more interior pages dedicated to franchise sales
by Franchisor and/or relations with Franchisor’s investors.

c.        Franchisor  may,  from  time  to  time,  establish  a  Franchisee  Page.  As  used  herein,  the  term
“Franchisee  Page”  shall  mean  one  or  more  interior  pages  of  the  Website  dedicated  in  whole  or  in  part  to
Franchisee’s  Restaurant.  Franchisor  may  permit  Franchisee  to  customize  or  post  certain  information  to  the
Franchisee  Page,  subject  to  Franchisee’s  execution  of  Franchisor’s  then-current  participation  agreement,  and
Franchisee’s  compliance  with  the  procedures,  policies,  standards  and  specifications  that  Franchisor  may  establish
from  time  to  time.  Such  participation  agreement  may  require  Franchisee  to  pay  a  reasonable  fee  (not  to  exceed
$1,000.00 per year, which maximum shall increase at a rate of 3% per year for the term of this Agreement) for the
privilege of having a Franchisee Page, and may include, without limitation, specifications and limitations for the data
or information to be posted to the Franchisee Page, customization specifications, the basic template for design of the
Franchisee  Page,  parameters  and  deadlines  specified  by  Franchisor,  disclaimers,  and  such  other  standards  and
specifications  and  rights  and  obligations  of  the  parties  as  Franchisor  may  establish  from  time  to  time.  Any
modifications (including customizations, alterations, submissions or updates) to the Content made by Franchisor for
any purpose will be deemed to be a “work made for hire” under the copyright laws, and therefore, Franchisor  shall
own the intellectual property rights in and to such modifications. To the extent any modification does not qualify as a
work made for hire as outlined above, Franchisee hereby assigns those modifications to Franchisor for no additional
consideration  and  with  no  further  action  required  and  shall  execute  such  further  assignment(s)  as  Franchisor  may
request.

d.        Without limiting  Franchisor’s  general  unrestricted  right  to  permit,  deny  and  regulate  Franchisee’s
participation  on  the  Website  as  Franchisor’s  sole  and  absolute  right  to  determine,  if  Franchisee  shall  breach  this
Agreement,  or  any  other  agreement  with  Franchisor  or  its  Affiliates,  Franchisor  may  disable  or  terminate  the
Franchisee Page and remove all references to the Restaurant on the Website until said breach is cured.

21.6.    Franchisee acknowledges that, in connection with the operation of the franchise business, Franchisor
will be disclosing confidential information and trade secrets to Franchisee. Franchisee further acknowledges that its
knowledge of, and access to, Franchisor's formulae, recipes, processes, products, techniques, know‑how and other
proprietary information, including without limitation the Manual and the El Pollo Loco® System (collectively referred to

as  the  "Confidential  Information"),  are  derived  entirely  from  the  material  disclosed  to  Franchisee  by  Franchisor.
Franchisee  acknowledges  and  agrees  that  at  all  times  and  in  all  respects,  the  Confidential  Information  is  a  trade
secret  of  Franchisor  and  that  Franchisee  has  only  a  license  to  use  the  Confidential  Information  according  to  the
provisions of this Agreement.

a.        Franchisee,  and  each  officer,  director,  shareholder,  member,  manager,  partner,  and  other  equity
owner,  as  applicable,  of  Franchisee,  if  Franchisee  is  a  Business  Organization,  shall  maintain  fully  and  strictly  the
secrecy  of  all  the  Confidential  Information  and  to  exercise  the  highest  degree  of  diligence  in  safeguarding  the
Confidential  Information  during  and  after  the  term  of  this  Agreement.  Franchisee  shall  divulge  the  Confidential
Information only to Franchisee's employees and only to the extent necessary to permit the efficient operation of the
Restaurant  during  the  effective  term  of  this  Agreement.  After  the  expiration  or  termination  of  this  Agreement,
Franchisee  shall  not  divulge  the  Confidential  Information  to  any  person  or  entity,  nor  shall  Franchisee  use  the
Confidential Information in any manner.

b.        It  is  expressly  agreed  that  the  ownership  of  all  of  the  El  Pollo  Loco®  Marks  and  the  Confidential
Information is and shall remain vested solely in Franchisor. Nothing contained in this Agreement shall be construed to
require Franchisor to divulge to Franchisee any secret processes, formulae, ingredients or other information, except
the material contained in Franchisor's Manual and training materials.

c.        Franchisee  shall  fully  and  promptly  disclose  to  Franchisor,  all  ideas,  concepts,  formulas,  recipes,
methods,  techniques,  and  other  possible  improvements  (each  an  “Improvement”)  relating  to  the  development  or
operation of a quick service flame-grilled food product and/or related service, conceived or developed by Franchisee
or  Franchisee’s  employees  during  the  Term.  Any  and  all  such  Improvements  will  automatically  be  deemed  to  be
Franchisor’s  sole  and  exclusive  property  and  works  made-for-hire;  provided,  however,  for  any  such  improvements
that  do  not  qualify  as  work  made-for-hire  for  Franchisor,  Franchisee  hereby  assigns  ownership  of  that  or  those
Improvements  to  Franchisor  and  covenants  to  execute  whatever  assignment  or  other  documentation  Franchisor
requests in order to evidence such assignment and to assist Franchisor in securing intellectual property rights in the
Improvement.  Franchisee  may  not  test,  offer,  or  sell  any  new  products  without  Franchisor’s  prior  written  consent,
which may be withheld as Franchisor’s sole and absolute right.

21.7.        To  further  protect  the  El  Pollo  Loco®  System  while  this  Agreement  is  in  effect,  Franchisee  and  each
officer,  director,  shareholder,  member,  manager,  partner,  and  other  equity  owner,  as  applicable,  of  Franchisee,  if
Franchisee is a Business Organization, shall neither directly nor indirectly, for itself, himself or herself, or through or
on behalf of, or in conjunction with any person, partnership, corporation or other entity, consult, work for, be employed
by, own any equity interest in, own, operate, control, engage in, provide assistance to, or have any interest (financial
or  otherwise)  in  any  other  business  which  would  constitute  a  "Competitive  Business"  (as  hereinafter  defined)
without the prior written consent of Franchisor; provided further, that Franchisor may, as its sole and absolute right,
consent  to  Franchisee's  continued  operation  of  any  business  already  in  existence  and  operating  at  the  time  of
execution  of  this  Agreement.  In  addition,  Franchisee  covenants  that,  except  as  otherwise  approved  in  writing  by
Franchisor, Franchisee shall not, for a continuous, uninterrupted period commencing upon the expiration, termination
or assignment of this Agreement, regardless of the cause for termination, and continuing for two (2) years thereafter,
either  directly  or  indirectly,  for  itself,  or  through  or  on  behalf  of,  or  in  conjunction  with  any  person,  partnership,
corporation or other entity, consult, work for, be employed by, own equity interest in, own, operate, control, engage in,
provide assistance to, or have any interest (financial or otherwise) in any Competitive Business which is located or
has outlets or restaurant units within a radius of five (5) miles of the location of the Restaurant. The foregoing shall
not apply to operation of an El Pollo Loco® restaurant by Franchisee pursuant to another Franchise Agreement with
Franchisor or the ownership by Franchisee of less than five percent (5%) of the issued or outstanding stock of any
company whose shares are listed for trading on any public exchange or on the over-the-counter market, provided that
Franchisee does not control or become involved in the operations of any such company. For purposes of this Section
21.7, a Competitive Business shall mean a quick-service restaurant or fast-food business which sells chicken and/or
Mexican food products, which products individually or collectively represent more than twenty percent (20%) of the
revenues from such quick-service restaurant or fast-food business operated at any one location during any calendar
quarter. A “Competitive Business” shall not include a full-service restaurant.

21.8.        In  the  event  that  any  provision  of  this  Section  21  shall  be  determined  by  a  court  of  competent
jurisdiction to be invalid or unenforceable, this Agreement shall not be void, but such provision shall be limited to the
extent necessary to make it valid and enforceable.

21.9.    Franchisee understands and acknowledges that Franchisor shall have the right to reduce the scope of
any  obligation  imposed  on  Franchisee  by  Section  21.7,  without  Franchisee’s  consent,  and  that  such  modified
provision shall be effective upon Franchisee’s receipt of written notice thereof.

21.10.    Franchisee acknowledges that violation of the covenants not to compete contained in this Agreement
would result in immediate and irreparable injury to Franchisor for which no adequate remedy at law will be available.
Accordingly,  Franchisee  hereby  consents  to  the  entry  of  a  preliminary  and  permanent  injunction  prohibiting  any
conduct  by  Franchisee  in  violation  of  the  terms  of  those  covenants  not  to  compete  set  forth  in  this  Agreement.
Franchisee expressly agrees that it may conclusively be presumed that any violation of the terms of said covenants
not  to  compete  was  accomplished  by  and  through  Franchisee’s  unlawful  utilization  of  Franchisor’s  Confidential
Information, know-how, methods and procedures.

22.

DISPUTE RESOLUTION

22.1.    Initial Meeting and Mediation – Except as otherwise provided in this Agreement, before any legal action
involving  any  claim  or  controversy  between  Franchisor  and  Franchisee  (including  its  affiliates)  relating  to  (a)  this
Agreement, (b) the parties’ business activities conducted as a result of this Agreement, or (c) the parties’ relationship
or business dealings with each other generally is filed, the following procedures shall be complied with:

a.       The  party  wishing  to  resolve  a  dispute  shall  initiate  negotiation  proceedings  by  first  requesting  in
writing a meeting. Within forty-five (45) days of receipt of the initial request for such a meeting, the parties shall meet,
discuss  and  negotiate  toward  a  resolution  of  the  controversy  at  a  location  within  the  county  in  which  Franchisor  is
then located.

b.        If  negotiation  efforts  do  not  succeed,  the  parties  shall  engage  in  mandatory  but  non-binding
mediation by a mediator jointly chosen by the parties or if the parties cannot agree upon a mediator, appointed by,
and  in  accordance  with  the  procedures  of,  JAMS  or,  if  JAMS  is  no  longer  in  existence,  an  organization  of  similar
quality.

c.    A mediation meeting will be held at a place and at a time mutually agreeable to the parties and the
mediator. The Mediator will determine and control the format and procedural aspects of the mediation meeting which
will  be  designed  to  ensure  that  both  the  mediator  and  the  parties  have  an  opportunity  to  present  and  hear  an  oral
presentation of each party’s views regarding the matter in controversy. The parties will act in good faith to resolve the
controversy in mediation.

d.    The mediation will be held as soon as practicable after the negotiation meeting is held.

e.    The mediator will be free to meet and communicate separately with each party either before, during

or after the mediation meeting within 60 days of demand by either party.

22.2.    At the election of Franchisor, the provisions of this Section 22 shall not apply to controversies relating to
any fee due Franchisor by Franchisee or its affiliates, any promissory note payments due Franchisor by Franchisee,
or any trade payables due Franchisor by Franchisee as a result of the purchase of equipment, goods or supplies. The
provisions of this Section 22 shall also not apply to any controversies relating to the use and protection of the El Pollo
Loco Marks, the Manual or the El Pollo Loco System, including without limitation, Franchisor’s right to apply to any
court of competent jurisdiction for appropriate injunctive relief for the infringement of the El Pollo Loco Marks or the El
Pollo Loco System.

23. MISCELLANEOUS PROVISIONS

23.1.       In  the  event  that  Franchisee  is  comprised  of  more  than  one  person,  firm,  corporation  or  other  entity,
Franchisee's rights, privileges, interests, obligations and liabilities under this Agreement shall be joint and several with
respect to such persons, firms, corporations or other entities.

23.2.        If  Franchisee  is  a  Business  Organization,  Franchisor  will  require,  as  a  condition  to  the  effectiveness
hereof, the written guarantee and assumption of Franchisee's obligations hereunder by any or all of the shareholders,
members,  partners,  other  equity  owners,  as  applicable,  of  a  Business  Organization  and/or  some  other  natural
persons associated with Franchisee, the form of which is attached hereto as Exhibit 2. Franchisor may also require
that  Franchisee  maintain  transfer  instructions  restricting  a  transfer  on  its  records  of  any  securities,  partnership
interests  or  other  ownership  interests  in  violation  of  the  restrictions  set  forth  in  Section  17  and  that  each  stock,
partnership or other ownership certificate of Franchisee shall have conspicuously endorsed upon its face a statement
in  form  satisfactory  to  Franchisor  that  further  assignment  or  transfer  thereof  is  subject  to  each  of  the  restrictions
imposed upon assignments by this Agreement.

23.3.    All notices required under this Agreement shall be in writing and shall be either (i) served personally; (ii)
sent  by  certified  or  registered  United  States  mail  to  the  party  to  be  charged  with  receipt  thereof;  (iii)  by  reputable
overnight delivery service or (iv) sent via facsimile. Notices served personally are effective immediately on delivery,
and those served by mail shall be deemed given forty-eight (48) hours after deposit of such notice in a United States
post office with postage prepaid and duly addressed to the party to whom such notice or communication is directed.
Notices served by overnight delivery shall be deemed to have been given the day after deposit of such notice with
such service. Notices  served  via  facsimile  shall  be  deemed  to  have  been  given  the  day  of  faxing  such  notice.  The
address  for  Franchisor  shall  be:  Attention:  Director  of  Legal  Services,  El  Pollo  Loco,  Inc.,  3535  Harbor  Blvd,  Suite
100, Costa Mesa, California 92626, and the address and facsimile number for Franchisee shall be the address and
facsimile number listed on the cover page of this Agreement. Franchisor or Franchisee may from time to time change
its  address  for  notice  pursuant  to  this  Section  by  giving  a  written  notice  of  such  change  to  the  other  party  in  the
manner provided herein. Notwithstanding anything to the contrary contained herein, Franchisor may deliver bulletins
and updates to the Manual by electronic means, such as by the internet (e-mail) or an intranet, if any, established by
Franchisor.

23.4.        Notwithstanding  the  above,  Franchisor  may  elect  to  utilize  email  or  similar  communications  to
Franchisee for the purpose of communicating System modifications, operations, marketing and other bulletins, menu
changes, product or equipment safety or recall alerts, or any other message Franchisor determines, and Franchisee
hereby acknowledges that such communications will constitute actionable communication under this Agreement and
shall ensure that Franchisee’s communications system includes the capability, and is set or programmed, to receive
such communications from Franchisor on a continual basis throughout the Term. Franchisee must never  opt  out  or
refuse to accept any of such Franchisor communications at any time during the Term.

23.5.        The  receipt  and  acceptance  by  either  party  of  any  delinquent  payment  due  hereunder  shall  not
constitute a waiver of any other default. No delay or omission in the exercise of any right or remedy of either party
upon any default by the other hereunder shall impair such right or remedy or be construed as a waiver of any term,
covenant or condition of this Agreement to be performed by the other party. To be effective, any waiver of any other
default  must  be  in  writing  and  shall  not  constitute  a  waiver  of  any  other  default  concerning  the  same  or  any  other
term, covenant or condition of this Agreement.

23.6.        Franchisor's  consent  to  or  approval  of  any  act  or  conduct  of  Franchisee  requiring  such  consent  or
approval shall not be deemed to waive or render unnecessary Franchisor's consent to or approval of any subsequent
act or conduct hereunder.

23.7.    The provisions of this Agreement are intended by the parties to be a complete and exclusive expression
of  their  agreement.  No  other  agreements,  representations,  promises,  commitments  or  the  like,  of  any  nature,  exist
between  the  parties  except  as  set  forth  or  referenced  herein.  Notwithstanding  the  foregoing,  nothing  in  this
Agreement shall disclaim or require Franchisee to waive reliance on any representation that Franchisor made in the
most recent disclosure document (including its exhibits and amendments) that Franchisor delivered to Franchisee or
its  representative,  subject  to  any  agreed-upon  changes  to  the  contract  terms  and  conditions  described  in  that
disclosure document and reflected in this Agreement (including any riders or addenda signed at the same time as this
Agreement).  The  provisions  of  this  Agreement  may  not  be  contradicted  by  any  other  statement  concerning  the
subject matter herein. Furthermore, this Agreement may not be amended or modified except by a written agreement
signed by the parties hereto.

23.8.    In the event of the bringing of any action by either party against the other arising out of or in connection
with this Agreement or the enforcement thereof, or by reason of the breach of any term, covenant or condition of this
Agreement on the part of either party, the party in whose favor final judgment is entered shall be entitled to have and

recover from the other party reasonable attorneys' fees plus costs and expenses reasonably incurred to be fixed by
the court rendering such judgment.

23.9.    This Agreement shall be governed by and construed in accordance with the laws of the state in which
Franchisor’s  then-current  headquarters  is  located  (i.e.,  currently,  the  State  of  California);  provided  however  that:  (i)
the  provisions  in  Section  21.7  covering  competition  following  the  expiration,  termination  or  assignment  of  this
Agreement shall be governed by the laws of the state in which the breach occurs; (ii) the provisions of any law of a
state regarding franchises (including registration, disclosure or relationship issues, and the regulations promulgated
thereunder)  shall  not  apply  unless  such  state’s  jurisdictional,  definitional  and  other  requirements  are  met
independently  of,  and  without  reference  to,  this  Section;  and  (iii)  if  any  matter  related  to  this  Agreement  would  be
unenforceable  under  the  laws  of  the  state  where  Franchisor’s  then-current  headquarters  is  located,  but  would  be
enforceable  under  the  laws  of  the  state  in  which  the  Franchisee  is  based,  then  the  laws  of  the  state  in  which  the
Franchisee  is  based  shall  apply  to  such  matter.  ANY  ACTION  BROUGHT  BY  EITHER  PARTY  AGAINST  THE
OTHER  IN  ANY  COURT,  WHETHER  FEDERAL  OR  STATE,  SHALL  BE  BROUGHT  WITHIN  THE  STATE  IN
WHICH  FRANCHISOR’S  HEADQUARTERS  (CURRENTLY  THE  STATE  OF  CALIFORNIA)  IS  THEN  LOCATED.
THE ACTION SHALL BE BROUGHT IN FEDERAL COURT IF FEDERAL COURT JURISDICTION IS AVAILABLE
AND, IF NOT, IN STATE COURT. THE PARTIES HEREBY WAIVE ANY RIGHT TO DEMAND OR HAVE TRIAL BY
JURY IN ANY ACTION RELATING TO THIS AGREEMENT IN WHICH FRANCHISOR IS A PARTY. THE PARTIES
CONSENT  TO  THE  EXERCISE  OF  PERSONAL  JURISDICTION  OVER  THEM  BY  SUCH  COURTS  IN
CALIFORNIA  AND  TO  THE  PROPRIETY  OF  VENUE  OF  SUCH  COURTS  FOR  THE  PURPOSE  OF  CARRYING
OUT THIS PROVISION, AND EACH PARTY WAIVES ANY OBJECTION THAT IT WOULD OTHERWISE HAVE TO
THE  SAME.  ANY  ACTION  BETWEEN  FRANCHISEE  AND  FRANCHISOR  SHALL  INVOLVE  ONLY  THE
INDIVIDUAL  CLAIMS  OF  FRANCHISEE  AND  SHALL  NOT 
INVOLVE  ANY  CLASS,  GROUP,  JOINT,
CONSOLIDATED, REPRESENTATIVE OR ASSOCIATIONAL ACTION.

23.10.    Except with respect to Franchisee's obligation to indemnify Franchisor pursuant to Sections 9.3 and
9.4 of this Agreement, the parties waive to the fullest extent permitted by the law any right to or claim for any punitive
or exemplary damages against the other and agree that, in the event of a dispute between them, the party making a
claim  shall  be  limited  to  recovery  of  any  actual  damages  it  sustains  and  injunctive  relief.  Any  and  all  claims  and
actions  arising  out  of  or  relating  to  this  Agreement,  the  relationship  of  Franchisee  and  Franchisor,  or  Franchisee’s
operation of the Restaurant, brought by either party hereto against the other, whether in mediation, or a legal action,
shall be commenced within one (1) year from the occurrence of the facts giving rise to such claim or action, or such
claim or action shall be barred.

23.11.    Any provision of this Agreement which may be determined by competent authority to be prohibited or
unenforceable  in  any  jurisdiction  shall,  as  to  that  jurisdiction,  be  ineffective  to  the  extent  of  the  prohibition  or
unenforceability  without  invalidating  the  remaining  provisions  of  this  Agreement.  Any  prohibition  against  or
unenforceability  of  any  provision  of  this  Agreement  in  any  jurisdiction,  including  the  state  whose  law  governs  this
Agreement,  shall  not  invalidate  the  provision  or  render  it  unenforceable  in  any  other  jurisdiction.  To  the  extent
permitted by applicable law, Franchisee waives any provision of law which renders any provision of this Agreement
prohibited or unenforceable in any respect.

23.12.        Franchisee  recognizes  the  unique  value  and  secondary  meaning  attached  to  the  El  Pollo  Loco®
System, the El Pollo Loco® Marks, the Confidential Information and the associated standards of operation and trade
practices, and Franchisee agrees that any noncompliance with the terms of this agreement or any unauthorized or
improper use will cause irreparable damage to Franchisor and its franchisees. Franchisee therefore agrees that if it
should engage in any such unauthorized or improper use, during or after the term of this Agreement, Franchisor shall
be entitled to both permanent and temporary injunctive relief from any court of competent jurisdiction in addition to
any other remedies prescribed by law. Franchisee agrees and acknowledges that in such event, Franchisee may be
required to post a bond while Franchisor shall not be required to post a bond.

23.13.        Franchisee  shall  grant  no  security  interest  in  the  franchise  or  in  any  of  the  tangible  assets  of  the
business including the furniture, fixtures and equipment located in the Restaurants, unless the secured party agrees
that  in  the  event  of  any  default  by  Franchisee  and  exercise  of  its  right  to  take  and  sell  such  assets  under  any
documents  relating  to  such  security  interests,  Franchisor  shall  have  the  right  and  option  to  exercise  a  right  of  first
refusal to purchase such assets on the same terms and conditions offered by the secured party. If, within thirty (30)
days after receipt of the offer, which would include information and documentation as Franchisor may need or require
for the purpose of considering whether to exercise its right of first refusal to purchase such assets, Franchisor does

not indicate its acceptance of the offer as stated in the notice, secured party shall thereafter have the right to make
the sale to the proposed transferee on the same terms and conditions as stated in the notice. Should Franchisor not
exercise its right of first refusal and should the contemplated sale not be completed within one hundred (120) days
from  the  date  of  the  notice,  or  should  the  terms  and  conditions  thereof  (including  the  proposed  transferee  or  the
ownership  therein)  be  altered  in  any  material  way,  this  right  of  first  refusal  shall  be  reinstated  and  any  such
subsequent  proposed  sale  or  altered  terms  and  conditions  of  the  current  transaction  must  again  be  offered  to
Franchisor in accordance with the terms listed above.

23.14.       This Agreement shall be binding upon and inure to the benefit of the parties hereto, their permitted

heirs, successors and assigns.

23.15.    This Agreement shall not be binding upon Franchisor unless and until it shall have been accepted and
signed by authorized officers of Franchisor. This Agreement may be executed in one or more counterparts, each of
which  will  constitute  an  original,  but  all  of  which  together  will  constitute  but  a  single  document.  A  signature  on  this
Agreement transmitted via facsimile or electronic mail shall be considered an original for all purposes hereunder.

23.16.    The parties intend to confer no benefit or right on any person or entity not a party to this Agreement,
and no third party shall have the right to claim the benefit of any provision hereof as a third party beneficiary of any
such provision.

23.17.    If following commencement of business at the Restaurant, the Restaurant is damaged or destroyed to
the extent that Franchisor determines that the Restaurant must be closed for repairs for more than sixty (60) days, or
if the Location is taken by condemnation proceedings or Franchisee's lease is terminated through no act or failure to
act  on  its  part  (except  the  failure  to  utilize  any  available  options  to  extend  such  lease,  or  Franchisee’s  willful
truncation of such lease), then at Franchisor’s option, Franchisor may elect to:

a.        terminate  this  Agreement,  require  Franchisee  to  relocate  the  Restaurant,  or  in  the  case  of  a

casualty, require Franchisee to rebuild the Restaurant.

b.        require  Franchisee  to  rebuild  the  Restaurant,  Franchisee  shall,  at  its  own  expense,  repair  or
reconstruct the Restaurant, and such construction shall be completed and the Restaurant shall reopen for business
not  later  than  twelve  (12)  months  following  the  date  the  triggering  event  occurred.  The  minimum  acceptable
appearance for the reconstructed Restaurant will be that which existed just prior to the casualty; however, every effort
shall be made to have the reconstructed Restaurant reflect the then-current image, design and specifications of new
El Pollo Loco® restaurants.

c.    require Franchisee to relocate the Restaurant, Franchisee must execute Franchisor’s then-current
form  of  Development  Agreement  within  thirty  (30)  days  of  the  date  Franchisor  notifies  Franchisee  of  Franchisor’s
election.  Franchisee  must  follow  the  site  selection  and  approval  procedures  associated  with  the  Development
Agreement; provided, however, that no development fee shall be required to be paid. Upon approval by Franchisor of
a new site, Franchisee must execute Franchisor’s then-current form of Franchise Agreement; provided, however, that
the term of such new agreement shall be equal to the remaining term of this Agreement and Franchisee shall not be
required  to  pay  a  new  initial  franchise  fee.  Franchisee  will  submit  a  replacement  site  for  the  new  Restaurant,  in
accordance  with  the  time  frames  indicated  in  the  then-current  form  of  Development  Agreement,  and  which
replacement site shall be located in an area defined as a radius surrounding the existing site of the Restaurant, the
exact  dimensions  of  which  shall  be  reasonably  negotiated  between  Franchisee  and  Franchisor  taking  into
consideration  the  rights  of  other  then-existing  and  potential  franchisees.  If  Franchisor  approves  the  new  site,
Franchisee shall either acquire or lease the site and design, construct and furnish the Restaurant in conformance with
the  design  and  construction  requirements  imposed  by  Franchisor  for  new  El  Pollo  Loco®  restaurants.  The  new
Restaurant must be open for business not later than twelve (12) months following the date of the casualty or loss of
possession of the original Location.

d.        terminate  the  Franchise  Agreement,  Franchisee  shall  promptly  comply  with  the  requirements  set

forth at Sections 19.1 and 19.2.

24.

EFFECTIVE DATE

24.1.    This Agreement shall be effective as of the date it is executed by Franchisor.

25.

ACKNOWLEDGMENTS

25.1.        Franchisee  acknowledges  that  Franchisee  has  received  a  complete  copy  of  the  El  Pollo  Loco®
Disclosure Document, together with all exhibits, issuance date March 26, 2019 (Control Number 032619), at least 14
calendar days prior to the date on which this Agreement was executed by Franchisee or payment of any monies to
Franchisor.

25.2.       Franchisee  acknowledges  that  it  has  read  and  understands  this  Agreement,  the  attachments  thereto
and  the  agreements  relating  thereto,  if  any,  contained  in  the  Disclosure  Document  received  by  Franchisee  on
_________________,  and  that  Franchisor  has  accorded  Franchisee  ample  opportunity  and  has  encouraged
Franchisee to consult with advisors of Franchisee's own choosing about the potential benefits and risks of entering
into this Agreement.

25.3.        The  execution  of  this  Agreement  by  Franchisee  will  not  constitute  or  violate  any  other  agreement  or

commitment to which Franchisee is a party.

25.4.    Each individual executing this Agreement on behalf of Franchisee is duly authorized to do so, and this

Agreement constitutes a valid and binding obligation of Franchisee.

25.5.    Franchisee has entered into this Agreement in reliance on information in this Agreement, the Disclosure
Document,  and  its  own  investigations,  and  did  not  rely  on  any  promise,  representation,  statement,  or  undertaking
made  by  Franchisor  or  Franchisor’s  representatives  that  is  not  included  in  this  Agreement  or  the  Disclosure
Document or that is in conflict with any statement or representation in this Agreement or the Disclosure Document; in
particular, Franchisee has not received or relied on any data, representation, projection, forecast, estimate, warranty,
assurance, or other communication, expressed or implied, as to actual or potential sales volume, profit, or success of
the Restaurant.

25.6.        Franchisee  understands  and  acknowledges  the  value  to  the  System  and  to  the  uniform  and  ethical
standards of quality, consistency, appearance, and service described in and required by the Operations Manual and
the  necessity  of  operating  the  franchised  business  under  the  standards  set  forth  in  the  Operations  Manual;  and,
Franchisee has the capabilities, professionally, financially and otherwise, to comply with the standards of Franchisor.

25.7.        Franchisee  has  carefully  read  this  Agreement  and  all  other  related  documents  to  be  executed  by
Franchisee concurrently or in conjunction with the execution hereof, has obtained, or had the opportunity to obtain,
the advice of legal, financial, and business advisors in connection with the execution and delivery of this Agreement,
understands  the  nature  of  this  Agreement  and  the  considerable  effort  to  be  expended  on  the  part  of  Franchisee  in
order to satisfactorily perform their respective obligations hereunder, and Franchisee intends to comply herewith and
be bound thereby.

25.8.        Franchisee  acknowledges  and  fully  appreciates  that  the  business  contemplated  by  this  Agreement
involves significant risks and that any particular results depend largely on Franchisee’s business abilities and efforts
as  well  as  external  economic  forces  outside  Franchisor’s  control;  and,  Franchisee  acknowledges  and  fully
appreciates that neither Franchisor nor any other person can assure any particular results.

25.9.        Incorporated  herein  by  this  reference  is  all  of  the  additional  information  provided  by  Franchisee  to
Franchisor  as  part  of  the  application  process  pertinent  to  the  grant  of  franchise  evidenced  by  this  Agreement.
Franchisee acknowledges that Franchisor has relied on each item of such information in granting this franchise.

26.

ANTI-TERRORISM LAW

26.1.    Franchisee certifies that neither Franchisee or its employees, or anyone associated with Franchisee is
listed in the Annex to Executive Order 13224. Franchisee  promises  not  to  hire  or  have  any  dealings  with  a  person

listed in the Annex. Franchisee certifies that it has no knowledge or information that, if generally known, would result
in  Franchisee,  its  employees,  or  anyone  associated  with  Franchisee  being  listed  in  the  Annex  to  Executive  Order
13224. Franchisee promises to comply with and assist Franchisor to the fullest extent possible in Franchisor's efforts
to comply with the Anti-Terrorism Laws (as defined below). In connection with such compliance, Franchisee certifies,
represents,  and  warrants  that  none  of  its  property  or  interests  is  subject  to  being  "blocked"  under  any  of  the  Anti-
Terrorism Laws, and that Franchisee are not otherwise in violation of any of the Anti-Terrorism Laws. Franchisee is
solely responsible for ascertaining what actions must be taken by Franchisee to comply with all such Anti-Terrorism
Laws. Franchisee specifically acknowledges and agrees that Franchisee's indemnification responsibilities as provided
in this Agreement pertain to Franchisee's obligations under this Section. Any misrepresentation by Franchisee under
this Section or any violation of the Anti-Terrorism Laws by Franchisee or its employees shall constitute grounds for
immediate  termination  of  this  Agreement  and  any  other  agreement  Franchisee  has  entered  into  with  Franchisor  or
one of Franchisor's Affiliates. "Anti-Terrorism Laws" means Executive Order 13224 issued by the President of the
United States, the Terrorism Sanctions Regulations (Title 31, Part 595 of the U.S. Code of Federal Regulations), the
Foreign Terrorist Organizations  Sanctions  Regulations  (Title  31,  Part  597 of the U.S. Code of Federal Regulations)
the  Cuban  Assets  Control  Regulations  (Title  31,  Part  515  of  the  U.S.  Code  of  Federal  Regulations),  the  USA
PATRIOT Act, and all other present and future federal, state and local laws, ordinances, regulations, policies, lists and
any other requirements of any Governmental Authority (including the United States Department of Treasury Office of
Foreign Assets Control) addressing or in any way relating to terrorist acts and acts of war.

27.

SIGNATURES

IN WITNESS WHEREOF, this Agreement has been executed by the parties hereto as of the date(s) first set

forth below.

FRANCHISOR:

FRANCHISEE:

EL POLLO LOCO, INC., a Delaware Corporation

____________________________, an individual

By:

Name:

Title:

Date:

By:

Name:

Title:

Date:

An individual

EXHIBIT 1: MEMORANDUM OF OPENING DATE

On  or  about  _________________,  20__  EL  POLLO  LOCO,  INC.,  a  Delaware  corporation  (“Franchisor”),  and
____________________________,  a  _____________  (“Franchisee”),  entered  into  a  Franchise  Agreement  (the
“Franchise  Agreement”) 
at
for 
____________________________________(the “Location”).

Loco”  Restaurant  Unit  No. 

“El  Pollo 

_______ 

located 

an 

The  parties  hereby  agree  that  the  Opening  Date  of  the  Restaurant  at  the  Location  was  ____________________,
20___.

The  term  of  the  Franchise  Agreement  shall  expire  on  ________________,  20___,  unless  sooner  terminated  as
provided in the Franchise Agreement.

This Memorandum of Opening Date may be executed in two or more counterparts, each of which shall be deemed an
original  but  all  of  which  together  shall  constitute  a  single  instrument.  A  signature  on  this  Memorandum  of  Opening
Date transmitted via facsimile or electronic mail shall be considered an original for all purposes hereunder.

IN WITNESS WHEREOF, the parties hereto have caused this Memorandum of Opening Date to be executed as of
the date(s) below.

FRANCHISOR:

FRANCHISEE:

EL POLLO LOCO, INC., a Delaware Corporation

____________________________, an individual

By:

Name:

Title:

By:

Name:

Title:

An individual

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Date:

Date:

EXHIBIT 2: PERSONAL GUARANTEE OF FRANCHISE AGREEMENT

The  undersigned  hereby  unconditionally  guarantees,  absolutely  and  irrevocably  the  performance  and  payment  by
Franchisee (as defined below) of, and expressly agrees to adopt and be individually bound by as if the undersigned
were  a  party  to  each  and  all  of  the  terms,  covenants  and  conditions  of  that  certain  Franchise  Agreement  dated
_______________,  20___  (the  “Agreement”)  between  EL  POLLO  LOCO,  INC.,  a  Delaware  corporation
(“Franchisor”) whose address is 3535 Harbor Blvd, Suite 100, Costa Mesa, CA 92626 and _________________, a
_________ (“Franchisee”) whose address is ____________________. The undersigned further agrees as follows:

1.    This guarantee will continue unchanged by any bankruptcy, reorganization or insolvency of Franchisee or by any
disaffirmance or abandonment by a trustee of Franchisee.

2.        This  covenant  and  agreement  on  the  part  of  the  undersigned  shall  continue  in  favor  of  Franchisor
notwithstanding any extension, modification or alteration of the Agreement entered into by and between the parties
thereto,  or  their  successors  or  assigns,  and  no  extension,  modification,  alteration  or  assignment  of  the  Agreement
shall in any manner release or discharge the undersigned and the undersigned does hereby consent thereto.

3.    The liability of the undersigned under this guarantee shall be primary and in any right of action which shall accrue
to  Franchisor  under  the  Agreement,  Franchisor  may,  at  its  option,  proceed  against  the  undersigned  without  having
commenced any action or having obtained any judgment against Franchisee.

4.    The undersigned shall pay Franchisor’s reasonable attorneys’ fees and all costs and other expenses incurred in
any collection or attempted collection or in any negotiations relative to the obligations hereby guaranteed or enforcing
this guarantee against the undersigned, individually and jointly only if final judgment is entered in favor of Franchisor.

5.        The  undersigned  hereby  waives  notice  of  any  demand  by  Franchisor  as  well  as  any  notice  of  default  in  the
payment of any and all amounts contained or reserved in the Agreement.

6.       All  sums  due  under  this  guarantee  shall  bear  interest  from  the  date  due  until  the  date  paid  at  the  maximum
contract rate permitted by law. The obligations under this guarantee include, without limitation, payment when due of
any and all sums due under the Agreement and all damages to which Franchisor is or may be entitled whether under
applicable law, indemnification payments and payment of any and all legal fees, courts costs and litigation expenses
incurred by Franchisor in endeavoring to collect or enforce any of the foregoing against Franchisee, the undersigned,
or in connection with any property securing any or all of the foregoing or this guarantee.

7.    The undersigned agrees that one or more successive or concurrent actions may be brought on this guarantee, in
the  same  action  in  which  Franchisee  may  be  sued  or  in  separate  actions,  as  often  as  deemed  advisable  by
Franchisor.  The  obligations  under  this  guarantee  are  joint  and  several,  and  independent  of  the  obligations  of
Franchisee.

8.        No  election  in  one  form  of  action  or  proceeding,  or  against  any  party,  or  on  any  obligation,  shall  constitute  a
waiver  of  Franchisor’s  right  to  proceed  in  any  other  form  of  action  or  proceeding  or  against  any  other  party.  The
failure of Franchisor to enforce any of the provisions of this guarantee at any time or for a period of time shall not be
construed to be a waiver of any such provision or the right thereafter to enforce the same. All  remedies  under  this
guarantee shall be cumulative and shall be in addition to all rights, powers and remedies given to Franchisor by law
or under any other instrument or agreement.

9.        All  rights,  benefits  and  privileges  under  this  guarantee  shall  inure  to  the  benefit  of  and  be  enforceable  by
Franchisor and its successors and assigns and shall be binding upon the undersigned and his heirs, representatives,
successors  and  assigns.  Neither  the  death  of  the  undersigned  nor  notice  thereof  to  Franchisor  shall  terminate  this
guarantee  as  to  his  estate,  and,  notwithstanding  the  death  of  the  undersigned  or  notice  thereof  to  Franchisor,  this
guarantee  shall  continue  in  full  force  and  effect.  The  provisions  of  this  guarantee  may  not  be  waived  or  amended
except in writing executed by the undersigned and a duly authorized representative of Franchisor.

 
 
 
10.    The undersigned represents and warrants that (i) it is in the undersigned’s direct interest to assist Franchisee in
procuring  the  Agreement,  because  Franchisee  has  a  direct  or  indirect  corporate  or  business  relationship  with  the
undersigned,  (ii)  this  guarantee  has  been  duly  and  validly  authorized  executed  and  delivered  and  constitutes  the
binding obligation of the undersigned, enforceable in accordance with its terms, and (iii) the execution and delivery of
this guarantee does not violate (with or without the giving of notice, the passage of time, or both) any order, judgment,
decree,  instrument  or  agreement  to  which  the  undersigned  is  a  party  or  by  which  it  or  its  assets  are  affected  or
bound.

11.    If any provision of this guarantee or the application thereof to any party or circumstance is held invalid, void,
inoperative, or unenforceable, the remainder of this guarantee and the application of such provision to other parties or
circumstances shall not be affected thereby, the provisions of this guarantee being severable in any such instance.
This guarantee is the entire and only agreement between the undersigned and Franchisor respecting the guarantee
of the Agreement, and all representations, warranties, agreements, or undertakings heretofore or contemporaneously
made, which are not set forth in this guarantee, are superseded.

12.    Any notice which a party shall be requested or shall desire to give to the other under this guarantee shall be
given  by  personal  delivery  or  by  depositing  the  same  in  the  United  States  mail,  first  class  postage  pre-paid,
addressed  to  Franchisor  at  its  address  set  forth  above  and  to  the  undersigned  at  its  address  set  forth  above,  and
such notices shall be deemed duly given on the date of personal delivery or three (3) days after the date of mailing as
aforesaid.  Either  party  may  change  their  address  for  purposes  of  receiving  notices  under  this  guarantee  by  giving
written notice thereof to the other party in accordance with this section.

13.        This  guarantee  is  governed  by  and  construed  according  to  the  laws  of  the  State  of  California  applicable  to
contracts made and to be performed in such state. In order to induce Franchisor to accept this guarantee, and as a
material part of the consideration therefore, the undersigned (i) agrees that all actions or proceedings relating directly
or indirectly to this guarantee shall, at the option of the Franchisor, be litigated in courts located within the State of
California, and (ii) consents to the jurisdiction of any such court and consents to the service of process in any such
action or proceeding by personal delivery or any other method permitted by law.

The undersigned waives and relinquishes any rights it may have under California Civil Code 2845, 2849 and
2850 or otherwise to require Franchisor to (a) proceed against Franchisee or any other guarantor, pledgor or person
liable under the Agreement; (b) proceed against or exhaust any security for the Franchisee or this guarantee; or (c)
pursue  any  other  remedy  in  Franchisor’s  power  whatsoever.  In  other  words,  Franchisor  may  proceed  against  the
undersigned for the obligations guaranteed without first taking any action against Franchisee or any other guarantor,
pledgor or person liable under the Agreement and without proceeding against any security. The undersigned shall not
have, and herby waives (a) any right of subrogation, contribution, indemnity and any similar right that the undersigned
may  otherwise  have,  (b)  any  right  to  any  remedy  which  Franchisor  now  has  or  may  hereafter  have  against
Franchisee, and (c) any benefit of any security now or hereafter held by Franchisor. The undersigned waives (a) all
presentments,  demands  for  performance,  notices  of  non-performance,  protests,  notices  of  protests  and  notices  of
dishonor; (b) all other notices and demands to which the undersigned might be entitled, including without limitation
notice of all the following:  the  acceptance  hereof;  any  adverse  change  in  Franchisee’s  financial  position;  any  other
fact which might increase the undersigned’s risk; any default, partial payment or non-payment under the Franchisee
and any changes, modifications, or extensions thereof; and any revocation, modification or release of any guarantee
of any or all of the Agreement by any person (including without limitation any other person signing this guarantee): (c)
any defense arising by reason of any failure of Franchisor to obtain, perfect, maintain or keep in force any security
interest  in  any  property  of  Franchisee  or  any  other  person;  (d)  any  defense  based  upon  or  arising  out  of  any
bankruptcy,  insolvency,  reorganization,  arrangement,  readjustment  of  debt,  liquidation  or  dissolution  proceeding
commenced by or against Franchisee or any other guarantor or any person liable under the Agreement.

Without  limiting  the  generality  of  the  foregoing  or  any  other  provision  of  this  guarantee,  the  undersigned  expressly
waives any and all benefits which might otherwise be available to it under California Civil Code 2839 (which provides
that a surety is exonerated by the performance or the offer of performance of the principal obligation), 2899 (which
provides  for  the  order  of  resort  to  different  funds  held  by  the  creditor)  and  3433  (which  provides  for  the  right  of  a
creditor  to  require  that  another  creditor  entitled  to  resort  to  several  sources  of  payments  first  resort  to  sources  not
available to the first creditor). The undersigned waives the rights and benefits under California Civil Code 2819 and
agrees that by doing so its liability shall continue even if Franchisor alters any obligations under the Agreement in any
respect  or  Franchisor’s  rights  or  remedies  against  Franchisee  are  in  any  way  impaired  or  suspended  without  the
undersigned’s consent. Franchisor may without notice assign this guarantee in whole or in part.

14.        The  undersigned  has  had  the  opportunity  to  review  this  guarantee  with  its  counsel  and  such  counsel  has
explained  to  it  the  meaning  and  significance  of  the  provisions  of  this  guarantee,  including  but  not  limited  to  the
waivers and consents contained in this guarantee, and answered any questions that it had regarding the meaning,
significance and effect of the provisions of this guarantee.

15.    This guarantee of the Agreement may be executed in two or more counterparts, each of which shall be deemed
an  original  but  all  of  which  together  shall  constitute  a  single  instrument.  A  signature  on  this  guarantee  of  the
Agreement transmitted via facsimile or electronic mail shall be considered an original for all purposes hereunder.

The  use  of  the  singular  herein  shall  include  the  plural.  The  obligations  of  two  or  more  parties  shall  be  joint  and
several. The terms and provisions of this guarantee of the Agreement shall be binding upon and inure to the benefit
of the respective successors and assigns of the parties herein named.

IN WITNESS WHEREOF, the undersigned executed this guarantee on the date(s) set forth below.

FRANCHISEE:

____________________________, an individual

By:

Name:

Title:

Date:

An individual

i.    

EXHIBIT 3: INVESTOR COVENANTS REGARDING CONFIDENTIALITY AND NON-COMPETITION

In  conjunction  with  your  investment  in  __________  a  ____________("Franchisee")  you  (Investor"  or  "you"),
acknowledge and agree as follows:

1)Franchisee  owns  and  operates,  or  is  developing,  pursuant  to  a  Franchise  Agreement  dated  _______________
("Franchise Agreement") with El Pollo Loco, Inc. (“EPL”), which Franchise Agreement requires persons with legal or
beneficial ownership interests in Franchisee under certain circumstances to be personally bound by the confidentiality
and  non-competition  covenants  contained  in  the  Franchise  Agreement.  All  capitalized  terms  contained  herein  shall
have the same meaning set forth in the Franchise Agreement.

2)You own or intend to own a _*_% legal or beneficial ownership interest in Franchisee and acknowledge and agree
that your execution of this Agreement is a condition to such ownership interest and that you have received good and
valuable consideration for executing this Agreement. EPL may enforce this Agreement directly against you and your
Owners (as defined below).

3)If  you  are  a  corporation,  partnership,  limited  liability  company  or  other  entity,  all  persons  who  have  a  legal  or
beneficial interest in you ("Owners") must also execute this Agreement.

4)You and your Owners, if any, may gain access to parts of EPL’s Confidential Information as a result of investing in
Franchisee.  The  Confidential  Information  is  proprietary  and  includes  EPL's  trade  secrets.  You  and  your  Owners
hereby agree that while you and they have a legal or beneficial ownership interest in franchise and thereafter you and
they: (a) will not use the Confidential Information in any other business or capacity (such use being an unfair method
of competition); (b) will exert best efforts to maintain the confidentiality of the Confidential Information; and (c) will not
make unauthorized copies of any portion of the Confidential Information disclosed in written, electronic or other form.
If you or your Owners cease to have an interest in franchisee, you and our Owners, if any, must deliver to EPL any
such Confidential Information in your or their possession.

5)During the term of the Franchise Agreement and during such time as you and your Owners, if any, have any legal
or beneficial ownership interest in Franchisee, you and your Owners, if any, agree that you and they will not, without
EPL's  consent  (which  consent  may  be  withheld  as  EPL's  sole  and  absolute  right)  directly  or  indirectly  (such  as
through  an  Affiliate  or  through  your  or  their  Immediate  Families)  own  any  legal  or  beneficial  interest  in,  or  render
services or give advice in connection with: (a) any Competitive Business located anywhere, or (b) any entity located
anywhere that grants franchises or licenses interest to others to operate any Competitive Business.

6)For  a  period  of  two  (2)  years,  starting  on  the  earlier  to  occur  of  the  date  you  or  your  Owners  cease  to  have  any
legal or beneficial ownership interest in Franchisee and the effective date of termination or expiration of the Franchise
Agreement, neither you nor any of your Owners directly or indirectly (such as through an Affiliate or through your or
their  Immediate  Families)  shall  own  a  legal  or  beneficial  interest  in,  or  render  services  or  give  advice  to:  (a)  any
Competitive  Business  operating  at  or  within  a  radius  of  five  (5)  miles  of  the  Restaurant  and/or  any  El  Pollo  Loco
Restaurant then in operation or under construction; or (b) any entity that grants franchises or license other interest to
others  to  operate  any  Competitive  Business.  If  you  or  any  of  your  Owners  fail  to  or  refuse  to  abide  by  any  of  the
foregoing covenants and EPL. obtains enforcement in a judicial or arbitration proceeding, the obligations under the

 
 
 
breached  covenant  will  continue  in  effect  for  a  period  of  time  ending  two  (2)  years  after  the  date  such  person
commences compliance with the order enforcing the covenant.

7)You and each of your Owners expressly acknowledge the possession of skills and abilities of a general nature and
the opportunity to exploit such skills in other ways, so that enforcement of the covenants contained in Sections 5 and
6 will not deprive any of you of your personal goodwill or ability to earn a living. If any covenant herein, which restricts
competitive activity, is deemed unenforceable by virtue of its scope or in terms of geographic area, type of business
activity prohibited and/or length of time, but could be rendered enforceable by reducing any part of all of it, you and
we  agree  that  it  will  be  enforce  to  the  fullest  extent  permissible  under  applicable  law  and  public  policy.  EPL  may
obtain  in  any  court  of  competent  jurisdiction  any  injunctive  relief,  including  temporary  restraining  orders  and
preliminary injunctions, against conduct or threatened conduct for which no adequate remedy at law may be available
or which may cause it irreparable harm. You and each of your Owners acknowledges that any violation of Section 4,
5, or 6 hereof would result in irreparable injury for which no adequate remedy at law may be available. If EPL files a
claim  to  enforce  this  Agreement  and  prevails  in  such  proceeding,  you  agree  to  reimburse  EPL  for  all  its  cost  and
expense, including reasonable attorneys' fees.

8)This  Investor  Covenants  regarding  Confidentiality  and  Non-Competition  Agreement  (“Investor  Agreement”)  may
be executed in two or more counterparts, each of which shall be deemed an original but all of which together shall
constitute a single instrument. A signature on this Investor Agreement transmitted via facsimile or electronic mail shall
be considered an original for all purposes hereunder.

*Statement of Ownership of Franchisee:
Franchisee Owner – ______%
Franchisee Owner – ______%
Franchisee Owner – ______%
IN  WITNESS  WHEREOF,  the  undersigned  have  executed  and  delivered  this  Agreement  on  the  date(s)  set  forth
below.

INVESTOR:
If an Individual:

____________________________, an individual

By:

Name:

Title:

Date:

An individual

If a corporation, partnership, limited liability company or other legal entity:

_______________________________, a ___________________________

By:

Name:

Title:

Date:

By:

Name:

Title:

Date:

OWNERS:

By:

Name:

Title:

Date:

An individual

By:

Name:

Title:

Date:

An individual

    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EXHIBIT 4: AUTHORIZATION AGREEMENT FOR PREARRANGED PAYMENTS (ACH)

On  _____________,_______  and  going  forth,  the  undersigned  depositor  (“Depositor”)  hereby  authorizes  El  Pollo
Loco, Inc. (“El Pollo Loco”) to initiate debit entries and/or credit correction entries to the Depositor’s checking and/or
savings  account(s)  indicated  below  and  the  depository  (“Depository”)  to  debit  such  account  pursuant  to  El  Pollo
Loco’s instructions (“Authorization”).

Depository:

Branch:

Street Address, City, State, Zip Code:

Bank Transit/ABA Number:

Account Number:

This authority is to remain in full force and effect until Depository has received joint written notification from El Pollo
Loco®  and  Depositor  of  the  Depositor’s  termination  of  such  authority  in  such  time  and  in  such  manner  as  to  afford
Depository  a  reasonable  opportunity  to  act  on  it.  Notwithstanding  the  foregoing,  Depository  shall  provide  El  Pollo
Loco® and Depositor with thirty (30) days’ prior written notice of the termination of this authority. If an erroneous debit
entry is initiated to Depositor’s account, Depositor shall have the right to have the amount of such entry credited to
such  account  by  Depository,  if  within  fifteen  (15)  calendar  days  following  the  date  on  which  Depository  sent  to
Depositor  a  statement  of  account  or  a  written  notice  pertaining  to  such  entry  or  forty  five  (45)  days  after  posting,
whichever  occurs  first,  Depositor  shall  have  sent  to  Depository  a  written  notice  identifying  such  entry,  stating  that
such entry was in error and requesting Depository to credit the amount thereof to such account. These rights are in
addition to any rights Depositor may have under federal and state banking laws.

This Authorization may be executed in two or more counterparts, each of which shall be deemed an original but all of
which  together  shall  constitute  a  single  instrument.  A  signature  on  this  Authorization  transmitted  via  facsimile  or
electronic mail shall be considered an original for all purposes hereunder.

Depositor: ________________________, a _______________

By:

Name:

Title:

Date:

By:

Name:

Title:

Date:

ATTACH VOID CHECK

EXHIBIT 5: ADVERTISING ASSOCIATION DOCUMENTS

ADVERTISING ASSOCIATION MEMBERSHIP AGREEMENT

THE [NAME OF AREA] EL POLLO LOCO® RESTAURANT ADVERTISING ASSOCIATION

MEMBERSHIP AGREEMENT

THIS  [NAME  OF  AREA]  EL  POLLO  LOCO®  RESTAURANT  ADVERTISING  ASSOCIATION  MEMBERSHIP
AGREEMENT is effective as of _____________________, 20___, by and between the [NAME OF AREA] EL POLLO
LOCO®  RESTAURANT  ADVERTISING  ASSOCIATION,  INC.  a  ______________  Nonprofit  Corporation  [the
“Association”] and ________________________________, a________________(the “Member”).

BACKGROUND INFORMATION:

EL POLLO LOCO, INC. (the “Franchisor”) owns, operates and franchises quick service restaurants which specialize
in the sale of retail marinated ________ grilled chicken and Mexican food items related to the El Pollo Loco® concept
(“Restaurants”). 
the
____________________________[described  geographic  area]____________________  (the  “Association  Area”).

or  more  Restaurants  within 

The  Member 

operates 

owns 

one 

and 

 
 
 
 
 
 
 
 
 
 
 
 
The Association was organized by the Franchisor and its franchisees that own Restaurants in the Association Area in
order to pool advertising funds.

OPERATIVE TERMS:

1.

Bylaws. The Association has adopted Bylaws and may amend, modify or replace them from time to
time  in  accordance  with  its  governing  documents,  subject  to  the  written  consent  of  the  Franchisor  (the  “Bylaws”).
Unless the context requires otherwise, terms used in this Agreement will have the meanings as defined in the Bylaws.

2.

Membership. By signing this Agreement:

(a)    The Member agrees to become a member of the Association and agrees to be bound by and adhere
to the Bylaws, and to observe any administrative rules, regulations and policy statements adopted by the Association
in accordance with the Bylaws; and

(b)    The Association accepts and enrolls the Member as a member in good standing with full rights and

Benefits of membership.

3.

Scope. This  Agreement  is  applicable  to  all  of  the  Member’s  Restaurants  located  in  the  Association

Area, whether currently existing, or opened or acquired after the signing of this Agreement.

4.

Contributions.

(a)

Obligation to Pay: The Member agrees to make such contributions to the Association, and at
such time and in such manner, as are determined by the Association from time to time in accordance with the Bylaws.
Contributions are non-refundable.

(b)

Reports: Each contribution must be accompanied by a report containing such information as
the Association may determine from time to time, showing the amount of the contribution the Member is required to
pay with respect to the Member’s Restaurants located in the Association Area. The Member authorizes and instructs
the Franchisor to furnish to the Association, on request, copies of the Member’s reports and records in Franchisor’s
possession for the purpose of verifying contributions due. The Association may review reports and other information
available to the Franchisor to verify that the proper amount of contributions have been made by the Member.

(c)

Collection by Franchisor: The Member acknowledges and agrees that the Association may
authorize  Franchisor  to  receive  and  collect  contributions  and  related  reports  on  behalf  of  the  Association.  In  such
case, the Member shall make contributions to Franchisor, and shall report to Franchisor, at such times and in such
manner as Franchisor may determine to be appropriate from time to time.

5.

Benefits.  The  Association  agrees  that  it  will  operate  on  a  not-for-profit  basis  in  accordance  with
governing  documents  and  that  all  contribution  will  be  spent  solely  for  the  purposes  permitted  in  its  Articles  of
Incorporation and Bylaws.

6.

Effective Date and Term. The Agreement becomes effective on the date signed by both Parties and

will continue until the earlier of:

(a)    The Association discontinues operations or is dissolved; or

(b)    Until the Member no longer owns and operates a Restaurant located in the Association Area under a
valid Franchise Agreement with Franchisor, or until the Member no longer owns or operates a Restaurant located in
the Association Area, if the Member is the Franchisor or an affiliate of Franchisor.

In the event this Agreement terminates pursuant to Section 6(b), the Member’s voting and other membership rights in
the Association automatically terminate on the effective date of termination of the Franchise Agreement (or closure of
the Restaurant, if the Franchisor or its affiliate is the Member), provided however, if the Member owes contributions at
the time of such termination (or closure), then it will still be obligated and responsible for all contributions that accrued
prior to the date of such termination (or closure).

7.

  Franchise  Transfers.  The  parties  recognize  that  the  timing  of  payment  of  contributions  may  not

always coincide with the consummation of the sale of a Restaurant. Accordingly, the parties agree as follows:

(a)

Timing:  The  Member  will  remain  responsible  to  the  Association  for  all  contributions  due
through  the  date  of  the  consummation  of  any  sale  of  an  El  Pollo  Loco®  restaurant  owned  by  the  Member  that  is
subject to this Agreement.

(b)

 Credit Balances: If the Member sells or closes an El Pollo Loco® restaurant subject to this
Agreement  at  a  time  when  the  Member  has  a  credit  balance  with  the  Association,  the  credit  balance  will  not  be
refunded,  but  will  be:  (i)  retained  for  the  benefit  of  other  members  of  the  Association,  if  the  transaction  involves  a
closing  of  the  Member’s  El  Pollo  Loco®  restaurant  or  the  termination  or  expiration  of  the  Member’s  Franchise
Agreement; or (ii) credited to the Restaurants of the purchaser that are subject to this Agreement, if a sale, transfer or
assignment is involved; or (iii) credited to the Member’s other Restaurants that are still subject to this Agreement.

8.

  Delinquencies.  The  Member  agrees  to  abide  by  all  rules  and  regulations  regarding  delinquent
contributions, including the payment of interest and late payment fees, adopted by the Association from time to time.
The  Member  acknowledges  and  agrees  that  delinquent  contributions  (a)  constitute  a  breach  of  the  Franchise
Agreement; (b) may result in loss of voting rights and other privileges with the Association; and/or (c) may result in
cancellation of membership with the Association.

9.

 Entity Participation.  If  the  Member  is  a  corporation,  limited  liability  company,  partnership  or  other
business entity, the Member will duly authorize one (1) person to represent its interests at Association meetings (the
“Representative”). The Representative must be a: (i) shareholder, partner, member (in case of an LLC), director or
officer of the Member; or (ii) the Member’s Operating Partner, as defined in the Member’s Franchise Agreement; or
(iii) in the event the Member is Franchisor or one of its affiliates, an officer or other designated representative of the
Franchisor  or  it  affiliate.  The  Association  shall  be  entitled  to  rely  on  any  written  authorization  appointing  the
Representative  that  the  Association  in  good  faith  believes  to  be  valid  unless  and  until  the  Association  shall  have
received an authorization for a successor Representative’s decisions, votes and consents to bind the Member at any
such meeting without any further inquiry. The same person can be a Representative for more than one (1) Member.

10.

  Program  Participation.  The  Member  will  not  be  required,  as  a  condition  of  membership  in  this
Association  or  otherwise,  to  participate  in  any  advertising  or  promotion  that  contains  a  specified  retail  price,  or  a
minimum  retail  price,  for  any  product  or  service  furnished  by  Restaurant  in  the  Association  Area.  However,  the
Member’s obligation to pay contributions pursuant to this Agreement will not be affected in any way by the Member’s
decision not to participate.

11.

Miscellaneous.

(a)

Severability: If any part of this Agreement is held invalid for any reason, the remainder of this

Agreement will not be affected and will remain in full force and effect in accordance with its terms.

(b)

  Costs  of  Collection:  Member  agrees  to  reimburse  the  Association  (or,  if  applicable,
Franchisor) for all costs and expenses, including attorneys’ fees and expenses, incurred in connection with collecting
delinquent contributions. Reimbursement is due within thirty (30) days of written notice.

(c)

Waivers:  No  waiver  of  any  provision  of  this  Agreement  will  be  valid  unless  in  writing  and
signed by the person signed by the person against whom it is sought to be enforced. The failure by either party to
insist upon strict performance of any provision will not be construed as a waiver or relinquishment of the right to insist
upon  strict  performance  of  the  same  provision  at  any  other  time  or  to  insist  on  strict  performance  of  any  other
provision of this Agreement.

(d)

Liabilities and Beneficiaries: Neither party will be liable to any other person who is not Party to
this not a Party to this not a party to this Agreement by virtue of their relationship to each other. No other person has
any rights because of this Agreement, except for the parties. However, notwithstanding  the  foregoing,  although  the
Franchisor  may  not  be  a  party  to  this  Agreement,  and  is  not  bound  by  it,  Franchisor  is  a  third-party  intended
beneficiary.

(e)

Entire Agreement: This Agreement reflects the entire understanding of the parties with respect
to the subject matter hereof and supersedes all prior oral or written agreements, communications or understandings
with respect to the matters provided for herein.

[NAME OF AREA] EL POLLO LOCO® RESTAURANT

By:     
Name:    
Title:    

Date:    

ADVERTISING ASSOCIATION, INC.
[Name of Member]

By:     

Name:    
Title:    

Date:    

BYLAWS  OF  _____[NAME  OF  AREA]_____EL  POLLO  LOCO®  RESTAURANT  ADVERTISING  ASSOCIATION,
INC.

Adopted as of _______________, 20___

27.2.    

TABLE OF CONTENTS

ARTICLE

ARTICLE 1 OFFICES

SECTION 1.1 REGISTERED AND PRINCIPAL OFFICE
SECTION 1.2 OTHER OFFICES

SECTION 1.3 REGISTERED AGENT FOR SERVICE OF PROCESS

ARTICLE 2 POWERS AND PURPOSE

SECTION 2.1POWERS

SECTION 2.2PURPOSES

SECTION 2.3 USE OF TRADEMARKS

ARTICLE 3 MEMBERS

SECTION 3.1    MEMBERS
SECTION 3.2    ENROLLMENT
SECTION 3.3    ENTITY MEMBERSHIP
SECTION 3.4    MEMBERS IN GOOD STANDING
SECTION 3.5
SECTION 3.6    SPECIAL MEETINGS
SECTION 3.7    PLACE OF MEETING
SECTION 3.8    NOTICE OF MEETINGS
SECTION 3.10    CLOSURE OF BOOKS AND FIXING OF RECORD DATE
SECTION 3.11    QUORUM
SECTION 3.12    VOTING

ANNUAL AND QUARTERLY MEETINGS OF THE MEMBERS    

    
    
SECTION 3.13    REPRESENTATIVES
SECTION 3.14    ACTION WITHOUT MEETING
SECTION 3.15    ORGANIZATION
SECTION 3.16    MEMBER MEETINGS BY TELEPHONE

ARTICLE 4 DIRECTORS

TERMS

SECTION 4.1 NUMBER
SECTION 4.2
VACANCIES
SECTION 4.3 REMOVAL OF DIRECTORS
SECTION 4.4 QUALIFICATION
SECTION 4.5
SECTION 4.6 RESIGNATION
SECTION 4.7
SECTION 4.8 MEETINGS
SECTION 4.9 NOTICE OF SPECIAL MEETING
SECTION 4.10 ACTION WITHOUT A MEETING
SECTION 4.11 QUORUM AND VOTING
SECTION 4.12 ORGANIZATION
SECTION 4.13 COMPENSATION
SECTION 4.14 ATTENDANCE BY TELEPHONE

POWERS

ARTICLE 5 OFFICERS

TERM OF OFFICE; VACANCIES

SECTION 5.1 OFFICES
SECTION 5.2
SECTION 5.3 REMOVAL OF OFFICERS
SECTION 5.4 RESIGNATIONS
SECTION 5.5 COMPENSATION
SECTION 5.6 REFUND OF PAYMENT
SECTION 5.7
POWERS AND DUTIES
SECTION 5.8DELEGATION OF DUTIES

ARTICLE 6 CONTRIBUTIONS

SECTION 6.1 CONTRIBUTIONS
SECTION 6.2
SESTION 6.3

PAYMENT OF CONTRIBUTIONS
PAYMENT IN PAYMENTS

ARTICLE 7 NOTICES

SECTION 7.1 RECORDING
SECTION 7.2 WAIVER

ARTICLE 8 DESIGNATED FINANCIAL AGENTS, SIGNATURES AND SEAL

SECTION 8.1 DESIGNATED FINANCIAL AGENTS
SECTION 8.2 OTHER AGREEMENTS

ARTICLE 9 AMENDMENTS OF BYLAWS

ARTICLE 10 INDEMNIFICATION

SECTION 10.1 INDEMNIFICATION IN PROCEEDINGS OTHER THAN ACTIONS BY, OR IN THE RIGHT OF

THE CORPORATION

SECTION 10.2 INDEMNIFICATION OF PERSONS PARTIES TO A PROCEEDING BY OR IN THE RIGHT OF

CORPORATION
SECTION 10.3 MANDATORY INDEMNIFICATION
SECTION 10.4 AUTHORIZATION OF INDEMNIFICATION IS REQUIRED
SECTION 10.5 ADDITIONAL CONDITIONS TO INDEMNIFICATION
SECTION 10.6 PREPAYMENT OF EXPENSES
SECTION 10.7 INDEMNIFICATION DISALLOWED IN CERTAIN CIRCUMSTANCES
SECTION 10.8 NONEXCLUSIVITY

ARTICLE 11 GENERAL PROVISIONS
SECTION 11.1 FISCAL YEAR
SECTION 11.2 GENDER AND NUMBER
SECTION 11.3 ARTICLES AND OTHER HEADINGS
SECTION 11.4 MINUTES, BOOKS AND RECORDS OF ACCOUNT
SECTION 11.5 STATUTORY CITES

    
i.    

BYLAWS  OF  _______[NAME  OF  AREA]_______EL  POLLO  LOCO®  RESTAURANT  ADVERTISING
ASSOCIATION, INC.

ARTICLE 1 - Officers

Section  1.1  -  Registered  and  Principal  Office.  The  initial  registered  office  of  the  _______  ______  [NAME  OF
AREA]  El  Pollo  Loco® 
located  at
located  at
_________________________.  The 
__________________________________.

Inc. 
initial  principal  office  of 

(the 
the  Corporation  will  be 

restaurant  Advertising  Association, 

“Corporation”)  will  be 

Section 1.2 - Other Offices. The Corporation may have offices at such other place or places within or without the
State of Delaware as the Board of Directors may from time to tie establish.

Section 1.3 - Registered Agent for Service of Process. The Corporation’s Board of Directors will have the right to
designate a registered agent for service of process, who may be an individual or a corporation. The registered agent
so designated will serve until a successor is elected by the Board of Directors.

ARTICLE 2 - Powers and Purposes

Section  2.1  -  Powers.  The  Corporation  will  have  all  of  the  powers  accorded  nonprofit  corporations  under  the
Missouri  Nonprofit  Corporation  Act  (the  “Act”).  The  Corporation  will  utilize  such  powers  to  engage  in  any  lawful
activity which is consistent with its purposes as set forth in the Articles of Incorporation.

Section 2.2 - Purposes. The purposes for which the Corporation is formed are to establish, maintain, administer and
operate a promotional and advertising fund (the “Fund”) for the benefit of the El Pollo Loco® restaurants (“EPL’s”) of
its members located in _____________[describe geographic area]_______________ (the “Association Area”)  and
to further any and all purposes consistent with the objectives of the Corporation.

Section 2.3 - Use of Trademarks. The Corporation recognizes that its activities will necessarily involve advertising
and  promotional  programs  that  contain  the  intellectual  property  rights,  including  copyrights,  trademarks,  service
marks, logos, and designs derived from El Pollo Loco, Inc. (the “Franchisor”). As such, the Corporation has entered
into, or will enter into, the [NAME OF AREA] ______El Pollo Loco® restaurant Advertising Association Authorization
Agreement.

ARTICLE 3 - Members

Section 3.1 - Members. The members will consist of (a) owners of franchised Restaurants located in the Association
Area operating under valid and effective Franchise Agreements with Franchisor; and (b) the Franchisor or any of its
affiliates, to the extent that it or any of its affiliates owns or operates any Restaurants located within the Association
Area.

Any Franchisee who ceases to be a party to any valid and effective Franchise Agreement with the Franchisor for a El
Pollo  Loco®  restaurant  located  in  the  Association  Area,  whether  due  to  transfer,  expiration  or  termination,  will
automatically cease to be a member of the Corporation, but will continue to remain liable to the Corporation for past
due unpaid contributions or other amounts payable to the Corporation at the time membership ceases. However, if a
Franchisee  operates  under  multiple  Franchise  Agreements  and  ceases  to  be  bound  by  one  or  more  Franchise
Agreements,  whether  due  to  transfer,  expiration  or  termination,  but  continues  to  be  bound  by  other  Franchise
Agreements for Restaurants located in the Association Area, the Franchisee shall continue to be a member, but its
voting  rights  shall  be  reduced  to  reflect  the  number  of  remaining  Restaurants  that  the  Franchisee  owns  in  the
Association Area. Likewise, to the extent the Franchisor or an affiliate of Franchisor owns or operates one or more
Bakery Cafes in the Association Area and has been a member of the Corporation, and ceases to own or operate any
such  Restaurants  in  the  Association  Area,  then  its  membership  with  respect  to  such  Restaurants  will  automatically
terminate.

In  accordance  with  the  terms  of  the  ________[NAME  OF  AREA]_________El  Pollo  Loco®  restaurant  Advertising
Association  Authorization  Agreement,  a  representative  of  Franchisor  shall  be  entitled  to  notice  of  all  regular  and
special meetings of the Members of the corporation and shall have the right to attend all meetings, either in person or

in any other manner of attendance authorized in these Bylaws. However, unless the Franchisor is a Member of the
Corporation by virtue to vote at a meeting of the Members in accordance with Section 3.12 of these Bylaws.

Section 3.2 – Enrollment.     Notwithstanding any of the foregoing, no person will be enrolled as a Member of the
Corporation nor will it have any rights as a Member unless and until it has signed a Membership Agreement with the
Corporation.  Notwithstanding  the  foregoing,  Members  shall  be  required  to  make  contributions  as  required  by  their
Franchise Agreements, regardless of whether they have signed Membership Agreements.

Section  3.3  -  Entity  Membership.  For  all  membership  purposes,  any  business  entity  (corporation,  partnership,
limited liability company, etc.), together with its owners, is deemed a single Member.

Section 3.4 - Members in Good Standing. A  Member will be in  good  standing  as  long  as: (a) the Member is not
delinquent in the payment of any contribution or other monetary obligation to the Corporation; and (b) Member shall
not  have  received  a  notice  of  default  from  Franchisor  with  respect  to  one  or  more  Restaurants  located  in  the
Association  Area  which  default  remains  uncured  to  the  satisfaction  of  Franchisor.  Loss  of  good  standing  will  not
relieve the Member of the obligation to make contributions, when due.

Section 3.5 - Annual and Quarterly Meetings of the Members. The annual meeting of the Members shall be held
for  the  election  of  directors,  consideration  and  approval  of  the  succeeding  year’s  advertising  budget  and  the
transaction  of  such  other  business  as  may  properly  come  before  the  meeting.  The  annual  meeting  will  be  held  at
such time within the first quarter of the Corporation’s fiscal year as the Board of Directors may determine. Quarterly
meetings of the Members shall be held for consideration and approval of advertising and promotional programs and
the  transaction  of  such  other  business  as  may  properly  come  before  the  meeting.  In  addition, at the final  quarterly
meeting  of  the  fiscal  year,  the  Members  shall  consider  and  approve  the  level(s)  of  Member  contributions  for  the
succeeding  fiscal  year.  Quarterly  meetings  will  be  held  at  times  within  the  second,  third  and  fourth  quarters  of  the
Corporation’s fiscal year as the Board of Directors may determine.

The  notice  of  annual  or  quarterly  meetings  of  Members,  except  as  otherwise  required  by  law,  need  not  state  the
matters to be considered at such meetings.

Section 3.6 - Special Meetings. Special meetings of the Members, for any purpose or purposes, unless otherwise
prescribed by applicable law, may be called on the written request of (i) a majority of the Board of Directors, or (ii)
Members  constituting  25%  of  the  voting  rights  of  the  Members  in  good  standing,  or  (iii)  Franchisor.  Requests for a
special meeting must state the purpose or purposes of the proposed meeting. The notice of any special meeting of
the Members must state the purpose or purposes for which the meeting is called.

Section 3.7 - Place of Meeting.     All meetings of the Members will be at such places as will be determined from
time to time by the Board of Directors of the Corporation.

Section 3.8 - Notice of Meetings. Written notice of each meeting of the Members stating the Place, day and hour
thereof,  must  be  delivered  to  each  Member  of  record  entitled  to  vote  at  such  meeting,  personally  or  by  telephone,
telegram,  cablegram,  e-mail,  first  class  mail,  confirmed  facsimile  transmission  or  any  other  means  of  personal
delivery providing evidence of actual delivery; and if mailed, the notice shall be deemed to be given when deposited
in the United States mail addressed to the Members at the Members’ addresses, as they appear in the records of the
Corporation,  with  postage  thereon  prepaid.  Notice  must  be  given  by  or  under  the  direction  of  the  Secretary,  or  the
officer  or  persons  calling  the  meeting  not  more  than  sixty  (60)  not  less  than  ten  (10)  days  before  the  date  of  the
meeting; provided that oral notice to the Member may be given in lieu of written notice so long as the party giving the
notice to the Member files with the Corporation a written statement of the date, time, place and manner of the oral
notice. No notice need be given of the time and place of reconvening of any adjourned meeting, if the time and place
to which the meeting is adjourned are announced at the adjourned meeting.

Section  3.9  -  Waiver  of  Notice.         A  written  waiver  of  notice  signed  by  any  Member,  whether  before  or  after  any
meeting, shall be equivalent to the giving of timely notice to said Member. Attendance of a Member at a meeting shall
constitute a waiver of notice of such meeting and waiver of any and all objections to the place of the meeting, the time
of the meeting, or the manner in which it has been called or convened, except when a Member attends a meeting for
the express purpose, as stated at the beginning of the meeting, of objecting to the transaction of business because

the  meeting  is  not  lawfully  called  or  convened.  Neither  the  business  to  be  transacted  at,  not  the  purpose  of,  any
meeting of the Member need be specified in any written waiver of notice.

Section 3.10 - Closure of Books and Fixing of Record Date. For the purpose of determining Members entitled to
notice of, or to vote at, any meeting of the Members or any adjournment thereof, the Board of Directors may provide
that the books will be closed for a period of not less than three (3) and not more than thirty (30) days immediately
preceding such meeting. If the books are not closed and no record date is fixed by the Board of Directors, the date on
which notice of the meeting is mailed will be the record date for the determination of Members entitled to notice and
to vote.

Section 3.11 – Quorum. Except as otherwise required by the Act, the Articles of Incorporation or these Bylaws, the
presence of Members holding a majority of the votes will constitute a quorum at all meetings of the Members. In case
a  quorum  is  not  present  at  any  meeting,  a  majority  of  the  Members  present  will  have  the  power  to  adjourn  the
meeting from time to time, without notice other than announcement at the meeting of the time and place to which the
meeting is adjourned, until a quorum is present. At any such adjourned meeting at which a quorum is present, any
business may be transacted which might have been transacted at the meeting as originally noticed; but only those
Members  entitled  to  vote  at  the  meeting  as  originally  noticed  will  be  entitled  to  vote  at  any  adjournment  or
adjournments thereof.

Section 3.12 – Voting. Each Member will be entitled at each Members’ meeting and upon each matter presented at
such meeting to one vote for each El Pollo Loco® restaurant located in the Association Area that the Member owns,
or,  in  the  case  of  Franchisor,  owns  or  operates.  Notwithstanding  the  fixing  of  the  record  date  in  Section  3.10,
Members  may  only  participate  in  and  vote  at  meetings  subject  to  being  in  good  standing,  in  accordance  with  the
Bylaws, both on the record date and at the time of the meeting. Furthermore, in the event that a meeting is postponed
or continue, a Member must be in good standing at the time the meeting is reconvened in order to participate and
vote at the meeting.

Any  Member  who  is  not  in  good  standing  pursuant  to  Section  3.4(a)  hereof  shall  have  all  rights  and  privileges  of
membership (including the right to vote and participate as a Member, director or officer in any meeting) suspended.
Any Member who is not in good standing pursuant to Section 3.4(b) hereof shall have its right to vote (but not its right
to participate) suspended at any meeting of the members or the board of directors of the Corporation. Any  dispute
regarding  the  good  standing  of  a  Member  and  its  right  to  vote  at  a  membership  meeting  will  be  determined
conclusively by the Chairman of the meeting, in conjunction with the representative of the Franchisor present at the
meeting,  which  determination  will  be  final  and  binding.  Any  such  suspension  shall  continue  until  the  Member  is  in
good standing again.

The list of Members must be produced at any Member’s meeting upon the request of any Member. Upon the demand
of  any  Member,  the  note  upon  any  question  before  the  meeting  must  be  by  written  ballot.  Except  as  otherwise
provided by these bylaws, by the Act, or by the Articles of Incorporation, all matters will be decided by a majority of
the votes of Members present at the meeting. There is no cumulative voting for directors or on any other matter.

Section  3.13  –  Representatives.  If  a  Member  is  a  corporation,  limited  liability  company,  partnership  or  other
business entity, the Member will duly authorize one (1) person to represent its interests at Association meetings (the
“Representative”). The Representative must be a: (i) shareholder, partner, member (in case of an LLC), director or
officer of the Member; or (ii) the Member’s Operating Partner, as defined in the Member’s Franchise Agreement; or
(iii)  in  the  event  the  Member  is  Franchisor  or  one  of  its  affiliates,  an  officer  or  other  designated  representative  of
Franchisor  or  its  affiliate.  The  Corporation  shall  be  entitled  to  rely  on  any  written  authorization  appointing  the
Representative  that  the  Corporation  in  good  faith  believes  to  be  valid  unless  and  until  the  Corporation  shall  have
received an authorization for a successor Representative that the Corporation in good faith believes to be valid. The
Corporation shall be entitled to rely on the Representative’s decisions, votes and consents to bind the Member at any
such meeting without any further inquiry. The same person can be a Representative for more than one (1) Member.

Section  3.14  -  Action  Without  Meeting.  Any  action  of  the  Members  of  the  Corporation  may  be  taken  without  a
meeting, without prior notice and without a vote, if one or more consents in writing, setting forth the action so taken,
are signed by the Members having not less than two-thirds (2/3) of the votes that would be necessary to authorize or
take such action at a meeting at which all Members entitled to vote thereon were present and voted. Such consents
must be delivered to the Corporation in the manner required by the Act. Neither the Articles of Incorporation nor these

Bylaws will be construed, interpreted or deemed to have, in any way, limited or prevented the utilization of the ability
to take written action in lieu of formal meetings as may be permitted by the Act.

Section  3.15  –  Organization.  Meeting  of  the  Members  must  be  presided  over  by  the  President,  or  if  he  is  not
present, by the Vice President, if a Vice President has been elected, or if neither the President not the Vice President
is present, then by a chairman to be chosen by a majority of the Members entitled to vote who are present in person
at the meeting. The Secretary of the Corporation, or in his absence, the Assistant Secretary, will act as secretary of
every  meeting,  but  if  neither  is  present,  the  Members  entitled  to  vote  who  are  present  in  person  may  choose  any
person present to act as secretary of the meeting.

At all meetings of the Members the order of business will be as follows:

(1)
(2)
(3)

(4)
(5)
(6)
(7)
(8)

Calling meeting to order.
Proof of notice of meeting and determination of quorum.
Reading and disposing of minutes of previous meeting.

Announcement of purposes for the meeting.
Reports of officers.
Unfinished business.
New business, including election of directors if an annual meeting.
Adjournment.

Section 3.16 - Member Meetings by Telephone.     Any Member may participate in a Members’ meeting, or may
conduct a Members’ meeting through the use of, any means of communication enabling all persons participating in
the  meeting  to  hear  each  other  at  the  same  time  during  the  meeting.  Participating  by  such  means  will  constitute
presence in person at a meeting.

ARTICLE 4 - Directors

Section 4.1 – Number. There will be at least three (3) directors on the Board. From time to time, the exact number of
directors may be determined by vote of the Members at any time, but never less than three (3) and never an amount
less than as otherwise required by the Act.

Section 4.2 – Vacancies. Whenever a vacancy occurs on the Board of Directors, including a vacancy resulting from
an increase in the number of directors or the removal of one (1) or more directors, it may be filled by the affirmative
vote of a majority of the remaining directors even if the remaining directors constitute less than a quorum.

Section 4.3 - Removal of Directors. Any director may be removed with or without cause by vote of a majority of the
Members at a membership meeting, or by written action in lieu of meeting signed by the Members having not less
than two-thirds (2/3) of the votes that would be necessary to authorize or take such action at a meeting at which all
Members entitled to vote thereon were present an voted.

Section 4.4 – Qualification. Each director must be either a Member (if the Member is an individual) or the Member’s
Representative.  If  there  are  less  than  three  (3)  Members  at  any  time,  then  the  franchisor,  through  Franchisor’s
representative designated as its “Member’s Representative”, shall have the right to designate two (2) directors one
of which shall be the Member’s Representative and the other shall be an officer of Franchisor. However, any director
serving on the Board of Directors will be automatically suspended at any time during which he or she, or the business
organization  for  which  he  or  she  is  the  Representative,  is  not  in  good  standing.  In  addition,  directors  will  be
automatically  removed  as  directors  if,  at  any  time,  the  Member  with  which  they  are  associated  is  expelled  from
membership or is no longer a franchise of the Franchisor either because the Franchise Agreement has expired or it
has been terminated or transferred.

Section 4.5 – Terms. Directors will hold office until their respective successors are duly elected and qualified or until
there is a decrease in the number of directors.

Section 4.6 – Resignation. Any director may resign at any time. Such  resignation  will  be  made  in  writing  and  will
take effect upon its delivery to the President or the Board of Directors or its Chairman.

Section  4.7  –  Powers.  Except  for  those  rights  reserved  to  the  Members  under  these  bylaws,  the  business  of  the
Corporation will be managed by its Board of Directors, which may exercise all such powers of the Corporation and do
all such lawful acts and things as are not prohibited by the Act, by the Articles of Incorporation or by these Bylaws.
The  Board  of  Directors  will  determine  the  compensation,  if  any,  to  be  paid  to  each  officer  and  director  of  the
Corporation, including those officers who may also be directors.

Section 4.8 – Meetings. The Board of Directors of the Corporation may hold meetings, whether annual or special,
either within or without the State of Missouri, The annual meeting of the Board of Directors for the purpose of electing
officers  and  transacting  such  other  business  as  may  be  brought  before  the  meeting  will  be  held  at  such  time  and
place as the Board of Directors may determine. The Board of Directors may by resolution provide for the time and
place of other regular meetings, and no notice of such regular meetings need to be given.

All other meetings of the Board may be called on the written request of (i) any director or (ii) Members with 25% of the
voting rights of Members in good standing, at such time and place as may be stated in such request.

In  accordance  with  the  terms  of  the  ___[NAME  OF  AREA]_  El  Pollo  Loco®  restaurant  Advertising  Association
Authorization Agreement, a representative of Franchisor shall be entitled to notice of all regular an special meetings
of the Board of Directors of the Corporation and shall have the right to attend all meetings, either in person or in any
other  manner  of  attendance  authorized  in  these  Bylaws.  However,  unless  the  Franchisor  is  a  Director  of  the
Corporation, the Franchisor representative shall have no right to participate in any action of the Board of Directors in
accordance with Sections 4.10 and 4.11 of these Bylaws.

Section 4.9 - Notice of Special Meetings. Written notice of the place, day and hour of any special meeting of the
Board of Directors must be given by or under direction of the Secretary, to each director at least two (2) days before
the meeting; provided, however, that oral notice may be given to directors in lieu of written notice so long as the party
giving the notice to the directors files with the Corporation a written statement of the date, time, place and manner of
the oral notices. Neither the business to be transacted at, nor the purpose of, any meeting of the Board of Directors,
need be stated in the notice or waiver of notice of such meeting.

Section 4.10 - Action Without a Meeting. Any action required to be taken, or which may be taken, at a meeting of
the Board of Directors may be taken without a meeting, if a consent in writing, setting forth the action so to be taken,
is signed by all of the directors entitled to vote. Such consent will have the same effect as a unanimous vote.

Section  4.11  -  Quorum  and  Voting.  At  all  meetings  of  the  Board,  a  majority  of  the  directors  then  in  office  will
constitute a quorum for the transaction of business. The act of a majority of directors present at a meeting where a
quorum is present will be the act of the Board of Directors, except as may be otherwise specifically provided by law,
the Articles of Incorporation or these Bylaws. If at any meeting of the Board of Directors there is less than a quorum
present, a majority of those present may adjourn the meeting, without further notice, from time to time and place to
place until a quorum will have been obtained.

Section 4.12 – Organization. The  President  of  the  Corporation  will  act  as  Chairman  and  the  Secretary  will  act  as
Secretary at all meetings of the Board.

Section  4.13  –  Compensation.  Directors  must  not  receive  any  stated  salary  for  their  services  as  directors  or  as
members of committees, but by resolution of the Board a fixed fee and /or expenses of attendance may be allowed
for attendance at each meeting.

Section  4.14  -  Attendance  by  Telephone.  Any  member  or  members  of  the  Board  of  Directors  will  be  deemed
present and voting at a meeting of the Board if said member or members participate in the meeting by means of a
conference telephone or other communications equipment enabling all persons participating in the meeting to hear
other at the same time. Participation by such means will constitute presence in person at a meeting.

ARTICLE 5 - Officers

Section 5.1 – Officers. The officers of this Corporation will consist of a President, a Secretary and a Treasurer, and
may consist of such other officers, including but not limited to one (1) or more Vice Presidents, Assistant Secretaries
and Assistant Treasurers with such titles, powers and duties as may be prescribed from time to time by the Board of
Directors. They will be elected by the Board of Directors at its annual meeting.

Section  5.2  -  Term  of  Office;  Vacancies.  Each  officer  shall  hold  office  for  one  (1)  year  and  until  such  officer’s
successor is duly elected and qualified. A vacancy in any office arising from any cause may be filled for the unexpired
portion of the term by the Board of Directors.

Section 5.3 - Removal of Officers. Any officer may be removed at any time with or without cause by action of the
Board of Directors by the affirmative vote of a majority of the directors then in office. Election or appointment of an
officer will not of itself create contract rights.

Section 5.4 – Resignations. An officer may resign at any time by delivering notice to the Corporation. A resignation
is  effective  when  the  notice  is  delivered  unless  the  notice  specifies  a  later  effective  date.  If  a  resignation  is  made
effective  at  a  later  date  and  the  Corporation  accepts  the  future  effective  date,  the  Board  of  Directors  may  fill  the
pending vacancy before the effective date if the Board of Directors provides that the successor does not take office
until the effective date of the pending vacancy.

Section 5.5 – Compensation. No compensation will be paid to any officer of the Corporation, except the Board of
Directors may determine a fixed fee or other reimbursement for expenses.

Section 5.6 - Refund of Payment. In the event that the Internal Revenue Service disallows, in whole or in part, the
deduction by the Corporation as an ordinary and necessary business expense of any payment made to an officer of
the  Corporation,  whether  as  salary,  commission,  bonus  or  other  form  of  compensation  or  as  interest,  rent  or
reimbursement of expenses incurred by such officer, such officer must reimburse the Corporation to the full extent of
such disallowance. The Board of Directors of the Corporation will have the duty to require each such officer to make
such reimbursement, and it will be the legal duty of each such officer thus to reimburse the Corporation.

Section 5.7 - Powers and Duties.

A.    In General. The officers of the Corporation will have such powers and duties as generally pertain to their
respective offices, including the powers and duties provided by these Bylaws, as well as such powers and duties as
from time to time may be conferred by the Board of Directors.

B.    President. The President will:

(1) preside at all meetings of the Board of Directors in the absence of the Chairman of the Board, if any;
(2)  present  at  each  annual  meeting  of  the  directors  a  report  of  the  condition  of  the  business  of  the

Corporation;

(3) cause to be called regular and special meetings of the directors in accordance with these Bylaws;
(4) jointly with the Treasurer, sign and make contracts and agreements in the name of the Corporation;
(5)  see  that  the  books,  reports,  statements  and  certificates  required  by  statute  are  properly  kept  and

filed according to law;

(6)  jointly  with  the  Treasurer,  sign  notes,  drafts  or  bills  of  exchange,  warrants  or  other  orders  for  the

payment of money duly drawn on behalf of the Corporation;        

(7) supervise all employees of the Corporation including the hiring and firing of such employees as he or

she deems advisable;

(8) jointly with the Treasurer, purchase on behalf of the Corporation, tangible or intangible assets; and
(9) have general charge of and control over the affairs of the Corporation and perform the entire duties
incident to such position and office, the enforcement of these Bylaws and all other things which the President
is required to do by law.

C. Vice President. The Vice President, if any will;

(1)  in  the  absence  or  disability  of  the  President,  perform  the  duties  and  exercise  the  powers  of  the

President;

(2) perform such other duties and have such other powers as the Board of Directors may from time to

time prescribe.

D. Secretary. The Secretary will:

(1) prepare the minutes of the meetings of the Board of Directors and keep the minutes in appropriate

permanent books of record;

(2) give and serve all notices of the Corporation;
(3) be the custodian of the records and of the seal, and affix the latter when required, and authenticate

records of the Corporation when required; and

(4) attend to all correspondence and perform all the duties incident to the office of the Secretary.

E. Treasurer. The Treasurer will:

(1) keep accounts of and have the care and custody of and responsible for all the funds and securities

of the Corporation;

(2) deposit all such funds in the name of the Corporation in such back or banks, trust company or trust

companies, or safe deposit vaults as the Board of Directors may designate;

(3) exhibit, at times required by law or these Bylaws, the corporate financial books and accounts to any

director upon application at the office of the Corporation during business hours;

(4) render a statement of the condition of the finances of the Corporation (at each regular meeting of the
Board of Directors, and at such other times as it will be required of the Treasurer) and a full financial report at
the annual meeting of the directors;

(5) keep  at  the  office  of  the  Corporation  current  books  of  account  of  all  its  business  transactions  and

such other books of account that the Board of Directors may require;

(6) jointly with the President, sign and make contracts and agreements in the name of the Corporation;
(7)  jointly  with  the  President,  sign  notes,  drafts  or  bills  of  exchange,  warrants  or  other  orders  for  the

    payment of money duly drawn on behalf of the Corporation;

(8) jointly with the President, purchase on behalf of the corporation, tangible or intangible assets, and

(9) do and perform all other duties pertaining to the office of the Treasurer.

F.  Assistant  Secretary  and  Assistant  Treasurer.  The  Assistant  Secretary  or  Assistant  Secretaries  and  the
Assistant Treasurer will, in the absence or disability of the Secretary, or Treasurer, respectively, perform the duties of
such officer and generally assist, in the case of an Assistant Secretary, the Secretary, or an Assistant Treasurer, the
Treasurer.

Section 5.8 - Delegation of Duties. In the case of the absence or disability of any officer of the Corporation or for
any  other  reason  deemed  sufficient  by  a  majority  of  the  Board,  the  Board  of  Directors  may  delegate  such  officer’s
respective powers or duties to any other officer or to any director or agent of the Corporation for a specified period or
until said delegation is revoked by the Board of Directors, provided that such delegation is otherwise permitted by law
and by the Articles of Incorporation and these Bylaws.

ARTICLE 6 - Contributions

Section 6.1 – Contributions. The Members will determine at the final quarterly Member meeting of the fiscal year
the  amount  of  contributions  to  be  paid  to  the  Corporation  by  its  Members  during  the  succeeding  fiscal  year.  The
amount of the contributions will generally be a percentage of Gross Sales, as defined in the most recent Disclosure
Document  issued  by  the  Franchisors,  uniform  among  Members  on  a  per  El  Pollo  Loco®  restaurant  basis.  The
Members may, subject to Franchisor’s approval, vary the level of benefits and/or contributions for any El Pollo Loco®
restaurant that is located in a geographical area in which broadcast coverage is less than eighty-five percent (85%),
according to the most recent A.C. Nielsen or Arbitron coverage study, in order to achieve approximate equivalence in
contributions and benefits of Members. If any Restaurants of a Member are located in geographical areas covered,
according  to  the  most  recent  A.C.  Nielsen  or  Arbitron  coverage  study,  by  more  than  one  regional  advertising
association,  the  variation  in  benefits  and/or  contribution  may  be  coordinated  with  such  other  regional  advertising
association.

Section 6.2 Payment of Contributions

Subject  to  the  terms  of  the  ________[NAME  OF  AREA]  El  Pollo  Loco®  restaurant  Advertising  Association
Authorization Agreement, the Board of Directors will set the dates and method of payment for contributions. However,
Members will not have to pay their contributions for new Restaurants until after their El Pollo Loco® restaurant have
opened for business.

Section  6.3  -  Default  in  Payments.  The  Board  of  Directors  will  establish  policies  and  procedures  for  dealing  with
situations  in  which  Members  have  not  timely  paid  contributions.  The  Board  of  Directors  may  set  interest  rates  and
fees to offset administrative expenses, collection costs, etc. for delinquent payments.

ARTICLE 7- Notices

Section 7.1 – Recording. Whenever these Bylaws require notice to be given to Members, directors, or committee
members,  proof  of  such  notice  whether  given  by  mail,  e-mail,  telecopy,  telephone,  telegraph,  cablegram  or  by
personal contact will be recorded and filed by the Secretary in the minute book and incorporated into the minutes for
the meeting to which such notice pertains.

Section 7.2 – Waiver. Whenever any notice of a meeting is required to be given under the provisions of the Act, of
the Articles of Incorporation, or of these bylaws, a waiver thereof in writing, signed by the person or persons entitled
to such notice either before, at, or after the meeting, will be deemed equivalent to such required notice. Attendance of
a person entitled to notice at a meeting will also constitute a waiver of notice of such meeting; provided, however, that
such attendance will not constitute such a waiver if said person attends said meeting solely for the purpose of, and
limits  his  participation  at  the  meeting  to,  objecting  to  the  transaction  of  any  business  because  the  meeting  is  not
lawfully called or convened and states such objection at the beginning of the meeting.

ARTICLE 8 - Designated Financial Agents, Signatures and Seal

Section  8.1  -  Designated  Financial  Agents.  All  funds  of  the  Corporation  will  be  deposited  in  the  name  of  the
Corporation in such bank or other financial institutions as the Board of Directors may from time to time designate and
will be drawn out on checks, drafts or other order signed on behalf of the Corporation by such person or persons as
the Board of Directors may from time to time designate.

Section 8.2 - Other  Agreements. Except  as  otherwise  specifically  provided  by  these  Bylaws,  all  contacts,
agreements,  deeds,  bonds,  mortgages  and  other  obligations  and  instruments  must  be  signed  on  behalf  of  the
Corporation by the President and Treasurer or by such other officers or agents as the Board of Directors may from
time to time by resolution provide.

ARTICLE 9 - Amendments of Bylaws

The Bylaws may be altered, amended or repealed only by the Members at a meeting of Members, provided that the
notice of the meeting contains a written proposal to amend these Bylaws along with the text of the amendments, and
subject  to  the  prior  written  approval  of  Franchisor  in  accordance  with  the  _______[NAME  OF  AREA]________El
Pollo Loco® restaurant Advertising Association Authorization Agreement. Nevertheless, the amendment of any Bylaw
or replacement of these Bylaws will not be effective unless it has been approved by a voting requirement that is in
excess of the voting requirement that it is replacing. In other words, voting requirement specifying approval by two-
thirds (2/3) can only be changed by a vote of at least that number.

ARTICLE 10 - Indemnification

Section 10.1 - Indemnification in Proceedings Other Than Actions by, or in the Right of, the Corporation. The
Corporation will indemnify any person who was or is a party to any proceedings (other than an action by, or in the
right of, the Corporation), by reason of the fact that he or she is or was a director, officer, employee, or agent of the
Corporation, or is or was serving at the request of the Corporation as a director, committee member, officer, employee
or  agent  of  another  corporation,  partnership,  joint  venture,  trust,  or  other  enterprise  against  liability  incurred  in
connection with such proceeding, including any appeal thereof, if the indemnitee acted in good faith and in a manner
he  reasonably  believed  to  be  in,  or  not  opposed  to,  the  best  interests  of  the  Corporation,  and,  with  respect  to  any
criminal action or proceeding, had no reasonable cause to believe his conduct was unlawful.

Section 10.2 - Indemnification of Persons Parties to a Proceeding by or in the Right of the Corporation.     The
Corporation will indemnify any person who was or is a party to any proceeding by or in the right of the Corporation to
procure a judgment in its favor by reason of the fact that he or she is or was a director, officer, employee, or agent of
the Corporation or is or was serving at the request of the Corporation as the director, officer, employee or agent of
another  corporation,  partnership,  joint  venture,  trust  or  other  enterprise,  against  expenses  and  amounts  paid  in
settlement  not  exceeding,  in  the  judgment  of  the  Board  of  Directors,  the  estimated  expense  of  litigating  the
proceeding  to  conclusion,  actually  and  reasonably  incurred  in  connection  with  the  defense  or  settlement  of  such
proceeding, including any appeal thereof. Such indemnification may be authorized if such person acted in good faith
and  in  a  manner  he  or  she  reasonably  believed  to  be  in,  or  not  opposed  to,  the  best  interests  of  the  Corporation.
Provided,  however,  that  no  indemnification  may  be  made  hereunder  in  respect  of  any  claim,  issue,  or  matter  as  to
which  such  person  has  been  adjudged  to  be  liable,  unless,  and  only  to  the  extent  that,  the  court  in  which  such
proceeding was brought, or any other court of competent jurisdiction, determines upon application that, despite the

adjudication of liability, but in view of all circumstances of the case, such person is fairly and reasonably entitled to
indemnity for such expenses which such court deems proper.

Section  10.3  -  Mandatory  Indemnification.          To  the  extent  that  a  director,  officer,  employee  or  agent  of  the
Corporation has been successful on the merits or otherwise in defense of any proceeding referred to in Sections 10.0
and 10.2 above, or in defense of any claim, issue or matter therein, he or she must be indemnified against expenses
actually and reasonably incurred by him or her in connection therewith.

Section  10.4  -  Authorized  of  Indemnification  is  Required.  Any  indemnification  under  Sections  10.1  and  10.2,
unless  pursuant  to  a  determination  by  a  court,  may  be  made  by  the  Corporation  only  as  authorized  in  the  specific
case  upon  a  determination  that  indemnification  of  the  director,  officer,  employee,  or  agent  is  proper  in  the
circumstances because he or she has met the applicable standard of conduct set forth in Section 10.1 or 10.2. Such
determination must be made pursuant to any procedures outlined by the Act, if any.

Section 10.5 - Additional Conditions to Indemnification. The Board, by a majority vote of a quorum consisting of
directors who were not parties to the action, suit or proceeding to which the indemnification relates, may impose such
additional conditions upon any form of indemnification as the Board may deem appropriate, including, but not limited
to,  the  right  to  assume  the  defense  in  appropriate  circumstances,  the  right  to  select  the  attorney  representing  the
indemnified person and the right to settle.

Section 10.6 - Prepayment of Expenses. Expenses (including attorneys’ fees and expenses) incurred in defending
a civil or criminal action, suit or proceeding must be paid by the Corporation in advance of the final disposition of such
action, suit or proceeding upon a preliminary determination following the procedures set forth in Section 10.04 that
such indemnified person meets the applicable standard of conduct referred to therein and subject to any conditions
imposed by the Board pursuant to this Article and the prior receipt by the Corporation of an undertaking satisfactory in
form  and  substance  to  the  Corporation  that  such  person  will  promptly  repay  such  amount  unless  it  is  ultimately
determined that the person is entitled to be indemnified by the Corporation as authorized in this Article 10.

Section  10.7  -  Indemnification  Disallowed  in  Certain  Circumstances.  The  indemnification  provided  pursuant  to
this article may not be made to or on behalf of any director, officer, employee, or agent if a judgment or other final
adjudication  establishes  that  his  or  her  actions,  or  omissions  to  act,  were  material  to  the  cause  of  action  so
adjudicated and constitute:

A. a violation of the criminal law, unless the director, officer, employee or agent had reasonable cause to

believe his or her conduct was lawful or had no reasonable cause to believe his or her conduct was unlawful;

B.  a  transaction  from  which  the  director,  officer,  employee  or  agent  directly  or  indirectly  derived  an

improper personal benefit;

C. in the case of a director, a circumstance under which the director would be liable to the Corporation

under the Act; or

D. willful misconduct or a conscious disregard for the best interests of the Corporation in a proceeding

by or in the right of the Corporation to procure a judgment in its favor.

Section 10.8 – Nonexclusively. The Corporation has the power to make any other or further indemnification of any
of its directors, officers, members of any committee, or any other person that the Corporation has the power by law to
indemnify, including without limitation, employees or agents of the Corporation, under any bylaw, agreement, vote of
disinterested  directors,  or  otherwise,  both  as  to  action  in  any  official  capacity  and  as  to  action  in  another  capacity
while  holding  such  office,  except  an  indemnification  against  gross  negligence  or  willful  misconduct.  The
indemnification as provided in this Article will continue as to any person who has ceased to be a director, officer, or
agent and will insure to the benefit of such person’s heirs and personal representatives.

ARTICLE 11 - General Provisions

Section 11.1 - Fiscal Year. The fiscal year of the Corporation shall be either fifty-two (52) or fifty-three (53) weeks
and end on the last Saturday in December of each year.

Section 11.2 - Gender and Number.     Whenever the context requires, the gender of all words used herein includes
the masculine, feminine and neuter, and the number of all words includes the singular and plural thereof.

Section  11.3  -  Articles  and  Other  Headings.  The  Articles  and  other  headings  contained  in  these  Bylaws  are  for
reference purposes only and will not affect the meaning or interpretation of these Bylaws.

Section 11.4 - Minutes, Books and Records of Account. The Corporation will keep correct and complete books
and  records  of  account  and  will  keep  minutes  of  the  proceedings  of  its  Board  of  Directors  and  other  records  as
required by the Act.

Section 11.5 - Statutory Cites. Any reference in these Bylaws to the Act will include all revisions and amendments
to the Act.

Exhibit D of Multi-State Disclosure Document Control No. 032619

Franchise Agreement - Page 5 of 5

EXHIBIT 6: EL POLLO LOCO® FINANCIAL REPORTING FORM

You will be required to submit quarterly and year-end financial statements electronically in the following format. The
financials should be comparative showing the prior year amounts for the same periods. There should be columns for
both  the  recently  completed  quarter  and  a  Year-to-date  column,  if  applicable.  Do  not  include  officer’s  salary,  auto
expenses, or any other above restaurant expenses should not be included.

Gross Sales

Net Sales

Food Cost
Paper Cost
Total Food & Paper
Gross Profit

Hourly and Manager labor
Fringe Benefits (a)
Total Labor

Utilities
Repair and Maintenance
Cash Over/Short
Controllable Costs (b)
Restaurant Controllable Profit

Advertising
Royalties
Indirect Costs (c )
Occupancy Costs (d)

Amount
0  

  $

%

0

0
0
0
0

0
0
0

0
0
0
0
0

0
0
0
0

100.0%

0.0%
0.0%
0.0%
0.0%

0.0%
0.0%
0.0%

0.0%
0.0%
0.0%
0.0%
0.0%

0.0%
0.0%
0.0%
0.0%

Restaurant Operating Profit

$____

____% 

(a) To include payroll taxes, health benefits, vacation, and workers compensation expense
(b) To  include  trash,  store  security,  uniforms,  laundry,  cleaning/janitorial,  operating  supplies,  music  and  plant

service, landscape, and other misc. restaurant costs not captured elsewhere.

Exhibit 6 to Franchise Agreement (Exhibit D of Multi-State Disclosure Document Control No. 032619)

El Pollo Loco® Financial Reporting Form - Page 6 of 6

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(c) To include credit card fees, bank charges, licenses, permits, fees, and pre-opening costs
(d) To include minimum and percentage rent, property taxes and insurance.

EXHIBIT 7: IT SUPPORT SERVICES AGREEMENT

Customer:

Franchise Store Number(s) Covered:

Customer Site(s):

Date of Franchise Agreement(s):

Effective Date:

Customer’s Authorized Representative(s)/Contacts:

Invoices to Customer to be sent to:

Notices, if to Customer, to be sent to:

El Pollo Loco IT:

Notices, if to El Pollo Loco IT, to be sent to:

Term Commencement Date:

Term Expiration Date:

Upon expiration of the Franchise Agreement(s),
unless sooner terminated as provided by the
Franchise Agreement(s)

Service Level Description

See Attached EPL IT Standard Platinum Service
Description

Annual Fees:

See Attached Franchise Support Options

Special Terms:

See Website

The  authorized  representatives  of  Customer  and  El  Pollo  Loco,  intending  to  be  legally  bound,  agree  to  the
terms  and  conditions  of  this  IT  Support  Services  Agreement  (“Agreement”),  including  without  limitation
documents incorporated by reference, as of the Effective Date.

El Pollo Loco IT: 
El Pollo Loco, Inc., a Delaware corporation

Customer:
___________________, a _________

By:

Name:

Title:

Date:

TERMS AND CONDITIONS

By:

Name:

Title:

Date:

1.

Performance.  El  Pollo  Loco  Informational  Technology  (“EPL  IT”)  shall  make  available  to  Customer
certain operations support services for the Service Level designated on the first page of this Agreement (“Services”)
based  on  EPL  IT’s  standard  description  of  services  for  such  Service  Level  in  accordance  with  the  terms  and
conditions  of  this  Agreement.  The  Services  are  limited  to  the  standard  EPL  franchise  store  configuration  unless

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
otherwise  agreed  upon  in  writing  by  EPL  IT  (“Standard  Store  Configuration”).  The  Services  are  limited  to  those
listed in the Services Descriptions in this Agreement and will be performed for the stated pricing. EPL IT shall perform
additional services as detailed and mutually agreed to by the Parties upon additional payment by Customer, Services
will be performed during EPL IT’s normal business hours as listed in the Services Descriptions. EPL IT reserves the
right to restrict access to the Services during periods of routine back-up, maintenance, scheduled downtime and other
activities  outside  such  normal  business  hours.  Information  relevant  to  Services  may  be  posted  on  the  EPL  internal
Customer  website  (“Website”).  Information  in  the  Website  or  other  EPL  documents,  may  be  changed  or  updated
without  notice.  EPL  may  also  make  improvements  and/or  changes  in  the  Services  or  pricing  at  any  time  without
notice.

2.

Customer Obligations. As a condition precedent to EPL IT performing its obligations hereunder, and in
addition  to  Customer's  other  obligations  as  set  forth  in  EPL  IT’s  standard  description  of  services  for  the  applicable
Service  Level,  Customer  shall  timely  provide  the  following  at  no  charge  to  EPL  IT:  (a)  access  to  and  use  of
reasonable working space, facilities and utilities, (b) any information, software, equipment, data and/or documentation
(collectively, “Data”) that EPL IT reasonably requests from Customer that is necessary for EPL IT to properly perform
its obligations hereunder; and (c) all components in the Standard Store Configuration and all updates, enhancements,
upgrades and replacements thereto recommended or otherwise identified in writing by EPL IT. Customer represents
to EPL IT that it has the right to grant EPL IT access to such facilities and Data for the performance of the Services.
Such Data shall be kept confidential by EPL IT in accordance with Section 4. In the event that there are any delays by
Customer in the timely providing of facilities, access, Data, or the Standard Store Configuration or there are errors or
inaccuracies  in  the  Data  or  the  Standard  Store  Configuration  provided,  and  such  delays,  errors  or  inaccuracies
require additions, corrections or modifications related to EPL IT's performance hereunder, then any costs associated
therewith shall be the responsibility of Customer, and EPL IT shall be entitled to appropriate adjustments. Customer
shall designate two points of contact who shall be the only people to make inquiries to EPL IT under this Agreement,
as  set  forth  on  the  first  page  of  this  Agreement.  Each  Customer  contact  must  possess,  or  at  Customer’s  expense
acquire the necessary familiarity, expertise and training on the Standard Store Configuration with direction by EPL IT.
Prior to requesting support, Customer will comply with all published operating and troubleshooting procedures for the
components of the Standard Store Configuration and, if such efforts are unsuccessful in eliminating the malfunction,
Customer  shall  promptly  notify  EPL  IT  of  any  problems  discovered  in  the  operation  of  the  Standard  Store
Configuration.  Customer  must  identify  the  Franchise  Store  Number  when  accessing  the  Services.  Customer  must
cooperate  with  EPL  IT  to  maintain  a  site  activity  log.  Customer  will  perform  routine  preventive  maintenance  and
cleaning  of  the  Standard  Store  Configuration  Customer  shall  be  solely  responsible  for  the  accuracy  of  all  Data
collected  and  submitted  to  third  party  suppliers  for  credit  card  processing.  Customer  shall  comply  with  such
reasonable  policies,  procedures  and  rules  relating  to  the  Services  as  EPL  IT  may  from  time  to  time  publish  on  its
Website or designate in writing to Customer. Customer shall educate and train their restaurant managers in how to
run their point of sales. Customer will ensure that all third parties, including its employees or contractors, using the
Services or any components of Customer’s Standard Store Configuration abide by Customer’s obligations under this
Agreement in their use thereof. Any act or omission of any third party related to Customer’s obligations hereunder or
the  use  of  any  Services,  Reports  or  Standard  Store  Configuration  shall  be  deemed  to  be  the  act  or  omission  of
Customer for all purposes whether or not Customer had knowledge of or had authorized such act or omission.

3.

Price  and  Payment  Terms. In  consideration  for  the  Services  performed  pursuant  to  this  Agreement,
Customer shall pay EPL IT based upon the fees specified on the first page of this Agreement (“Fees”) and any Other
Fees as defined below. EPL IT reserves the right to increase the Fees at any time, which would take effect upon the
first  day  of  the  following  month  by  providing  Customer  with  thirty  (30)  days  prior  written  notice  setting  forth  the
adjustment  to  the  Fees.  EPL  IT  shall  automatically  debit  Fees  from  Customer’s  account  via  ACH  funds  transfer  in
accordance with the terms indicated on the first page of this Agreement. The first installment is due and payable on
the first day of this Agreement. Subsequent payments or account ACH funds transfers will be made according to the
schedule specified under the terms indicated on the first page of this Agreement. Customer shall reimburse EPL IT
the  following  fees  collectively  defined  as  (“Other Fees”)  should  they  be  incurred  by  Customer:  (a)  any  reasonable
and  properly  documented  out-of-pocket  travel  and  living  expenses  incurred  by  EPL  IT  personnel  during  their
performance of the Services; (b) any reasonable and properly documented services and/or equipment, which EPL IT,
or their designated representative, determines, as its sole and absolute right, to be outside the scope of the Services
including, but is not limited to, (i) software license fees, (ii) software updates, (iii) hardware updates associated with
software  updates,  (iv)  onsite  services,  (v)  consulting  services,  (vi)  equipment  and  any  associated  shipping  and
handling charges incurred by EPL IT; and (c) the Professional service rates described under Complete I.T. Operations
Support  plus  materials  charges  incurred  in  the  performance  of  such  services  or  if  an  outside  designated
representative is used, at the rate they charge plus materials charges incurred in the performance of such services.
Invoices  for  Other  Fees  shall  be  submitted  to  Customer  by  EPL  IT  on  a  per  incident  basis.  Customer  may  not
withhold or set off any amounts due. EPL IT shall automatically direct debit Other Fees from Customer’s account via
ACH funds transfer upon advance written notice via electronic mail to Customer. All sums payable to EPL IT shall be
made in United States dollars and due ten (10) days from the date of EPL IT's invoice should EPL IT be unable to
direct debit Fees from Customer’s account via ACH funds transfer. All amounts past due shall accrue interest from
their due dates at the rate of one and one-half percent (1.5%) per month or the maximum percentage allowable by
law (whichever is less). All amounts due (including the Fees) do not include any federal, state or local sales, use or
excise  taxes  or  other  charges  assessed  against  or  payable  by  EPL  IT  in  connection  with  this  Agreement,  and
Customer shall pay to EPL IT the amount of any such taxes that EPL IT may be required to pay on account of its
performance under this Agreement except for any franchise tax or tax based upon EPL IT's net income or personal
property. EPL IT reserves the right to cease performance and assert appropriate liens if all amounts are not paid in
full when due.

 
4.

Confidential & Proprietary Information. Each party shall maintain in strict confidence, and not disclose
or distribute to any third person any Confidential Information of the other party for a period of three (3) years from the
date of disclosure (except with respect to trade secrets, which shall be kept confidential until no longer qualifying as a
trade  secret).  “Confidential  Information”  shall  mean  the  information  disclosed  by  either  party  pursuant  to  this
Agreement that is (a) stamped or otherwise marked as being confidential by the disclosing party, (b) if disclosed in
oral form, identified as confidential at the time of oral disclosure and is summarized by the disclosing party in a written
memorandum marked as confidential and delivered within ten (10) business days after such disclosure, or (c) of such
a  nature  as  to  put  a  reasonable  party  on  notice  as  to  the  confidentiality  of  the  information  disclosed.  Confidential
Information does not include any information that: (i) entered the public domain through no fault of the receiving party;
(ii)  is  rightfully  received  by  the  receiving  party  from  a  third  party  without  similar  non-disclosure  obligations;  (iii)  is
already known to the receiving party prior to disclosure by the disclosing party; (iv) is independently developed by the
receiving  party  without  reference  to  the  Confidential  Information  of  the  disclosing  party,  or  (v)  is  required  to  be
disclosed by law, provided that the party intending to make such required disclosure shall promptly notify the other
party  of  such  intended  disclosure  in  order  to  allow  such  party  to  seek  a  protective  order  or  other  remedy.  The
obligations set forth above in this Section shall not affect EPL IT's ownership of Inventions (as defined in Section 5)
and all intellectual property rights therein, or EPL IT's full exercise of those Inventions and intellectual property rights,
so  long  as  EPL  IT  does  not  disclose  Customer's  Confidential  Information.  All  Inventions  shall  constitute  EPL  IT’s
Confidential Information.

5.

Proprietary Rights. EPL IT or its subcontractors or suppliers, as applicable, retain sole ownership of all
designs, engineering details, data, methodologies, ideas, concepts, discoveries, inventions, improvements, works of
authorship, technology or information. and all enhancements, modifications and derivative works thereof (collectively,
“Inventions”),  and  all  intellectual  property  rights  therein,  used  or  created  by  EPL  IT  or  such  subcontractors  in  the
performance of the Services, and shall have the exclusive right to determine how to protect the Inventions. Reports or
other  work  product  delivered  by  EPL  IT  to  Customer  under  this  Agreement  are  provided  to  Customer  with  Limited
Rights.  “Reports”  means  the  written  reports  or  work  product  specifically  produced  by  EPL  IT  in  performing  the
Services and specified to be an item delivered to Customer. “Limited Rights” means the right of Customer to use the
Reports in operating Customer’s Standard Store Configuration for Customer’s own internal business purposes only,
but in no event the right to make copies, modifications, enhancements or derivative works thereof or resell, distribute,
exploit or sublicense such Reports or any portion thereof. EPL IT retains for itself, its parent company, affiliates and
subsidiaries, the right to retain and make copies of the Reports and to make use of the contents thereof for its and
their business use and, as to any portion of such contents that is not Customer’s Confidential Information, to make
use thereof for any purpose, whether internal or otherwise.

6.

Limited Warranty. EPL IT warrants to Customer only that: (i) for a period of thirty (30) days from the
date of completion of its performance of a particular task under the Services, the particular task will be performed in a
good  and  workmanlike  manner  consistent  with  standard  industry  practices  employed  by  persons  knowledgeable  in
the field of computers and within the limits of the technology embodied in the Standard Store Configuration; and (ii)
for a period of thirty (30) days from the date of delivery of a particular Report, that Report will be free from material
defects  in  workmanship  and  materials,  and  will  conform  in  all  material  respects  to  the  applicable  descriptions  or
specifications provided by EPL IT to Customer In the event of a breach by EPL IT of the foregoing warranty of which
Customer  notifies  EPL  IT  in  writing  during  the  warranty  period,  EPL  IT's  sole  obligation  and  Customer’s  exclusive
remedy shall be for EPL IT to use commercially reasonable efforts to re-perform the task or to correct the portion of
the Report that does not conform to such warranty. In the event EPL IT is unable to re-perform such task or to make
such  corrections,  as  applicable,  the  sole  remedy  of  Customer  and  EPL  IT'  sole  obligation  shall  be  to  recover  the
compensation actually paid to EPL IT for the Service or the Report giving rise to such warranty failure. This  limited
warranty with respect to any Services or Reports shall be voided in the event Customer: (i) makes additions to, alters,
modifies, enhances, changes, repairs or disassembles or reverse engineers the Standard Store Configuration, or fails
to  maintain  the  Standard  Store  Configuration  (or  any  component  thereof  or  any  equipment  or  facilities  upon  which
such component depends) in good working order or the environmental conditions within the operating range specified
by  the  manufacturer  of  the  components  in  the  Standard  Software  Configuration  or  EPL  IT;  (ii)  uses  the  Standard
Store  Configuration  or  any  Report  in  a  manner  for  which  it  was  not  designed,  or  in  an  incompatible  operating
environment;  or  (iii)  mishandles,  abuses,  misuses  or  damages  the  Standard  Store  Configuration.  THE  LIMITED
WARRANTY STATED IN THIS SECTION AND THE REMEDIES FOR A FAILURE OR BREACH OF SUCH LIMITED
WARRANTY  ARE  EXCLUSIVE.  THEY  ARE  GIVEN  TO  CUSTOMER  IN  LIEU  OF  ALL  OTHER  WARRANTIES,
WRITTEN  OR  ORAL,  STATUTORY,  EXPRESS  OR  IMPLIED,  INCLUDING  WITHOUT  LIMITATION,  THE  IMPLIED
WARRANTIES  OF  MERCHANTABILITY,  FITNESS  FOR  A  PARTICULAR  PURPOSE,  TITLE,  ACCURACY,  QUIET
ENJOYMENT,  NON-INFRINGEMENT,  OR  COURSE  OF  PERFORMANCE  OR  DEALING,  WHICH  EPL  IT
SPECIFICALLY DISCLAIMS.

7.

Limitation  of  Damages.  IN  NO  EVENT  SHALL  EPL  IT  (OR  ITS  SUPPLIERS)  BE  LIABLE  TO
CUSTOMER FOR LOST PROFITS, LOSS OR INTERRUPTION OF BUSINESS, LOSS OF DATA OR ANY SPECIAL,
INCIDENTAL,  EXEMPLARY,  PUNITIVE,  CONSEQUENTIAL  OR  OTHER  DAMAGES,  HOWEVER  CAUSED,  AND
WHETHER BASED IN CONTRACT, TORT (INCLUDING NEGLIGENCE) OR ANY OTHER THEORY OF LIABILITY.
THE  FOREGOING  LIMITATION  SHALL  APPLY  EVEN  IF  EPL  IT  (OR  ITS  SUPPLIERS)  KNOW  OR  HAVE  BEEN
ADVISED OF THE POSSIBILITY OF SUCH DAMAGE AND NOTWITHSTANDING ANY FAILURE OR ESSENTIAL
PURPOSE  OF  ANY  LIMITED  REMEDY  PROVIDED  FOR  HEREIN.  EXCEPT  IN  RESPECT  OF  INJURY  TO  OR
DEATH OF ANY PERSON RESULTING FROM THE GROSS NEGLIGENCE OR WILLFUL MISCONDUCT OF EPL
IT, ITS EMPLOYEES, AGENTS OR SUBCONTRACTORS (FOR WHICH NO LIMIT APPLIES), IN NO EVENT WILL
EPL  IT'S  ENTIRE  LIABILITY  UNDER  THIS  AGREEMENT  EXCEED  THE  GREATER  OF  (A)  THE  FEES  PAID  TO
EPL  IT  FOR  THE  AFFECTED  SERVICE  OR  REPORT  UNDER  THIS  AGREEMENT  OR  (B)  $5,000.00.  IN  NO

EVENT  SHALL  EPL  IT  HAVE  ANY  LIABILITY  FOR  ANY  COMPONENT  OF  THE  STANDARD  STORE
CONFIGURATION (AS DESCRIBED IN THE EPL IT STANDARD SERVICES DESCRIPTION). IN ADDITION, EPL IT
SHALL  NOT  BE  LIABLE  UNDER  ANY  CLAIM  BROUGHT  UNDER  ANY  THEORY  OF  LAW  THAT  AROSE  MORE
THAN  ONE  (1)  YEAR  PRIOR  TO  THE  INSTITUTION  OF  SUIT  THEREON.  EPL  IT  SHALL  NOT  BE  LIABLE  FOR
ANY  LOSS  OR  DAMAGE  CAUSED  BY  DELAY  IN  FURNISHING  ANY  COMPONENT  OF  THE  STANDARD
NETWORK  OPERATING  ENVIRONMENT,  ANY  REPORTS,  ANY  SERVICES,  OR  ANY  OTHER  PERFORMANCE
UNDER  OR  PURSUANT  TO  THIS  AGREEMENT.  EACH  PARTY  ACKNOWLEDGES  AND  AGREES  THAT  THE
FOREGOING  LIMITATIONS  ON  LIABILITY  ARE  ESSENTIAL  ELEMENTS  OF  THE  BASIS  OF  THE  BARGAIN
BETWEEN  THE  PARTIES  AND  THAT  IN  THE  ABSENCE  OF  SUCH  LIMITATIONS,  THE  MATERIAL  AND
ECONOMIC TERMS OF THIS AGREEMENT WOULD BE SUBSTANTIALLY DIFFERENT.

8.

Term  &  Termination.  This  Agreement  shall  commence  on  the  term  commencement  date  set  forth
above  and  continue  in  effect  through  the  expiration  of  the  Franchise  Agreement(s)  or  the  earlier  termination  of  the
Franchise Agreement(s) listed on Exhibit “A” attached hereto and incorporated herein by reference.

9.

Default. If any material breach of this Agreement continues uncorrected for more than thirty (30) days
after written notice from the aggrieved party describing the breach, the aggrieved party shall be entitled to declare a
default, suspend performance, terminate this Agreement, and pursue any and all other remedies available at law or
equity, except as specifically limited elsewhere in this Agreement.

10.

Notices.  Notices,  authorizations  and  other  official  communications  under  this  Agreement  shall  be
transmitted in writing by prepaid United States certified mail, return receipt requested, or overnight receipted courier,
to EPL IT, at the address and attention of the person set forth on the first page of this Agreement for EPL IT and to
Customer, to the billing address and attention of the person set forth on the first page of this Agreement for Customer.
Any notice given pursuant to this Section shall be deemed to have been received, in the case of certified mail, on the
date of receipt as evidenced by the U.S. Postal Service return receipt card, and, in the case of overnight courier, on
the  next  business  day  after  sending,  unless  documented  otherwise  by  recipient.  All  notices  must  be  in  the  English
language.

11.

Assignment. Neither this Agreement nor any of the rights or obligations hereunder may be assigned
by  either  party,  in  whole  or  in  part,  without  the  prior  written  consent  of  the  other  party,  such  consent  not  to  be
unreasonably withheld. Notwithstanding the preceding sentence, either party may assign this Agreement to its parent
company  or  another  affiliated  company  without  the  consent  of  the  other  party  but  upon  written  notice  to  the  other
party; provided that the successor unconditionally agrees in writing to be bound by the terms and conditions of this
Agreement.

12.

Subcontracting.  EPL  IT  reserves  the  right  to  subcontract  such  portions  of  the  Services  to
subcontractors of EPL IT's choice as it deems appropriate, provided that no such subcontract shall relieve EPL IT of
primary responsibility for performance of such Services.

13.

Reserved Rights.  EPL  IT’s  service  offerings  are  continually  evolving.  Accordingly,  EPL  IT  reserves
the right to make service substitutions and modifications and to modify or amend its standard description of services
for each Service Level at any time by publication including posting on its Website or written notice to Customer. All
Services will be delivered in English. EPL IT reserves the rights to charge Customer if dispatch is required, or if the
restaurant  support  center  receives  excessive  training  calls  as  described  under  Franchise  Support  Options  –  Fee
Schedule.

14.

Indemnification. Each party shall indemnify, defend and hold harmless the other with respect to any
third  party  claim  alleging  bodily  injury,  including  death,  or  damage  to  tangible  property,  to  the  extent  such  injury  or
damage is caused by the gross negligence or willful misconduct of the indemnifying party. Customer shall indemnify,
defend and hold harmless EPL IT, at Customer’s expense, from and against any action brought against EPL IT by a
third  party,  to  the  extent  that  such  action  is  based  on  a  claim  relating  to  Customer’s  Standard  Store  Configuration,
Data or the performance of Services hereunder. A condition precedent to any obligation of a party to indemnify shall
be for the other party to promptly advise in writing the indemnifying party of the claim and turn over its defense. The
party  being  indemnified  must  cooperate  in  the  defense  or  settlement  of  the  claim,  but  the  indemnifying  party  shall
have sole control over the defense or settlement. If the defense is properly and timely tendered to the indemnifying
party,  then  the  indemnifying  party  must  pay  all  litigation  costs,  reasonable  attorney's  fees,  settlement  payments
agreed to by the indemnifying party and any damages finally awarded by a court; provided, however, that this shall
not be construed to require the indemnifying party to reimburse attorney's fees or related costs that the indemnified
party incurs either to fulfill its obligation to cooperate, or to monitor litigation being defended by the indemnifying party.

15.

Independent Contractor. Nothing in this Agreement shall be interpreted or construed so as to create
any  relationship  between  the  parties  other  than  that  of  independent  contracting  entities.  Neither  party  shall  be
authorized to obligate, bind or act in the name of the other party, except to the extent EPL IT is expressly authorized
to do so in this Agreement.

16.

Non-Solicitation. Customer shall not solicit or otherwise seek, directly or indirectly, to induce any of
EPL IT’s employees or contractors to work for Customer for a period of one (1) year after the employee or contractor
ceases  to  be  employed  or  otherwise  utilized  by  EPL  IT  or  one  (1)  year  after  the  termination  of  this  Agreement,

whichever  is  greater.  Prohibited  solicitation  includes,  but  is  not  limited  to,  the  direct  solicitation  of  any  individual  or
contracting with a third party to intentionally solicit an individual covered by this Section.

17.

Similar Services. Customer acknowledges that EPL IT is free to offer services or work product similar

to the Services or Reports to other EPL IT customers or third parties without restriction or royalty to Customer.

18.

Applicable Law. The rights and obligations of the parties and all interpretations and performance of
this Agreement shall be governed in all respects by the laws of the State of California except for its rules with respect
to the conflict of laws.

19.

Force  Majeure.  In  no  event  shall  either  party  have  any  liability  for  failure  to  comply  with  this
Agreement if such failure results from the occurrence of any contingency beyond the reasonable control of the party
and which delays, interrupts or prevents such party from performing its obligations under this Agreement, including,
without  limitation,  strike  or  other  labor  disturbance  or  shortage,  riot,  theft,  flood,  lightning,  storm,  any  act  of  God,
power  failure,  war,  delays  or  failure  of  third  party  equipment,  software  or  service  suppliers,  national  emergency,
interference by any government or governmental agency, embargo or seizure. The party affected by a force majeure
event shall give notice thereof to the other party within ten days following the occurrence thereof and shall apprise the
other party of the probable extent to which the affected party will be unable to perform or will be delayed in performing
its  obligations  hereunder.  The  affected  party  shall  exercise  due  diligence  to  eliminate  or  remedy  the  force  majeure
cause and shall give the other party prompt notice when that has been accomplished. Except as provided herein, if
performance of this Agreement by either party is delayed, interrupted or prevented by reason of any event of force
majeure,  both  parties  shall  be  excused  from  performing  hereunder  while  and  to  the  extent  that  the  force  majeure
condition exists after which the parties’ performance shall be resumed.

20.

Waiver. Failure by either party to require performance by the other party or to claim a breach of any
provision of this Agreement will not be construed as a waiver of any right accruing hereunder or of any subsequent
breach, and will not affect the effectiveness of this Agreement or any part hereof, or prejudice either party regarding
any subsequent action.

21.

Invalidity. If any provision of this Agreement is held invalid, the remaining provisions shall continue in
full  force  and  effect  and  the  parties  shall  substitute  for  the  invalid  provision  a  valid  provision  which  most  closely
approximates the economic effect and intent of the invalid provision.

22.

Attorneys’ Fees. In any dispute or litigation between the parties, the prevailing party shall be entitled

to reasonable attorneys’ fees and all costs of proceedings incurred in enforcing this Agreement.

23.

Entire Agreement. This Agreement constitutes the entire agreement between EPL IT and Customer
with respect to the subject matter hereof and supersedes all previous negotiations, proposals, commitments, writings,
advertisements, publications and understandings of any nature and in any manner whatsoever relating thereto, but
does  not  amend  or  supersede  any  Franchise  Agreement  between  EPL  and  Customer.  No  agent,  employee  or
representative of EPL IT has any authority to bind EPL IT to any affirmation, representation, or warranty concerning
the Services and unless such affirmation, representation or warranty is specifically included within this Agreement, it
shall not be enforceable by Customer or any assignee or sublicensee of Customer. Any terms and conditions on any
Customer  purchase  order  form  or  other  document  issued  by  Customer  to  implement  this  Agreement  that  are  in
addition to or in conflict with the terms and conditions of this Agreement shall be null and void, even if acknowledged
in writing by EPL IT. This Agreement may be executed in two or more counterparts, each of which shall be deemed
an  original  and  all  of  which  together  shall  constitute  one  instrument,  and  facsimile  or  electronic  signature  shall  be
treated as originals.

EPL IT STANDARD SERVICES DESCRIPTIONS
(Date: March 26, 2019)

For a current/updated EPL IT Standard Services Descriptions, click on:

Platinum Service Descriptions
Unlimited number of calls per month per store
Standard Store Configuration includes:

• Back of house system
• Two front counter POS terminals with receipt printers
• Two drive thru POS terminals with receipt printer
• Four KDS systems (four monitors and four controllers)
• BROADBAND Wide Area Network connection, router and firewall
• All  local  area  network  components  including  equipment  rack,  UPS,  patch  panel,  patch  cords,  cabling

infrastructure and data jacks

• Normal Business Hours are 8:00 A.M. to 5:00 P.M., Pacific Time Monday through Friday excluding EPL

IT’s normal published holidays and schedule downtimes for maintenance and support*

• Backup internet

• WIFI (Consumer/Guest and Internal)
• Android Tablet (e.g., Samsung Galaxy Tab A)
• Optional - Three (3) digital menu boards (three (3) panels and three (3) controllers)

COMPLETE I.T. OPERATIONS SUPPORT

Hardware Service and Support:

Restaurant POS Equipment:  Helpdesk  will  initiate  advance  depot  repair  and/or  replacement  for  all  POS  hardware,
including  back  of  house  server,  KDS  system,  front  of  house  terminals  and  cash  drawers,  receipt  printers,  network
switch, UPS, (digital menu boards and controllers if requested by Customer) and line conditioners will be supported
through  an  approved  depot  partner.  Customer  may  enroll  in  the  depot  warranty  program  offered.  Customer  must
notify  EPL  IT  in  writing  at  least  30  days  prior  to  any  changes  in  hardware  support  agreements  Customer  has
established. Equipment replaced via our current approved depot partner “Washburn” is covered against breakage for
90 days after replacement depot processing. Customer is responsible for all costs associated with depot or any other
hardware provider. All depot payments are processed directly to Customer accounts setup with the depot company
directly. Customer may opt to maintain hardware support agreements with Micros or any other hardware provider at
their own discretion. The EPL helpdesk will support full dispatch and implementation management of Customer that
opt  into  the  Washburn  depot  program.  The  EPL  helpdesk  will  NOT  support  any  hardware  related  issues  for
Customers that are not using an approved depot partner.

Software Service and Support includes:

• Micros Enterprise Management, currently version 5.7
• Patching of installed MyEpl.Net Web Based Portal
• Patching  of  critical  security  updates  for  installed  operating  system,  currently  version  Windows  10

Professional

• Current updates on antivirus software
• Current updates on anti-malware software
• Endpoint DLP (data loss protection) which includes white listing
• Software disaster recovery tool
• Proactive monitoring via EPL Alerts program
•
• WIFI Cloud Management / Consumer WIFI
• Digital Menu Board management / price integration

LMS (EDUonGO learning management solution)

Credit Card Processing includes:

• Acceptance of Visa, MasterCard, American Express and Discover
• Secure high speed credit card authorization as primary
• Secure low speed credit card authorization as backup
• NFC Payments (Apple Pay/Android Pay/Samsung Pay)
• Gift card Processing

Payment Card Industry (“PCI”) Program includes:

• Educating  EPL  Franchisees  about  cardholder  data  security,  the  Payment  Card  Industry  (“PCI”)  Data

Security Standard (“DSS”) and PCI DSS compliance

• Providing Automated Quarterly Network Scanning of stores for potential security issues.
• Executing a compliance strategy that helps to:
o Eliminate the storage of prohibited data
o Protect stored data
o Secure the merchant network environment via compliance with the PCI DSS
o Identify the payment applications used and ensures merchants use or switch to Payment Application

(“PA”) that comply with the PA-DSS

• Tracking and reporting on the program’s progress each month

Firewall Service and Support includes:

• Repair and/or replacement cost of firewall
• Software maintenance on firewall
• Remote monitoring of up/down state
•
• Quarterly PCI Scanning
• WIFI Firewall / SSID Configuration

Latest security updates to prevent unauthorized intrusion attacks

Broadband WAN Service and Support includes:

• High speed access to all credit card processing
• High speed access to MyEpl.net Portal
• Does not include unrestricted Internet access
•

24x7 active monitoring and alerting

Helpdesk includes:
•
•
•
•
•
•
•

7:00 am to 12:00 am** Helpdesk via a toll free number 1-888-POLLO-IT
Single point of contact for hardware and cabling dispatch
Menu changes***
Pricing adjustments***
Full portal support
WAN troubleshooting and support
Support on all IT and POS issues

MyEpl.Net Portal Service and Support includes:

•
•

Access to standard corporate reporting
Near real time sales performance data for all stores

Professional Service includes:

•
•
•
•

Any service outside of the scoop of this Agreement will be billing at the following rates:
Helpdesk rate $60 per hour
Networking rate $120 per hour
Development rate $120 per hour

* Business hours are subject to change
** Helpdesk hours are subject to change
*** Does not include Tax changes. Customer acknowledges and agrees that the data entered by EPL IT is on behalf
of  Customer.  Customer  acknowledges  and  agrees  that  it  is  their  responsibility  to  verify  the  accuracy  of  the  data
inputted by EPL IT and also to maintain and update the data as needed. Any maintenance and/or updates Customer
wishes EPL IT to perform must be communicated to EPL IT in writing in order for EPL IT to perform the maintenance
and/or updates.

Franchise Support Options – Fee Schedule*

Service Description
Quarterly PCI Scanning
Unlimited Number of Calls for Helpdesk Support
including Credit Card Support
MyEpl.Net
Backup Internet (3G or LTE)
Network Management Fee
Mobile Device Management (Per Tablet)
WIFI Controller (2 Access Points)
Learning Management Platform

Monthly Cost per Store 1
Broadband WAN 2
Digital Menu Board 3

Kiosk Software 4
Beyond Software 5

Annual Cost*
$300**

$2,004
$600
$300
$300
$36
$135
$228

$1,188
$672

$1,920
$720

Oracle Micros POS Software Support 6

Up to $1,000

Monthly
Cost*
$25**

$167
$50
$25
$25
$3
$11.25
$19

$325.25
$99
$56

$160
$60

n/a

Platinum
Support
Option
Yes

Payable to:
EPL

Yes
Yes
Yes
Yes
Yes
Yes
Yes

Yes
Yes

Yes
Yes

n/a

EPL
EPL
EPL
EPL
EPL
EPL
EPL

EPL
EPL

EPL
EPL

EPL

NOTE: Mixed services not allowed. All service levels must be the same for all stores per Franchisee.

*All fees listed in this Fee Schedule may change depending on vendor price changes.

**The  Annual  Cost/Monthly  Cost  listed  for  Complete  Firewall  Service  and  Support  and  Quarterly  PCI
Scanning.  However,  this  fee  may  range  up  to  $20  depending  on  vendor  price  increases.  There  may  be  additional

 
 
 
charges if any remediation is required.

1 Monthly rate based on standard store configuration. Support cost for non-standard configuration subject to change,
based on actual hardware deployed.

2 BROADBAND service cost is approximate and subject to increase if 2Mx1M Broadband is not available. Services
subject to additional costs are wireless broadband, business class cable, and Fractional or full T1. These costs are
pass-through costs from the EPL approved broadband provider. The costs may actually be different than the amount
shown due to price changes by vendor.

3 Optional Digital Menu  Board  fees  are  determined  by  the  count  of  digital menu panels. Each digital menu/preview
board carries a vendor fee of $14 per panel. The costs may actually be different than the amount shown due to price
changes by vendor and depending on the number of panels used.

4  Optional  Kiosk  Software  fees  are  $160  per  month  per  restaurant  location  for  application  hosting  and  a  $400  one
time  setup  fee  per  restaurant  location.  The  costs  may  actually  be  different  than  the  amount  shown  due  to  price
changes by vendor and price tiers based on the total count of system wide installations.

5 Beyond Software fees are $60 per month per restaurant location for application hosting and support. The fees will
increase  to  $75  per  month  on  the  third  anniversary  of  the  commencement  of  the  contract  between  EPL  and
Peachworks (“Contract”); $90 per month on the fourth anniversary of the commencement of the Contract and $110
per  month  on  the  fifth  anniversary  of  the  commencement  of  the  Contract.  Peachworks  offers  inventory,  ordering,
temperature line checks, log scheduling, and reports. The costs may actually be different than the amount shown due
to price changes by vendor.

6  This  annual  fee  of  up  to  $1,000.00  is  for  Oracle  Micros  POS  Software  Support  which  is  required  to  be  able  to
receive Micros software updates.

EXHIBIT 8: GENERAL RELEASE

This  General  Release  (“General  Release”)  is  made  effective  _________________,  20__,  by  the  undersigned,
____________________________________, a _______________ (referred herein after as the “Franchisee”).

a 

of 

El 

Pollo 

Loco, 

Delaware 

corporation 

consideration 

In 
(“Franchisor”):
Inc., 
__________________________________; and other good and valuable consideration the receipt and sufficiency of
which  is  hereby  acknowledged,  Franchisee  hereby  waives,  releases,  and  forever  discharges  Franchisor,  and  all
Franchisor’s affiliates, and all the respective directors, officers, employees, attorneys, representatives and agents of
said corporations, as well as parent corporations, subsidiaries, affiliates and any other legal entities which it owns or
controls, individually or jointly, from any and all obligations, liabilities, claims, demands, actions and causes of action
in law or in equity of whatsoever kind or nature arising prior to and including the date hereof, which Franchisee now
has  or  may  hereafter  have  by  reason  of  any  act,  omission,  event,  deed  or  course  of  action  having  taken  place,  or
which should have taken place, or on account of or arising out of any claimed violation of the Franchise Agreement,
any  claim  for  breach  of  any  other  express  or  implied  agreement,  claim  for  breach  of  any  implied  violation  of  the
covenant  of  good  faith  and  fair  dealing  or  any  other  claims  which  relate  or  refer  in  any  way  to  the  relationship
between  Franchisor  and  Franchisee  which  arises  on  or  before  the  date  hereof  insofar  as  said  claims  relate  to  the
Franchise Agreement or any other agreement between Franchisee and Franchisor, any claim arising under or alleged
violation of the California Franchise Relations Act, any Federal antitrust law or State antitrust law except as prohibited
by law.

This  General  Release  extends  to  claims  arising  from  representations  made  by  the  Franchisor  in  the  Franchise
Disclosure  Document  except  as  prohibited  by  law.  Furthermore,  it  is  expressly  acknowledged  by  each  of  the
undersigned  that  any  and  all  rights  granted  under  Section  1542  of  the  California  Civil  Code  are  hereby  expressly
waived. Such statute reads as follows:

“Section 1542.
A general release does not extend to claims which the creditor does not know or suspect to exist in
his favor at the time of executing the release which if known by him must have materially affected the
settlement with the debtor.”

Releasors  voluntarily  waive  all  benefits  and  protections  of  Civil  Code  Section  1542,  and  any  comparable  law,  and
intend the release above to apply to known and unknown claims alike.

This General Release may be executed in two or more counterparts, each of which shall be deemed an original but
all  of  which  together  shall  constitute  a  single  instrument.  A  signature  on  this  General  Release  transmitted  via
facsimile or electronic mail shall be considered an original for all purposes hereunder.

IN WITNESS WHEREOF each of the parties either personally or through its duly authorized signatory, as applicable,
has executed this General Release effective as of the date(s) written below.

FRANCHISEE:

If an entity:
___________________, a ______________

By:

Name:

Title:

Date:

If an individual:
________________________, an Individual

By:

Name:

Title:

Date:

An Individual

EXHIBIT 9: CONSENT TO AND ASSIGNMENT OF FRANCHISE RIGHTS

A: To be Used for a Change of Ownership Interests in Franchisee

This  Consent  to  and  Assignment  of  Franchise  Rights  (the  "Consent  Agreement")  is  made  as  of  this  day  of
____________,  20___  by  and  between  EL  POLLO  LOCO,  INC.,  a  Delaware  corporation  (“Franchisor”),
________________________,  a  ___________  (the  "Assignor")  and  ________________________,  a  _________
(the "Assignee").

RECITALS

A. 

that  certain  Franchise  Agreement  dated
_________________________  (the  "Franchise  Agreement")  pertaining  to  the  operation  of  the  El  Pollo  Loco
restaurant located at _____________________ (the "Restaurant").

  Franchisor  and  Assignor  are  parties 

to 

B.        Assignor  desires  to  assign  all  of  his  title,  rights,  privileges  and  interests  and  obligations  under  the
Franchise Agreement to Assignee and to sell, transfer, and convey all of his title, rights, privileges, and interests to
the  Assets  of  the  Restaurant  to  Assignee,  all  in  accordance  with  the  assignment  provisions  of  the  Franchise
Agreement.

C.        The  Franchise  Agreement  requires  that  Assignor  first  obtain  written  consent  of  Franchisor  before

undertaking any assignment of the Franchise Agreement or sale of the assets of the Restaurant.

NOW, THEREFORE, in consideration of the mutual covenants contained herein, the parties agree as follows:

1.

Recitals A through C above are incorporated herein and by this reference made a part of this Consent

Agreement.

2.

Subject to the terms and conditions set forth herein, and upon the payment to Franchisor of a transfer fee
of __________________ Dollars ($____,000.00), Franchisor does hereby consent to the assignment by Assignor to
Assignee of all of Assignor's rights, privileges, interests, and obligations under the Franchise Agreement.

 
 
 
 
 
 
 
 
 
3.

Assignee shall execute the current form of Franchise Agreement (the "Current Franchise Agreement")
for  a  term  which  coincides  with  the  initial  term  of  the  Franchise  Agreement  and  for  which  there  shall  be  no  initial
franchise  fee;  and  Assignee  covenants,  warrants  and  agrees  that,  as  of  the  date  hereof,  all  of  the  obligations,
liabilities and provisions of the Current Franchise Agreement shall be fully performed and complied with by Assignee
in its capacity as "Franchisee" under the Current Franchise Agreement, including, but not limited to, payment in full of
all  obligations  to  Franchisor  and  to  third  parties  arising  from  the  existence,  operation,  or  maintenance  of  the
Restaurant.

4.

If  there  are  remodel  requirements  the  following  language  will  be  used:  “Assignee  covenants,
warrants and agree that the required reimage and/or remodel requirements, will be completed to the satisfaction of
Franchisor no later than ninety (90) days after the date of transfer of the Restaurant operation from Assignor to
Assignee ("Changeover Date"). Assignee agrees that such required reimage and/or remodel requirements will not
be considered complete until Franchisor has agreed to the final completion in writing. Should  the  required  reimage
and/or remodel of the Restaurant not be completed to Franchisor’s satisfaction, then Franchisor may terminate the
Current  Franchise  Agreement  under  Section  18,  entitled  Default  and  Termination”.  If  there  are  no  remodel
requirements the above language will be replaced with: “Franchisor acknowledges and agrees that as of the date
of this Consent Agreement there are no remodel requirements to be completed prior to the transfer of the Restaurant
from Assignor to Assignee.”

5.

Assignee acknowledges and warrants:

a.    that the Current Franchise Agreement and any related franchise disclosure documents, manuals,

lists, forms and other documents previously transmitted to Assignee have been fully read and understood;

b.        that  Assignee  is  knowledgeable  and  experienced  in  regard  to  the  operation  of  an  El  Pollo  Loco

restaurant and the Franchisor operating system;

c.        that  Assignee  agrees  to  undertake,  in  accordance  with  the  terms  of  the  Current  Franchise
Agreement, such training as Franchisor may deem appropriate in connection with the operation and maintenance of
the Restaurant;

d.    that Assignee is fully aware that the initial term of the Current Franchise Agreement will expire on
_____________________, and has no renewal option periods and the Current Franchise Agreement does not grant
Assignee any territorial right or licenses, exclusive or otherwise; and

e.        that  as  of  the  date  of  this  Consent  Agreement,  the  ownership  interest  in  Assignee  is  divided  as

follows:

(i) ____________ - ____%

(ii) ____________ - ____%

f.        that  Assignee  has  conducted  an  independent  study  of  the  Restaurant,  including  consideration  of
any sales, profits or earnings figures that may have been made available to Assignee by or on behalf of Assignor, and
in  entering  into  this  Agreement,  Assignee  relies  solely  upon  such  independent  knowledge  and  in  no  respect  has
Assignee relied upon any representation, statement, endorsement or promise, either oral or written, by or on behalf of
Franchisor.

6.

Release.

a.    In consideration of the consent by Franchisor granted herein, Assignor and Assignee (collectively
“Releasors”) do each hereby waive, release and forever discharge Franchisor, and all of Franchisor's affiliates, and
all the respective directors, officers, employees, attorneys, representatives, and agents of said corporations, as well
as  parent  corporations,  subsidiaries,  affiliates  and  any  other  legal  entities  which  it  owns  or  controls,  individually  or
jointly,  from  any  and  all  obligations,  liabilities,  claims,  demands,  actions  and  causes  of  action  in  law  or  in  equity  of
whatsoever kind or nature arising prior to and including the date hereof, which Releasors now have or may hereafter
have by reason of any act, omission, event, deed or course of action having taken place, or which should have taken
place, or on account of or arising out of any claimed violation of the Franchise Agreement or the Current Franchise
Agreement, any claim for breach of any other express or implied agreement, claim for breach of any implied violation
of the covenant of good faith and fair dealing or any other claims which relate or refer in any way to the relationship
between Franchisor and Assignee or Franchisor and Assignor or Assignor and Assignee which arises on or before

the date hereof insofar as said claims relate to the Franchise Agreement, or the Current Franchise Agreement, or the
Consent  Agreement,  and  to  the  extent  allowed  by  law,  any  claim  for  breach  of  the  assignment  of  Assignor's  title,
rights,  privileges,  interests,  and  obligations  under  the  Franchise  Agreement  as  contemplated  in  this  Consent
Agreement, or any other agreement between Releasors (or any of them) and Franchisor, any claim arising under or
alleged violation of the California Franchise Relations Act, any Federal antitrust law or State antitrust law except as
prohibited by law.

b.    This general release does not extend to claims arising from representations made by the Franchisor
in  the Franchise Disclosure  Document. Furthermore, it is  expressly  acknowledged  by  each  of  the  undersigned  that
any and all rights granted under Section 1542 of the California Civil Code are hereby expressly waived. Such statute
reads as follows:

"A general release does not extend to claims which the creditor does not know or suspect to exist in
his favor at the time of executing the release, which if known by him must have materially affected his
settlement with the debtor."

c.        Releasors  voluntarily  waive  all  benefits  and  protections  of  Civil  Code  Section  1542,  and  any

comparable law, and intend the release above to apply to known and unknown claims alike.

7.

Assignor and Assignee understand and agree that Assignor shall remain secondarily liable in the event of
any  default  by  the  Assignee  under  the  Current  Franchise  Agreement,  and  that  by  entering  into  this  Consent
Agreement, Assignor and Assignee fully and unconditionally guarantee the Assignee's performance and compliance
in all respects with the obligations, liabilities and provisions thereunder; provided, however, that this guarantee shall
not extend to any default of non-compliance with the obligations, liabilities, and provisions of the Current Franchise
Agreement by Assignee during any extension of the initial term of the Current Franchise Agreement. Assignor further
understands  and  agrees  that,  to  the  extent  principals  of  Assignor  have  personally  guaranteed  the  performance  of
Assignor under the terms and conditions of the Current Franchise Agreement, such personal guarantee shall NOT be
modified by this Consent Agreement and any such guarantors shall not be released from liability of any kind or nature
by the terms of this Consent Agreement. Franchisor agrees that a copy of any notice of default given to Assignee by
Franchisor shall also be concurrently given to Assignor.

8.

Unless Assignee is currently the franchisee of another El Pollo Loco restaurant, Assignor shall train, at
Assignor's expense, Assignee and up to two (2) of Assignee's managers prior to Assignee's takeover of the operation
of the Restaurant from Assignor, in order to train Assignee in the Franchisor operating system. Such training must be
completed  to  Franchisor's  satisfaction  prior  to  turning  over  the  running  of  the  Restaurant  to  Assignee.  In  the  event
that  Assignor  wishes  Franchisor  to  train  Assignee's  personnel  in  the  Franchisor  operating  system,  Assignor  shall
reimburse Franchisor for the cost of such training.

9.

Assignor  agrees  to  grant  permission  to  Assignee  for  Assignee  to  access  the  historical  sales  and
transactional  information  belonging  to  Assignor  as  stored  in  Assignor’s  Point  of  Sale  system  (“POS”)  prior  to  the
effective date of this Consent Agreement.

10.

Franchisor's  consent  to  the  assignment  of  Assignor's  rights  and  obligations  under  the  Franchise
Agreement  and  the  assets  of  the  Restaurant  is  expressly  contingent  upon  Assignor  paying  and  discharging  all
obligations incurred in Assignor's operation of the Restaurant prior to the Changeover Date including, but not limited
to, the following:

a.    Any unpaid amounts owed Franchisor under monthly franchise billing statements for periods up to
the Changeover Date which, through __________, 20___ are estimated to be _____________Dollars ($_____) and
shall be payable through escrow, by cashier's check or by direct debit (ACH) to Franchisor. If the Changeover Date is
not ______________, 20___, the estimate should be adjusted by _____________Dollars ($_____) per diem;

b.        Taxes  due  or  accrued  and  unpaid,  including,  but  not  limited  to,  the  sales  tax  on  food  and

consumables sold in the Restaurant;

c.    Any federal, state or local taxes required to be withheld from employees' salaries and wages; and

d.    Any and all amounts due suppliers and vendors to the Restaurant.

11. Within thirty (30) days following the Changeover Date, Franchisor shall prepare and submit to Assignor
a final accounting for sums due together with a check for any sums due Assignor or a statement for any sums due
Franchisor. In connection with such accounting, Franchisor shall have the right, without the obligation, to pay any bills
incurred by Assignor prior to the Changeover Date and to add amounts so paid to amounts charged Assignor in such
accounting. As of the Changeover Date, Assignee shall assume total responsibility for the operation of, and shall be
solely responsible for, any obligations incurred in connection with the Restaurant prior to the Changeover Date in the
event that such obligations have not been satisfied by Assignor.

12.

This Consent Agreement shall inure to the benefit of the successors and assigns of Franchisor, and to
any and all of its affiliates, parents and subsidiaries, and shall be binding upon the heirs, representatives, successors
and assigns of Assignor and Assignee.

13.

Except as modified herein, all the terms and conditions of the Franchise Agreement shall be unaffected

and remain in full force and effect.

14.

The parties hereto acknowledge that they have read and fully understand the provisions of this Consent

Agreement and that said provisions constitute a complete and exclusive expression of its terms and conditions.

15.

The parties executing this Consent Agreement on behalf of Assignee or Assignor hereby represent and
warrant that: (a) they have the full power, right and authority to enter into and execute this Consent Agreement; and
(b) those persons whose signatures are hereinafter evidenced on this Consent Agreement on behalf of Assignee or
Assignors are duly authorized signatories of Assignee or Assignors, fully empowered to commit and bind Assignee or
Assignors to those certain terms, covenants and conditions set forth herein.

16.

If either party is a business organization, the party is duly organized and qualified to do business in the

state and any other applicable jurisdiction within which the Restaurant is located.

17.

This  Consent  Agreement  shall  not  be  binding  upon  Franchisor  unless  and  until  it  shall  have  been

accepted and signed by an authorized officer of Franchisor.

18.

This Consent Agreement may be executed in one or more counterparts, each of which will constitute an
original,  but  all  of  which  together  will  constitute  but  a  single  document.  It  shall  not  be  necessary  for  Franchisor,
Assignors and Assignee to execute the same counterpart(s) of this Consent Agreement for this Consent Agreement
to  become  effective.  A  signature  on  this  Consent  Agreement  transmitted  via  facsimile  or  electronic  mail  shall  be
considered an original for all purposes hereunder.

IN WITNESS WHEREOF, the parties hereto have executed this Consent Agreement as of the date(s) written below.

FRANCHISOR:

ASSIGNOR:

EL POLLO LOCO, INC., a Delaware Corporation

____________________________, an individual

By:

Name:

Title:

Date:

An individual

By:

Name:

Title:

Date:

ASSIGNEE:

__________________, a ____________

By:

Name:

Title:

Date:

B: To be Used for an Entity Change by Franchisee

This  Consent  to  and  Assignment  of  Franchise  Rights  (the  "Consent  Agreement")  is  made  as  of  this  day  of
____________,  20___  by  and  between  EL  POLLO  LOCO,  INC.,  a  Delaware  corporation  (“Franchisor”),
________________________,  a  _________  (the  "Assignor")  and  ___________________,  a  ________  (the
"Assignee").

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RECITALS

A. 

that  certain  Franchise  Agreement  dated
_________________________  (the  "Franchise  Agreement")  pertaining  to  the  operation  of  the  El  Pollo  Loco
restaurant located at _____________________ (the "Restaurant").

  Franchisor  and  Assignor  are  parties 

to 

B.        Assignor  desires  to  assign  all  of  his  title,  rights,  privileges  and  interests  and  obligations  under  the
Franchise Agreement to Assignee and to sell, transfer, and convey all of his title, rights, privileges, and interests to
the  Assets  of  the  Restaurant  to  Assignee,  all  in  accordance  with  the  assignment  provisions  of  the  Franchise
Agreement.

C.        The  Franchise  Agreement  requires  that  Assignor  first  obtain  written  consent  of  Franchisor  before

undertaking any assignment of the Franchise Agreement or sale of the assets of the Restaurant.

NOW, THEREFORE, in consideration of the mutual covenants contained herein, the parties agree as follows:

1.

Recitals A through C above are incorporated herein and by this reference made a part of this Consent

Agreement.

2.

Subject to the terms and conditions set forth herein, and upon the payment to Franchisor of an entity fee
of Five Hundred Dollars ($500.00) [delete fee reference if this is Franchisee’s initial entity transfer], Franchisor
does hereby consent to the assignment by Assignor to Assignee of all of Assignor's rights, privileges, interests, and
obligations under the Franchise Agreement.

3.

Assignee covenants, warrants and agrees that, as of the date hereof, all of the obligations, liabilities and
provisions  of  the  Franchise  Agreement  shall  be  fully  performed  and  complied  with  by  Assignee  in  its  capacity  as
"Franchisee"  under  the  Franchise  Agreement,  including,  but  not  limited  to,  payment  in  full  of  all  obligations  to
Franchisor and to third parties arising from the existence, operation, or maintenance of the Restaurant.

4.

Assignee acknowledges and warrants:

a.        that  the  Franchise  Agreement  and  any  related  franchise  disclosure  documents,  manuals,  lists,

forms and other documents previously transmitted to Assignee have been fully read and understood;

b.        that  Assignee  is  knowledgeable  and  experienced  in  regard  to  the  operation  of  an  El  Pollo  Loco

restaurant and the Franchisor operating system;

c.        that  Assignee  is  fully  aware  that  the  initial  term  of  the  Franchise  Agreement  will  expire  on
_____________________,  and  has  no  renewal  option  periods  and  the  Franchise  Agreement  does  not  grant
Assignee any territorial right or licenses, exclusive or otherwise; and

d.        that  as  of  the  date  of  this  Consent  Agreement,  the  ownership  interest  in  Assignee  is  divided  as

follows:

(i) ____________ - ____%

(ii) ____________ - ____%

5.

Release.

a.    In consideration of the consent by Franchisor granted herein, Assignor and Assignee (collectively
“Releasors”) do each hereby waive, release and forever discharge Franchisor, and all of Franchisor's affiliates, and
all the respective directors, officers, employees, attorneys, representatives, and agents of said corporations, as well
as  parent  corporations,  subsidiaries,  affiliates  and  any  other  legal  entities  which  it  owns  or  controls,  individually  or
jointly,  from  any  and  all  obligations,  liabilities,  claims,  demands,  actions  and  causes  of  action  in  law  or  in  equity  of
whatsoever kind or nature arising prior to and including the date hereof, which Releasors now have or may hereafter
have by reason of any act, omission, event, deed or course of action having taken place, or which should have taken
place, or on account of or arising out of any claimed violation of the Franchise Agreement or the Current Franchise
Agreement, any claim for breach of any other express or implied agreement, claim for breach of any implied violation

 
 
of the covenant of good faith and fair dealing or any other claims which relate or refer in any way to the relationship
between Franchisor and Assignee or Franchisor and Assignor or Assignor and Assignee which arises on or before
the date hereof insofar as said claims relate to the Franchise Agreement, or the Current Franchise Agreement, or the
Consent  Agreement,  and  to  the  extent  allowed  by  law,  any  claim  for  breach  of  the  assignment  of  Assignor's  title,
rights,  privileges,  interests,  and  obligations  under  the  Franchise  Agreement  as  contemplated  in  this  Consent
Agreement, or any other agreement between Releasors (or any of them) and Franchisor, any claim arising under or
alleged violation of the California Franchise Relations Act, any Federal antitrust law or State antitrust law except as
prohibited by law.

b.    This general release does not extend to claims arising from representations made by the Franchisor
in  the Franchise Disclosure  Document. Furthermore, it is  expressly  acknowledged  by  each  of  the  undersigned  that
any and all rights granted under Section 1542 of the California Civil Code are hereby expressly waived. Such statute
reads as follows:

"A general release does not extend to claims which the creditor does not know or suspect to exist in
his favor at the time of executing the release, which if known by him must have materially affected his
settlement with the debtor."

c.        Releasors  voluntarily  waive  all  benefits  and  protections  of  Civil  Code  Section  1542,  and  any

comparable law, and intend the release above to apply to known and unknown claims alike.

6.

Assignor and Assignee understand and agree that Assignor shall remain secondarily liable in the event of
any  default  by  the  Assignee  under  the  Franchise  Agreement,  and  that  by  entering  into  this  Consent  Agreement,
Assignor  and  Assignee  fully  and  unconditionally  guarantee  the  Assignee's  performance  and  compliance  in  all
respects  with  the  obligations,  liabilities  and  provisions  thereunder;  provided,  however,  that  this  guarantee  shall  not
extend to any default of non-compliance with the obligations, liabilities, and provisions of the Franchise Agreement by
Assignee  during  any  extension  of  the  initial  term  of  the  Franchise  Agreement.  Assignor  further  understands  and
agrees that, to the extent principals of Assignor have personally guaranteed the performance of Assignor under the
terms and conditions of the Franchise Agreement, such personal guarantee shall NOT be modified by this Consent
Agreement  and  any  such  guarantors  shall  not  be  released  from  liability  of  any  kind  or  nature  by  the  terms  of  this
Consent Agreement. Franchisor agrees that a copy of any notice of default given to Assignee by Franchisor shall also
be concurrently given to Assignor.

7.

Assignor  agrees  to  grant  permission  to  Assignee  for  Assignee  to  access  the  historical  sales  and
transactional  information  belonging  to  Assignor  as  stored  in  Assignor’s  Point  of  Sale  system  (“POS”)  prior  to  the
effective date of this Consent Agreement.

8.

Franchisor's  consent  to  the  assignment  of  Assignor's  rights  and  obligations  under  the  Franchise
Agreement  and  the  assets  of  the  Restaurant  to  Assignee  is  expressly  contingent  upon:  (i)  Assignor  paying  and
discharging  all  obligations  incurred  in  Assignor's  operation  of  the  Restaurant  prior  to  the  date  of  transfer  of  the
Restaurant  operation  from  Assignor  to  Assignee  (“Changeover  Date”);  and  (ii)  Assignee  shall  assume  total
responsibility for the operation of, and shall be solely responsible for, any obligations incurred in connection with the
Restaurant prior to the Changeover Date in the event that such obligations have not been satisfied by Assignor.

9.

This  Consent  Agreement  shall  inure  to  the  benefit  of  the  successors  and  assigns  of  Franchisor,  and  to
any and all of its affiliates, parents and subsidiaries, and shall be binding upon the heirs, representatives, successors
and assigns of Assignor and Assignee.

10.

Except as modified herein, all the terms and conditions of the Franchise Agreement shall be unaffected

and remain in full force and effect.

11.

The parties hereto acknowledge that they have read and fully understand the provisions of this Consent

Agreement and that said provisions constitute a complete and exclusive expression of its terms and conditions.

12.

The parties executing this Consent Agreement on behalf of Assignee or Assignor hereby represent and
warrant that: (a) they have the full power, right and authority to enter into and execute this Consent Agreement; and
(b) those persons whose signatures are hereinafter evidenced on this Consent Agreement on behalf of Assignee or
Assignors are duly authorized signatories of Assignee or Assignors, fully empowered to commit and bind Assignee or
Assignors to those certain terms, covenants and conditions set forth herein.

13.

If either party is a business organization, the party is duly organized and qualified to do business in the

state and any other applicable jurisdiction within which the Restaurant is located.

14.

This  Consent  Agreement  shall  not  be  binding  upon  Franchisor  unless  and  until  it  shall  have  been

accepted and signed by authorized officers of Franchisor.

15.

This Consent Agreement may be executed in one or more counterparts, each of which will constitute an
original,  but  all  of  which  together  will  constitute  but  a  single  document.  It  shall  not  be  necessary  for  Franchisor,
Assignors and Assignee to execute the same counterpart(s) of this Consent Agreement for this Consent Agreement
to  become  effective.  A  signature  on  this  Consent  Agreement  transmitted  via  facsimile  or  electronic  mail  shall  be
considered an original for all purposes hereunder.

IN WITNESS WHEREOF, the parties hereto have executed this Consent Agreement as of the date(s) written below.

FRANCHISOR:

ASSIGNOR:

EL POLLO LOCO, INC., a Delaware Corporation

____________________________, an individual

By:

Name:

Title:

Date:

An individual

By:

Name:

Title:

Date:

ASSIGNEE:

__________________, a ____________

By:

Name:

Title:

Date:

EXHIBIT 10: AMENDMENT TO FRANCHISE AGREEMENT TO APPLY DEVELOPMENT FEE

This  Amendment  to  the  Franchise  Agreement  to  Apply  Development  Fee  (“Amendment”) 
is  made  on
_____________,____  by  and  among  EL  POLLO  LOCO,  INC.,  a  Delaware  corporation  (“Franchisor”)  and
____________________, an individual ("Franchisee").

RECITALS:

Franchisor  and  Franchisee  are  simultaneously  entering  into  this  Amendment  to  Franchise  Agreement  and  a
located  at

for  an  El  Pollo  Loco® 

(“Franchise  Agreement”) 

A.
Franchise  Agreement 
_____________________________ (“Restaurant”).

restaurant 

B.
Franchisor and _________________________ (“Developer”) entered into Franchise Development Agreement
(#_____________) dated ______________ (“Development Agreement”) for the Territory as set forth on Exhibit A
to be developed as set forth in the Development Schedule as set forth on Exhibit B of the Development Agreement.
Developer is an affiliate of Franchisee.

Franchisor  and  Franchisee  wish  to  modify  the  terms  of  the  Franchise  Agreement  as  described  in  this

C.
Amendment.

AGREEMENT:

NOW, THEREFORE, in consideration of the mutual promises and covenants of the parties hereto, the parties

agree as follows:

Recitals.  Franchisor  and  Franchisee  acknowledge  and  agree  with  all  of  the  above  listed  recitals  which  are

1.
incorporated herein to this Amendment.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
2.
Application of Development Fee towards the Initial Franchise Fee for the Franchise Agreement for the
Restaurant. Per the Development Agreement, Developer paid Twenty Thousand Dollars ($20,000) in Development
Fees to be applied towards the Initial Franchise Fee for the Franchise Agreement for the Restaurant developed under
the  Development  Agreement.  This  payment  has  been  applied  to  the  Initial  Franchise  Fee  for  this  Franchise
Agreement. Franchisee will pay the balance of _______ Thousand Dollars ($_________) in full within thirty (30) days
of delivery of execution copies of this Agreement to Franchisee.

3.
Entire  Agreement.  This  Amendment  and  the  Franchise  Agreement  embody  the  entire  understanding  between
Franchisor and Franchisee with respect to the modifications set forth above, and can be changed only by a writing signed
by Franchisor and Franchisee. Except as modified herein, all the terms and conditions of the Franchise Agreement shall
be unaffected and remain in full force and effect. In the event of any inconsistency between the terms of this Amendment
and the terms of the Franchise Agreement, the terms of this Amendment shall control.

4. Miscellaneous. All capitalized terms not otherwise defined in this Amendment shall have the meanings given
them in the Franchise Agreement. Titles and captions are for convenience only and shall not constitute a portion of
this  Amendment.  The  parties  hereto  acknowledge  that  they  have  read  and  fully  understand  the  provisions  of  this
Amendment and that said provisions constitute a complete and exclusive expression of its terms and conditions. The
parties  executing  this  Amendment  on  behalf  of  Franchisor  and  Franchisee  are  duly  authorized  to  do  so.  This
Amendment  shall  not  be  binding  upon  Franchisor  unless  and  until  it  shall  have  been  accepted  and  signed  by  an
authorized officer of Franchisor. This Amendment may be executed in one or more counterparts, each of which will
constitute an original, but all of which together will constitute but a single document. A signature on this Amendment
transmitted via facsimile or electronic mail shall be considered an original for all purposes hereunder.

IN  WITNESS  WHEREOF,  this  Amendment  to  the  Franchise  Agreement  has  been  executed  by  the  parties

hereto as of the dates set forth below.

FRANCHISOR:

FRANCHISEE:

EL POLLO LOCO, INC., a Delaware Corporation

____________________________, an individual

By:

Name:

Title:

Date:

By:

Name:

Title:

Date:

An individual

EXHIBIT 11: AMENDMENT TO SUCCESSOR FRANCHISE AGREEMENT

This Amendment to the Successor Franchise Agreement (“Amendment”) is made on _____________,____ by and
among EL POLLO LOCO, INC., a Delaware corporation (“Franchisor”) and ____________________, an individual
("Franchisee").

RECITALS:

A.
Franchisor  and  Franchisee  are  simultaneously  entering  into  this  Amendment  to  Successor  Franchise
Agreement  and  a  Successor  Franchise  Agreement  (“Successor  Franchise  Agreement”)  for  an  El  Pollo  Loco®
restaurant located at _____________________________ (“Restaurant”).

Franchisor  and  _________________________  entered 

B.
that  certain  Franchise  Agreement  dated
________________,____  (“Original  Franchise  Agreement”).  The  Original  Franchise  Agreement  will  expire  on
________________,____.

into 

C.
Franchisee and ______________ (“Landlord”), entered into that certain Lease dated ________________,____
(“Lease”). The Lease expires on ________________,____ and has ______ option(s) to extend the term of the Lease
for a period of ____ years (each).

Per the terms of the Original Franchise Agreement, Franchisee has requested a new El Pollo Loco® franchise

D.
agreement for a term of ________(___) years for the Restaurant (“Successor Franchise Agreement”).

Franchisor and Franchisee wish to modify the terms of the Successor Franchise Agreement as described in this

E.
Amendment.

 
 
 
 
 
 
 
 
 
 
 
 
 
    
The effectiveness of the Successor Franchise Agreement and this Amendment are contingent upon Franchisee

F.
being in good standing as of the date first written above.

AGREEMENT:

NOW, THEREFORE, in consideration of the mutual promises and covenants of the parties hereto, the parties

agree as follows:

Recitals. Franchisor  and  Franchisee  acknowledges  and  agrees  with  all  of  the  above  listed  recitals  which  are

1.
incorporated herein to this Amendment.

2.
Commencement  Date  and  Expiration  Date  of  Successor  Franchise  Agreement.  Paragraph  3.1  of  the
Successor  Franchise  Agreement  is  hereby  deleted  in  it’s  entirely  and  replaced  with  the  following:  “The  term  of  this
Successor  Franchise  Agreement  shall  commence  on  ________________,____  and  shall  expire  on
________________,____ (“Term”), unless sooner terminated as provided herein. Should Franchisee lease the site of
the Restaurant, the lease or sublease must be for a term which with renewal options is not less than the Term of the
Successor  Franchise  Agreement,  and  contain  the  following  terms  and  conditions  set  forth  below  and  in  a  form
approved by Franchisor:

(a)

(b)

(c)

The tenant entity on the lease must match the franchise entity on the successor franchise agreement;
and
The  term  (with  renewal  options)  of  the  lease  must  match  at  least  the  initial  term  of  the  successor
franchise agreement; and
The landlord consents to your use of the premises as an El Pollo Loco® restaurant which will be open
during the required days and hours set out in the Operations Manual.

Should Franchisee be unable to lease the site of the Restaurant for a term equal to the Term, then as our sole
and absolute right to determine, the Term of the Successor Franchise Agreement may be reduced to match the term
of the lease or sublease and the renewal franchise fee will be appropriately pro-rated. Upon the expiration or earlier
termination  of  this  Successor  Franchise  Agreement,  Franchisee  shall  have  no  right  or  option  to  extend  the  term  of
this Successor Franchise Agreement.”

Amendment  (Site  Development, 

3.
Improvements,  Fixtures  and  Equipment,  and  Grand  Opening
Advertising). Sections 4.1, 5.8 and 8.8 of the Successor Franchise Agreement are hereby deleted in their entirety;
provided however, that Sections 4.1, 5.8 and 8.8 shall be reinstated in the event that Franchisor grants Franchisee
the  right  to  relocate  the  Restaurant  under  Section  23.17.a,  23.17.b  and  23.17.c  of  the  Successor  Franchise
Agreement.

Successor  Franchise  Fee.  The  first  sentence  of  Section  6.1.a  of  the  Successor  Franchise  Agreement  is
4.
hereby deleted and replaced with the following: “Per the renewal fee described in the Original Franchise Agreement,
Franchisee  will  pay  in  full  a  renewal  franchise  fee  of  ___________________Dollars  ($__________)  (“Renewal
Franchise Fee”). The  Renewal  Franchise  Fee  will  be  paid  within  thirty  (30)  days  of  delivery  of  execution  copies  of
this  Amendment  and  Successor  Franchise  Agreement  to  Franchisee;  provided,  however,  if  the  Restaurant  is  a
Turnkey  Restaurant  the  Renewal  Franchise  Fee  shall  be  payable  upon  execution  of  this  Successor  Franchise
Agreement.”

5.
Restaurant  Remodel.  The  following  language  will  be  added  to  Section  12.3  of  the  Successor  Franchise
Agreement  regarding  remodeling  the  Restaurant:  Notwithstanding  the  above,  Franchisee  covenants,  warrants  and
agrees  that  the  required  remodel  requirements  will  be  completed  to  the  satisfaction  of  Franchisor  no  later  than
________________,____.  Franchisee  agrees  that  such  required  remodel  requirements  will  not  be  considered
complete until Franchisor has agreed to the final completion in writing. Should the required remodel of the Restaurant
not  be  completed  to  Franchisor’s  satisfaction,  then  Franchisor  may  terminate  the  Successor  Franchise  Agreement
under Section 18, entitled Default and Termination.

6.
Rights to a Successor Franchise. Section 20 of the Successor  Franchise  Agreement  is  hereby  deleted  and
replaced with the following: “Franchise shall have no right or option to extend the Successor Term of this Successor
Franchise  Agreement.  In  order  for  Franchisee  to  operate  beyond  the  Successor  Term,  Franchisee  must  meet  the
then-current  criteria  to  become  an  El  Pollo  Loco  franchisee  and  enter  into  a  then  current  form  of  Franchise
Agreement and ancillary agreements, the terms of which may vary substantially from this Amendment and Successor
Franchise Agreement.”

7.
Entire  Agreement.  This  Amendment  and  the  Successor  Franchise  Agreement  embodies  the  entire
understanding  between  Franchisor  and  Franchisee  with  respect  to  the  modifications  set  forth  above,  and  can  be
changed  only  by  a  writing  signed  by  Franchisor  and  Franchisee.  Except  as  modified  herein,  all  the  terms  and
conditions of the Successor Franchise Agreement shall be unaffected and remain in full force and effect. In the event
of  any  inconsistency  between  the  terms  of  this  Amendment  and  the  terms  of  the  Successor  Franchise  Agreement,
the terms of this Amendment shall control.

8. Miscellaneous. All capitalized terms not otherwise defined in this Amendment shall have the meanings given
them in the Successor Franchise Agreement. Titles and captions are for convenience only and shall not constitute a
portion of this Amendment. The parties hereto acknowledge that they have read and fully understand the provisions
of  this  Amendment  and  that  said  provisions  constitute  a  complete  and  exclusive  expression  of  its  terms  and
conditions. The parties executing this Amendment on behalf of Franchisor and Franchisee are duly authorized to do
so. This Amendment shall not be binding upon Franchisor unless and until it shall have been accepted and signed by
an authorized officer of Franchisor. This Amendment may be executed in one or more counterparts, each of which
will  constitute  an  original,  but  all  of  which  together  will  constitute  but  a  single  document.  A  signature  on  this
Amendment transmitted via facsimile or electronic mail shall be considered an original for all purposes hereunder.

IN WITNESS WHEREOF, this Amendment to the Successor Franchise Agreement has been executed by the

parties hereto as of the date(s) set forth below.

FRANCHISOR:

FRANCHISEE:

EL POLLO LOCO, INC., a Delaware Corporation

____________________________, an individual

By:

Name:

Title:

Date:

By:

Name:

Title:

Date:

An individual

EXHIBIT 12: REMODEL SCHEDULE PARTICIPATION AGREEMENT

THIS REMODEL SCHEDULE PARTICIPATION AGREEMENT (“Remodel Agreement”) is made and entered into as
of _____________,______ (“Effective Date”), by and between EL POLLO LOCO, INC., a Delaware corporation (the
“Franchisor”) and ____________________________, a _____________ (“Franchisee”).

RECITALS:

A.

Franchisor and Franchisee are parties to the El Pollo Loco Franchise Agreements referenced
hereto  and  incorporated  herein  as  Exhibit  A.  The  Franchise  Agreements  listed  on  Exhibit  A  shall  be  referred  to
collectively herein as “Franchise Agreements” and individually as “Franchise Agreement”. The Restaurants listed
on Exhibit A shall be referred to collectively herein as “Restaurants” and individually as “Restaurant”.

B.

Franchisor and Franchisee desire to set forth the terms and conditions whereby Franchisee will

remodel all the Restaurants as set forth herein.

NOW,  THEREFORE,  in  consideration  of  the  mutual  covenants  and  agreements  contained  in  this  Remodel

Agreement the parties agree as follows:

AGREEMENT:

1.

The  Recitals  listed  above  are  incorporated  herein  and  by  this  reference  made  a  part  of  this

Remodel Agreement.

2.

Franchisee, at Franchisee's expense, will remodel all Restaurants as described in Exhibit A to
then current El Pollo Loco® standards, format, design and image, as designated pursuant to plans and specifications
provided  by  Franchisor  (“Remodel  Requirements”).  All  signs  to  be  used  in  connection  with  the  Restaurant,  both
exterior and interior, must conform to Franchisor's sign criteria as to type, color, design and location and be approved
in writing by Franchisor prior to installation or display.

3.

Franchisee  covenants,  warrants  and  agrees  that  the  required  Remodel  Requirements  will  be
completed  in  each  of  Franchisee’s  Restaurants,  to  the  satisfaction  of  Franchisor  no  later  than  the  dates  listed  on
Exhibit  A.  Franchisee  agrees  that  such  required  Remodel  Requirements  will  not  be  considered  complete  until
Franchisor has agreed to the final completion in writing. Should the required Remodel Requirements of any or all
Restaurants  not  be  completed  to  Franchisor’s  satisfaction,  then  such  violation  of  this  Remodel  Agreement
and/or  the  Franchise  Agreements  is  deemed  to  be  a  material  breach  and  Franchisor  hereby  reserves  all
rights  and  remedies  available  under  this  Remodel  Agreement  and  the  operative  Franchise  Agreement.  In
addition,  Franchisee  acknowledges  and  agrees  that  Franchisor  will  inspect  the  first  Restaurant  to  ensure  the
Remodel  Requirements  have  been  complied  with.  Only  after  Franchisor’s  approval  of  the  remodel  of  the  first
Restaurant, then Franchisee may remodel any or all of the remaining Restaurants, more than one at a time. Should
Franchisor  not  approve  the  remodel  of  the  first  Restaurant,  Franchisee  will  have  to  finalize  the  remodel  of  that

 
 
 
 
 
 
 
 
 
 
 
 
 
Restaurant and seek Franchisor’s re-inspection and approval of that Restaurant before continuing onto the remodel
of any or all of the remaining Restaurants.

4.

In consideration of Franchisor’s consent to Franchisee’s participation in the remodel deadlines
granted herein, Franchisee hereby waives, releases and forever discharges Franchisor, all Franchisor’s affiliates, and
all  the  respective  directors,  officers,  employees,  attorneys,  representatives,  and  agents  of  said  entities,  from  all
obligations,  liabilities,  claims,  actions  and  causes  of  action  of  whatever  kind  or  nature,  including,  but  not  limited  to,
any  alleged  violation  of  the  California  Franchise  Relations  Act  or  any  other  similar  state  statute  or  regulation,  any
Federal  or  State  antitrust  claims,  any  claimed  violation  of  the  Franchise  Agreement,  any  claim  for  breach  of  any
implied covenant of good faith and fair dealing or any other claims which relate or refer in any way to the relationship
between Franchisor and Franchisee which arose on or before the date hereof, it is understood and agreed that any
and  all  rights  granted  to  Franchisee  under  Section  1542  of  the  California  Civil  Code  are  hereby  expressly  waived.
Such statute reads as follows:

"A general release does not extend to claims which the creditor does not know or suspect to exist in his favor
at the time of executing the release, which if known by him must have materially affected his settlement with
the debtor."

5.

Franchisee  hereby  agrees  to  indemnify  and  defend  the  Franchisor,  its  officers,  directors,
shareholders,  employees,  agents  and  affiliates  against  and  hold  them  harmless  from  any  loss,  liability,  claim,
damage, award, settlement, cost or expense (including reasonable legal fees and expenses) incurred in connection
with  any  suit  or  claim  of  action  brought  against  any  such  indemnified  party  in  connection  with  Franchisee’s
participation  in  the  remodel and/or  the  services  or  goods  provided  by  Franchisor  in  connection  therewith,  including
but not limited to, any breach by Franchisee of this Remodel Agreement.

6.

This  Remodel  Agreement  embodies  the  entire  understanding  between  Franchisor  and
Franchisee with respect to the matters set forth herein, and can be changed only by a writing signed by Franchisor
and Franchisee. Except as otherwise modified by this Remodel Agreement, the terms and conditions of the Franchise
Agreements shall remain unchanged and in full force and effect. In the event of any inconsistency between the terms
of this Remodel Agreement and the terms of the Franchise Agreement, the terms of this Remodel Agreement shall
control.

7.

The  parties  executing  this  Remodel  Agreement  on  behalf  of  Franchisor  and  Franchisee  are
duly authorized to do so. This Remodel Agreement shall not be binding upon Franchisor unless and until it shall have
been  accepted  and  signed  by  an  authorized  officer  of  Franchisor.  This  Remodel  Agreement  may  be  executed  in
counterparts, each of which shall be deemed an original, but all of which together shall constitute one and the same
Remodel  Agreement.  A  signature  on  this  Remodel  Agreement  transmitted  via  facsimile  or  electronic  mail  shall  be
considered an original for all purposes hereunder.

8.

Should any party hereto institute any action or proceeding at law or in equity, or in connection
with an arbitration, to enforce any provision of this Remodel Agreement, including an action for declaratory relief, or
for damages by reason of an alleged breach of any provision of this Remodel Agreement, or otherwise in connection
with this Remodel Agreement, or any provision thereof, the prevailing party shall be entitled to recover from the losing
party or parties reasonable attorneys' fees and costs for services rendered to the prevailing party in such action or
proceeding or in connection with the collection of any judgment thereby obtained.

9.

Nothing  contained  herein  shall  be  construed  so  as  to  require  the  commission  of  any  act
contrary to law, and wherever there is any conflict between any provisions contained herein and any present or future
statute,  law,  ordinance  or  regulation,  the  latter  shall  prevail;  but  the  provision  of  this  Remodel  Agreement  which  is
affected shall be curtailed and limited only to the extent necessary to bring it within the requirements of the law. In the
event any portion of this Remodel Agreement is determined to be invalid or unenforceable, the balance of all other
provisions shall remain in full force and effect.

10.

All  of  the  terms  and  provisions  contained  herein  shall  inure  to  the  benefit  of  and  shall  be

binding upon the parties hereto and their respective heirs, legal representatives, successors and assigns.

IN WITNESS WHEREOF, Franchisor and Franchisee have duly executed this Remodel Agreement as of the

date(s) set forth below.

FRANCHISOR:

FRANCHISEE:

EL POLLO LOCO, INC., a Delaware Corporation

____________________________, a _________________

By:

Name:

Title:

Date:

By:

Name:

Title:

Date:

  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EXHIBIT A
FRANCHISE AGREEMENTS & REMODEL DEADLINES

Location No

Address

City

State

ZIP

Agreement Signed

Next Remodel Due

EL POLLO LOCO® FRANCHISE AGREEMENT SCHEDULE 1: PROTECTED AREA

The Protected Area for Franchisee’s El Pollo Loco® Restaurant shall be the lesser of (a) two (2) miles radiating
out from the Franchisee’s El Pollo Loco® Restaurant; or (b) the area within a ring radiating out from Franchisee’s El
Pollo  Loco®  Restaurant  which  contains  at  least  30,000  people,  measured  by  the  most  recent  U.S.  Government
Bureau of Census survey as of:

a.        (for  a  newly  franchised  El  Pollo  Loco®  Restaurant)  the  date  Franchisee’s  El  Pollo  Loco®  Restaurant  is

approved by Franchisor’s Real Estate Site Approval Committee (“RESAC”);

b.        (for  a  Successor  Term  of  an  existing  franchised  El  Pollo  Loco®  Restaurant)  the  date  of  signing  of  the

Successor Franchise Agreement; or

c.    (for a change of ownership of any existing El Pollo Loco® Restaurant (whether it was company-owned or

franchised)) the date the change of ownership agreement is signed.

EL  POLLO  LOCO®  FRANCHISE  AGREEMENT  SCHEDULE  2:  STATEMENT  OF  OWNERSHIP  OF

FRANCHISEE

Name of Party to Franchisee Entity - _____ %

Name of Party to Franchisee Entity - _____ %

Exhibit 6 to Franchise Agreement (Exhibit D of Multi-State Disclosure Document Control No. 032619)

El Pollo Loco® Financial Reporting Form - Page 7 of 7

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit 10.16

EL POLLO LOCO® FRANCHISE DEVELOPMENT AGREEMENT

Dated: ____________________

Territory:
Developer:

(Disclosure Document Control No. 032619)

TABLE OF CONTENTS
1.DEVELOPMENT RIGHTS IN TERRITORY.    4
2.LIMITATION ON DEVELOPMENT RIGHTS.    5
3.DEVELOPMENT FEE.    9
4.TERM OF DEVELOPMENT AGREEMENT.    10
5.TERRITORY CONFLICTS.    10
6.PROPRIETARY RIGHTS OF EL POLLO LOCO.    11
7.INSURANCE AND INDEMNIFICATION.    11
8.TRANSFER OF RIGHTS.    13
9.ACKNOWLEDGMENT OF SELECTED TERMS AND PROVISIONS OF THE FRANCHISE AGREEMENT.    14
10.TERMINATION BY DEVELOPER; EXPIRATION DATE.    14
11.EVENTS OF DEFAULT.    15
12.EFFECT OF TERMINATION.    16
13.NON-WAIVER.    17
14.INDEPENDENT CONTRACTOR AND INDEMNIFICATION.    17
15.ENTIRE AGREEMENT.    17
16.DISPUTE RESOLUTION    18
17.SEVERABILITY.    19
18.APPLICABLE LAW; CHOICE OF FORUM; WAIVER OF JURY TRIAL.    19
19.DOCUMENT INTERPRETATION.    19
20.COVENANT NOT TO COMPETE.    20
21.NOTICES.    21
22.SECTION HEADINGS.    21
23.ACKNOWLEDGMENTS.    21
24.COUNTERPARTS.    22

EXHIBITS
EXHIBIT "A" TO DEVELOPMENT AGREEMENT - TERRITORY23

EXHIBIT "B" TO DEVELOPMENT AGREEMENT - DEVELOPMENT SCHEDULE24
EXHIBIT “C” TO DEVELOPMENT AGREEMENT - EXISTING EL POLLO LOCO® RESTAURANTS IN THE
TERRITORY    25

EL POLLO LOCO® FRANCHISE DEVELOPMENT AGREEMENT
(Non-exclusive/Exclusive)

THIS  FRANCHISE  DEVELOPMENT  AGREEMENT  (“Agreement”)  dated  for  identification  purposes  only  as  of
_____________________,  is  made  and  entered  into  by  and  between  EL  POLLO  LOCO,  INC.,  a  Delaware
corporation,  with  its  principal  place  of  business  at  3535  Harbor  Blvd,  Suite  100,  Costa  Mesa,  California  92626
(referred  to  herein  as  “El  Pollo  Loco”  or  “Franchisor”)  and  __________________an  individual,  with  its  principal
place of business at _____________________________________ (“Developer”).

Recitals.

A.
Franchisor  owns  certain  proprietary  and  other  property  rights  and  interests  in  and  to  the  “El  Pollo  Loco®”
trademark  and  service  mark,  and  such  other  trademarks,  service  marks,  logo  types,  insignias,  trade  dress  designs
and commercial symbols as Franchisor may from time to time authorize or direct Developer to use in connection with
the operation of a(n) “El Pollo Loco®” restaurant (the “El Pollo Loco® Marks”). Franchisor has a  distinctive  plan  for
the operation of retail outlets for the sale of fire-grilled food items and related products, which plan includes but is not
limited  to  the  El  Pollo  Loco®  Marks  and  the  Operations  Manual  (the  “Manual”),  policies,  standards,  procedures,
employee  uniforms,  signs,  menu  boards  and  related  items,  and  the  reputation  and  goodwill  of  the  El  Pollo  Loco®
chain of restaurants (collectively, the “El Pollo Loco® System”).

B.
Developer represents that it is experienced in and has independent knowledge of the nature and specifics of
the restaurant business. Developer represents that in entering into this Agreement it has relied solely on its personal
knowledge  and  has  not  relied  on  any  representations  of  Franchisor  or  any  of  its  officers,  directors,  employees  or
agents, except those representations contained in any legally required Franchise Disclosure Document delivered to
Developer.

  Developer  desires  to  obtain  development  rights  for  multiple  restaurants  under  the  El  Pollo  Loco®  System
C.
(each, an “El Pollo Loco® Restaurant”) from Franchisor within a specified geographical (the “Territory”)  specified  in
Exhibit “A” attached hereto and made a part hereof (or if single unit, replace with “Developer desires to obtain
development rights for a single restaurant under the El Pollo Loco® System (each, an “El Pollo Loco® Restaurant”)
from  Franchisor  within  a  specified  address  (the  “Territory”)  specified  in  Exhibit  “A”  attached  hereto  and
made a part hereof.”)

D.
Restaurant(s) within the Territory referenced in Exhibit “A.”    

Franchisor  is  willing  to  grant  the  (non-exclusive/exclusive)  right  to  develop  and  open  El  Pollo  Loco®

NOW, THEREFORE, in consideration of the mutual covenants and obligations herein contained, the parties hereto
agree as follows:

1.Development Rights in Territory.

1.1.    Franchisor hereby grants to Developer, subject to the terms and conditions of this Agreement (if Section
2.20 is applicable add “, and specifically Section 2.20 hereof,”) and as long as Developer shall not be in default
of this Agreement or any other development, franchise or other agreement between Developer and Franchisor, (non-
exclusive/exclusive)  development  rights  to  establish  and  operate  ____  franchised  restaurant(s),  and  to  use  the  El
Pollo  Loco®  System  solely  in  connection  therewith,  at  specific  locations  to  be  designated  in  separate  Franchise
Agreement(s) (the “Franchise Agreements”). (If exclusive agreement, add “Developer expressly acknowledges
that  the  exclusive  rights  granted  herein  apply  only  to  the  right  to  develop  new  restaurants  in  the  Territory,
and no exclusive territory or radius protection for the term of any Franchise Agreement is granted herein and
any  such  protection  shall  be  set  forth  in  the  particular  Franchise  Agreement  to  be  signed.”)  The  Franchise
Agreements  (and  all  ancillary  documents  attached  as  Exhibits  to  the  Franchise  Agreement,  including  the  Personal
Guarantee)  executed  in  accordance  with  this  Agreement  shall  be  in  the  form  currently  in  use  by  Franchisor  at  the
time of execution of the Franchise Agreement and shall be executed individually by each person, partner, member or
shareholder.

1.2.        (Only  applies  if  exclusive  Agreement.  Delete  if  non-exclusive  Agreement.)  Except  as  otherwise
provided  in  this  Agreement  and  subject  to  the  terms  and  conditions  of  Section  2.20  hereof,  after  the  date  of  this
Agreement  and  during  the  term  of  this  Agreement,  and  so  long  as  Developer  is  in  compliance  with  its  obligations
under this Agreement, Franchisor shall neither, without Developer’s prior written consent: (i) grant development rights
to anyone else with respect to the Territory or any part of the Territory; nor (ii) establish or franchise any person to
establish  an  El  Pollo  Loco  restaurant  under  the  Marks  and  System  at  any  location  within  the  Territory.  Franchisor

expressly  retains  all  other  rights  and  may,  among  other  things,  on  any  terms  and  conditions  Franchisor  deems
advisable, and without granting Developer any rights therein:

a.        Establish  and  operate  or  franchise  others  to  establish  and  operate  an  El  Pollo  Loco  restaurant

located outside of the Territory;

b.    Sell the same or similar products (whether or not using the Marks), as will be sold by Developer in a
developed  El  Pollo  Loco  restaurant,  to  customers  at  any  retail  location  (whether  within  or  outside  of  the
Territory), through any method or channel of distribution, including, without limitation, at retail locations such as
grocery or convenience stores and via the Internet, telemarketing and direct marketing means, through other
non-El-Pollo  Loco  restaurants  having  the  same  or  similar  menu  items,  or  through  any  other  distribution
channel;

c.    Establish and operate or franchise others to establish and operate restaurants (not using the Marks)

having the same or similar menu items whether within or outside of the Territory; and

d.    Any continued operation by Franchisor, or the allowance of any continued operation by a franchisee
of Franchisor, of an El Pollo Loco restaurant within the Territory which was opened on or before the date of this
Agreement shall not be considered to constitute a breach of this Agreement.

1.3.        (Only  applies  to  multi-unit  Development  Agreement  –  delete  if  single-unit  Development
Agreement).  Prior  to  or  concurrent  with  the  execution  of  this  Agreement,  Developer  shall  meet  with  Franchisor’s
development representatives and prepare a market development plan for the units to be constructed and opened by
Developer  in  the  Territory  (identifying  specific  key  areas,  key  intersections  and  trade  areas  in  the  Territory)  and  all
development pursuant to this Agreement shall be in accordance with this plan (the “Market Plan”). The Market Plan
shall  include  proposed  areas  where  sites  may  be  located,  ranking  and  prioritization  of  site  locations  and  other
information  customarily  used  by  market  planners  in  the  restaurant  industry.  Developer  and  Franchisor  shall  jointly
approve the Market Plan.

2.    Limitation on Development Rights.

2.1.        Developer  must  submit  one  or  more  site(s)  for  approval,  enter  into  binding  leases  or  purchase
agreements and open to the public the number of El Pollo Loco® Restaurant(s) on such approved sites each calendar
year  as  required  on  the  Development  Schedule,  all  as  set  forth  on  Exhibit  “B”  attached  hereto  and  made  a  part
hereof.

2.2.    For purposes of the Development Schedule in Exhibit “B”, no credit will be given for the development of
El Pollo Loco® Restaurant(s) outside the Territory, regardless of the fact that Developer may, upon proper application,
obtain from Franchisor an El Pollo Loco® Franchise Agreement (“Franchise Agreement”) for any such development.

2.3.        Although  this  Agreement  affords  the  Developer  the  right  to  develop  and  open  El  Pollo  Loco®
restaurant(s) within the Territory, as set forth on Exhibit “A”, all Restaurant(s) developed under this Agreement must
be  duly  licensed  through  individual  Franchise  Agreement(s).  Developer  will  execute  El  Pollo  Loco’s  then  standard
Franchise  Agreement  in  use  at  the  time  of  execution  for  each  restaurant  developed  under  this  Agreement,  and
agrees to pay Franchisor the current fees, royalties and other required payments in accordance with the Franchise
Agreement  and  Franchise  Disclosure  Document  then  in  effect.  Execution  of  the  appropriate  Franchise  Agreement
and  payment  of  the  initial  franchise  fee  and/or  any  other  required  fees  must  be  accomplished  prior  to  the
commencement of construction at any site.

2.4.    Developer must satisfy all Franchisor’s financial and operational criteria then in effect and in addition, if
Developer is also a Franchisee of one or more El Pollo Loco Restaurants, Franchisee must also be in good standing
with  Franchisor  and  satisfy  all  Franchisor’s  financial  and  operational  criteria  then  in  effect  prior  to  El  Pollo  Loco's
execution  of  each  standard  Franchise  Agreement  issued  pursuant  to  this  Agreement.  Developer  shall  provide
Franchisor  with  current  information  pertaining  to  Developer's  financial  condition  and  the  financial  condition  of  the
majority and managing members/partners/shareholders of Developer at any time upon El Pollo Loco's request and in
no  event  less  than  once  annually.  Developer  acknowledges  that,  among  other  things,  it  will  be  required  to  submit
annual  financial  statements  of  Developer  and  personal  financial  statements  of  each  of  its  principal  owners  and
Managing Members to be eligible for financial approval by El Pollo Loco. In the event any of the majority owners of
Developer shall also be the Managing Members and/or majority owners of any other entity which is a franchisee of El
Pollo  Loco,  then  each  such  franchisee  entity  must  be  operationally  and  financially  approved  by  Franchisor  before
approval  for  expansion  will  be  granted  to  any  one  franchisee  entity.  “Managing  Members”  shall  be  any  individuals
who  are  designated  as  the  primary  decision  makers  or  general  managers  of  the  franchisee  entity  and  those
individuals who (individually or collectively) own at least 51% interest in the franchisee entity.

2.5.        Developer  shall  use  its  best  efforts  to  retain  qualified  real  estate  professionals  (including  licensed
brokers) to locate proposed sites for the El Pollo Loco® Restaurant(s). Developer shall submit proposed sites for each
El Pollo Loco® Restaurant unit to be developed under this Agreement for acceptance by Franchisor’s Real Estate Site
Approval Committee (“RESAC”), together with such site information as may be reasonably required by Franchisor to
evaluate the proposed site, no later than the dates set forth in Exhibit “B” as RESAC Submittal Dates, the first of
which  shall  be  approximately  ninety  (90)  days  after  execution  of  this  Agreement.  Should  the  site  be  accepted  by
RESAC,  it  will  be  referred  to  as  the  “Approved  Site”.  Such  acceptance  will  expire  one  (1)  year  from  the  RESAC
approval date. Franchisor may require, as a condition to its approval of a site, a “Market Study”, which shall include a
site description and analysis, traffic and other demographic information and an analysis of the impact of the proposed
site  on  other  company  owned  and  franchised  El  Pollo  Loco  restaurants  surrounding  or  within  the  vicinity  of  such
proposed site all in such format as the Franchisor may require. All such analyses, information and studies shall be
prepared at the sole cost and expense of Developer.

2.6.    Franchisor shall send representatives to evaluate proposed site(s) for each El Pollo Loco® Restaurant to
be developed under this Agreement, and Franchisor will do so at its own expense for the first two (2) proposed sites
for  each  El  Pollo  Loco®  Restaurant.  If  Developer  proposes,  and  Franchisor  evaluates,  more  than  two  (2)  sites  for
each El Pollo Loco® Restaurant, then Developer shall reimburse Franchisor for the reasonable costs and expenses
incurred  by  Franchisor’s  representatives  in  connection  with  the  evaluation  of  such  additional  proposed  site(s),
including, without limitation, the costs of lodging, travel, meals and wages.

2.7.    Provided there exists no default by Developer under this Agreement or any other development, franchise
or  other  agreement  between  Franchisor  and  Developer,  Franchisor  shall  evaluate  each  site  proposed  for  which
Developer  has  provided  all  necessary  evaluation  information,  and  shall  promptly  after  receipt  of  Developer’s
proposal, send to Developer written notice of acceptance or non-acceptance of the sit

2.8.    If RESAC determines through its evaluation of the proposed site that the proposed site may impact sales
at any company-owned El Pollo Loco® Restaurant, Franchisor has the sole and absolute right to accept or reject the
proposed site, without any obligation to discuss a possible resolution with Developer. However, Franchisor may elect
to  discuss  with  Developer  a  possible  resolution  with  regard  to  the  proposed  site;  however,  if  such  an  agreement
cannot  be  reached,  Franchisor  has  the  sole  and  absolute  right  to  reject  the  proposed  site.  If  RESAC  determines
through its evaluation of the proposed site that the proposed site may potentially impact sales at any existing El Pollo
Loco® franchisee’s restaurant, Franchisor shall notify Developer of the existing El Pollo Loco® franchisees’ location(s)
and contact information. If nevertheless Developer wishes to try to proceed with that site, Developer must obtain a
written waiver from those existing El Pollo Loco® franchisees of any claims they might have against Developer and
Franchisor with respect to the proposed new El Pollo Loco® Restaurant. Such waiver, if obtained, must be submitted
along with the evaluation information required pursuant to this Section.

2.9.        No  later  than  the  Site  Commitment  Dates  set  forth  in  Exhibit  “B”,  Developer  shall  submit  for  the

Approved Site to Franchisor for its review and approval of:

a.        A  fully  negotiated  but  unexecuted  lease,  which  may  only  subject  to  obtaining  necessary
governmental  permits.  The  unexecuted  form  of  the  lease  must  be  submitted  to  Franchisor  to  review  for  the
required terms and conditions listed in Sections 2.9, 2.10, 2.11 and 2.12 below prior to  full execution of  the
lease. Franchisor will promptly notify Developer upon their approval of the inclusion of such required terms and
conditions. Developer will promptly then provide a final executed copy of the lease to Franchisor; or

b.        A  purchase  agreement.  Should  Developer  purchase  the  site  using  another  entity  other  than  the
franchise  entity,  Developer  must  then  enter  into  a  lease  with  the  Franchise  entity  as  the  lessee  and  the
purchasing entity as the lessor and must comply with all the requirements of this Sections 2.9, 2.10, 2.11 and
2.12 below).

2.10.    Any lease to be entered into by Developer shall include the terms and conditions set forth below and in

a form approved by Franchisor:

a.    The tenant entity on the lease must match the franchise entity on the franchise agreement; and

b.       The  term  (with  renewal  options)  of  the  lease  must  match  at  least  the  initial  term  of  the  franchise

agreement; and

c.       The  landlord  consents  to  your  use  of  the  premises  as  an  El  Pollo  Loco®  restaurant  which  will  be

open during the required days and hours set out in the Operations Manual.

2.11.        Franchisor  shall  have  no  liability  under  any  lease  or  purchase  agreement  for  any  El  Pollo  Loco®
Restaurant  location  developed  under  this  Agreement  and  shall  not  guarantee  Developer’s  obligations  thereunder.
Upon  approval  by  Franchisor  of  the  form  of  Developer’s  lease  and  execution  of  a  lease  for  a  site  by  Developer,
Developer shall furnish to Franchisor a fully executed copy of such lease and any amendments thereto within fifteen
(15) calendar days of such execution. Franchisor shall have no obligation to assist Developer to negotiate its leases.

2.12.        The  lease  or  deed  may  not  contain  a  non-competition  covenant  which  restricts  Franchisor  or  any
franchisee  or  licensee  of  Franchisor,  from  operating  an  El  Pollo  Loco®  Restaurant  or  any  other  retail  restaurant,
unless such covenant is approved by Franchisor in writing prior to the execution by Developer of the lease.

2.13.    Each subsequent site to be developed pursuant to the Development Schedule shall be submitted for
approval by RESAC by the date set forth in Exhibit “B”. Similarly,  each  fully  executed  lease  (executed  upon  prior
review and approval by Franchisor) or purchase agreement (with all contingencies to Developer’s obligations waived
or  satisfied,  except  permitting  contingencies)  relating  to  each  subsequent  Approved  Site  shall:  (1)  be  delivered  to
Franchisor  on  or  before  the  Site  Commitment  Date  for  each  respective  El  Pollo  Loco®  Restaurant  as  set  forth  in
Exhibit  “B”  and  (2)  prior  to  the  execution  of  your  Franchise  Agreements  (3)  prior  to  the  payment  of  your  initial
Franchise Fees for each site and (4) prior to the commencement of construction of the El Pollo Loco® Restaurant.

2.14.    RESAC site approval does not assure that a Franchise Agreement will be executed. Execution of the
Franchise Agreement is contingent upon Developer completing the purchase or lease of the proposed site within sixty
(60)  days  after  approval  of  the  site  by  the  Franchisor  or  no  later  than  the  dates  set  forth  in  Exhibit  “B”  as  Site
Committment Dates.

2.15.    Developer acknowledges that time is of the essence in this Agreement. If Developer has not obtained
approval and entered into a binding lease or purchase agreement for each site for El Pollo Loco® Restaurant(s) to be
developed  under  this  Agreement  by  the  applicable  Site  Commitment  Date,  Developer  shall  be  in  default  of  its
obligations  under  the  Development  Schedule  and  Franchisor  shall  be  entitled  to  exercise  its  rights  and  remedies
under this Agreement, up to and including termination of this Agreement.

2.16.        Developer  also  acknowledges  that  it  is  required  pursuant  to  this  Agreement  to  open  El  Pollo  Loco®
Restaurants  in  the  future  pursuant  to  dates  set  forth  in  the  Development  Schedule  attached  as  Exhibit  “B”.  If
Developer fails to meet the opening date for any El Pollo Loco® Restaurant to be developed under this Agreement,
Developer  shall  be  in  default  and  Franchisor  shall  be  entitled  to  exercise  all  rights  and  remedies  available  to
Franchisor set forth in Section 11. Developer acknowledges that if Developer fails to open El Pollo Loco® Restaurants
in  a  timely  manner  pursuant  to  the  Development  Schedule,  Franchisor  will  suffer  lost  revenues,  including  royalties
and other fees which would be difficult to calculate and which Franchisor would have received had Developer met the
agreed schedule or had Franchisor had the right to grant development rights to others in the Territory.

2.17.    Developer acknowledges that the estimated initial investment and estimated expenses set forth in Items
6 and 7 of our Franchise Disclosure Document are subject to and likely to increase over time, and that future El Pollo
Loco® Restaurants will likely involve a greater initial investment and operating capital requirements than those stated
in the Franchise Disclosure Document provided to you prior to your execution of this Agreement.

2.18.    Developer understands and acknowledges that in accepting Developer’s proposed site or by granting a
franchise  for  each  approved  site,  Franchisor  does  not  in  any  way,  endorse,  warrant  or  guarantee  either  directly  or
indirectly the suitability of such site or the success of the franchise business to be operated by Developer at such site.
The  suitability  of  the  site  and  the  success  of  the  franchise  business  depend  upon  a  number  of  factors  outside  of
Franchisor’s control, including, but not limited to, the Developer’s operational abilities, site location, consumer trends
and such other factors that are within the direct control of the Developer.

2.19.        The  purpose  of  this  Agreement  is  to  promote  orderly  incremental  growth  within  the  El  Pollo  Loco®
System. The acquisition of existing El Pollo Loco® restaurants by Developer does not represent incremental growth
and, therefore, does not satisfy the terms of this Agreement pertaining to development.

2.20.    (To be added where there are existing restaurants in the Territory) Developer acknowledges that
Franchisor (i) is operating or has franchised another to operate, one (1) or more restaurants in the Territory
or (ii) has granted franchise rights to another in the Territory or (iii) approved a new site for development for
those locations identified in Exhibit “C” attached hereto and incorporated herein by this reference. Developer
further  acknowledges  that  Franchisor  retains  the  sole  and  absolute  right  to  approve  or  disapprove  any
proposed  location  for  development  under  this  Agreement  if,  in  Franchisor’s  reasonable  judgment:  (i)  such
proposed location is not suitable for an El Pollo Loco® Restaurant or (ii) such proposed location will have a
material adverse effect on the profitability of another existing El Pollo Loco® location (or approved site) in the

Territory. Developer covenants to use its reasonable best efforts to avoid selecting proposed locations that
would adversely impact pre-existing locations in the Territory.

3.    Development Fee.

3.1.    Developer shall pay to Franchisor upon execution of this Agreement a non-refundable Development Fee
(the “Development Fee”)  equal  to  Twenty  Thousand  Dollars  ($20,000)  in  immediately  available  funds,  for  each  El
Pollo  Loco®  Restaurant  to  be  developed  under  this  Agreement.  The  Development  Fee  is  consideration  for  this
Agreement.  The  Development  Fee  is  not  consideration  for  any  Franchise  Agreement  and  is  non-refundable.  The
$20,000  Development  Fee  for  each  El  Pollo  Loco®  Restaurant  shall  be  applied  against  the  initial  franchise  fee
payable upon the execution of the Franchise Agreement applicable to such El Pollo Loco® Restaurant. As a benefit of
signing the Development Agreement, the Initial Fee for the second and each subsequent restaurant developed under
the  same  Development  Agreement  will  be  reduced  by  us  to  $30,000.  As  an  example,  the  Initial  Fee  for  the  first
restaurant developed under a Development Agreement would be $40,000 to which $20,000 (from the Development
Fee  will  be  credited.  The  Initial  Fee  for  the  second  and  remaining  restaurants  developed  under  the  same
Development  Agreement  would  be  $30,000,  to  which  $20,000  from  the  Development  Fee  will  be  credited.  If  this
Agreement  is  terminated  pursuant  to  Sections  10  or  11  below,  Developer  will  lose  its  right  to  develop  and
Development Fee.

4.    Term of Development Agreement.

4.1.        This  Agreement  shall  commence  on  the  date  specified  in  Exhibit "B".  Unless  terminated  pursuant  to
Section 10 or 11 below, it shall expire upon the earlier of the date specified in Exhibit "B" or upon the opening of the
last El Pollo Loco® Restaurant listed in the Development Schedule.

5.    Territory Conflicts.

5.1.        The  rights  granted  Developer  in  this  Agreement  are  subject  to  any  prior  territorial  rights  of  other
franchisees  which  may  now  exist  in  the  Territory,  whether  or  not  those  rights  are  currently  being  enforced.  In  the
event  of  a  conflict  in  territorial  rights,  whether  under  a  Franchise  Agreement  or  separate  territorial  or  development
agreement, Developer shall be free to negotiate with any person, corporation or other entity, which claims territorial
rights adverse to the rights granted under this Agreement, for the assignment of those prior territorial rights. For this
purpose, Franchisor agrees to approve any such assignment not in conflict with the other terms of this Agreement,
subject  to  the  condition  of  any  Franchise  Agreements  involved,  and  current  policies  pertaining  to  assignments,
including,  but  not  limited  to,  satisfaction  of  all  past  due  debts  owed  to  Franchisor  and  the  execution  of  a  General
Release.

5.2.    In the event of third party claims of the right to develop the Territory, it is the sole responsibility of El Pollo
Loco, where the right granted herein is exclusive, to protect and maintain Developer's right to the development of the
Territory.  However,  if  it  appears  to  El  Pollo  Loco,  as  its  sole  and  absolute  right  to  determine,  that  protection  of  the
Territory  by  legal  action  is  not  advisable,  whether  due  to  the  anticipation  of,  or  the  actual  protracted  nature  of  the
action,  the  costs  involved,  the  uncertainty  of  outcome,  or  otherwise,  Franchisor  has  the  right  to  terminate  this
Agreement,  provided  that  it  refunds  to  Developer  the  balance,  if  any,  of  the  Development  Fee  made  pursuant  to
Section  3,  which  has  not  been  applied  against  the  initial  franchise  fees  for  Franchise  Agreement(s)  to  be  acquired
under this Agreement.

6.    Proprietary Rights of El Pollo Loco.

6.1.    Developer expressly acknowledges El Pollo Loco's exclusive right, title, and interest in an to the trade
name,  service  mark  and  trademark  "El  Pollo  Loco",  and  such  other  trade  names,  service  marks,  and  trademarks
which are designated as part of the El Pollo Loco® System (the "Marks"), and Developer agrees not to represent in
any  manner  that  Developer  has  any  ownership  in  El  Pollo  Loco®  Marks.  This  Agreement  is  not  a  Franchise
Agreement. Developer may not open an El Pollo Loco® Restaurant or use the El Pollo Loco®  Marks  at  a  particular
site until it executes a Franchise Agreement for that site. Developer's use of the El Pollo Loco® Marks shall be limited
to  those  rights  granted  under  each  individual  Franchise  Agreement.  Notwithstanding  the  foregoing,  El  Pollo  Loco®
may  authorize  Developer  in  writing  to  use  the  Marks  in  connection  with  advertising  and  marketing  activities  in
connection with this Agreement. Developer expressly agrees that such usage is limited to those specific activities or
promotional materials approved by El Pollo Loco’s marketing department in advance. Developer further agrees that
its use of the Marks shall not create in its favor any right, title, or interest in or to El Pollo Loco® Marks, but that all of
such use shall inure to the benefit of El Pollo Loco, and Developer has no rights to the Marks except to the degree
specifically granted by the individual Franchise Agreement(s). Building designs and specifications, color schemes and
combinations, sign design specifications, and interior building layouts (including equipment, equipment specification,

equipment layouts, and interior color schemes and combinations) are acknowledged by Developer to comprise part of
the El Pollo Loco® System. Developer shall have no right to license or franchise others to use the Marks by virtue of
this Agreement.

6.2.        Developer  acknowledges  that,  in  connection  with  its  execution  of  this  Agreement,  it  may  receive
confidential and proprietary information regarding the El Pollo Loco® System, including but not limited to the El Pollo
Loco Operational Manual. Developer recognizes the unique value and secondary meaning attached to the El Pollo
Loco® Marks and the El Pollo Loco®  System,  and  Developer  agrees  that  any  noncompliance  with  the  terms  of  this
Agreement  or  any  unauthorized  or  improper  use  will  cause  irreparable  damage  to  Franchisor  and  its  franchisees.
Developer, therefore, agrees that if it should engage in any such unauthorized or improper use during, or after, the
term of this Agreement, Franchisor shall be entitled to both seek temporary and permanent injunctive relief from any
court of competent jurisdiction in addition to any other remedies prescribed by law.

6.3.        Developer  acknowledges  that  it  will  receive  one  (1)  copy  of  the  Operations  Manual  on  loan  from

Franchisor and that the Operations Manual shall at all times remain the sole property of the Franchisor.

7.    Insurance and Indemnification.

7.1.        Throughout  the  term  of  this  Agreement,  Developer  shall  obtain  and  maintain  insurance  coverage  for
public liability, including products liability, in the amount of at least One Million Dollars ($1,000,000) combined single
limit. Developer also shall carry such worker's compensation insurance as may be required by applicable law.

7.2.    Franchisor shall be named as an additional insured on all such insurance policies and shall be provided
with certificates of insurance evidencing such coverage. All public liability and property damage policies shall contain
a provision that El Pollo Loco, although named as an insured, shall nevertheless be entitled to recover under such
policies on any loss incurred by El Pollo Loco, its affiliates, agents and/or employees, by reason of the negligence of
Developer,  its  principals,  contractors,  agents  and/or  employees.  All  policies  shall  provide  Franchisor  with  at  least
thirty (30) days’ notice of cancellation or termination of coverage.

7.3.        Franchisor  reserves  the  right  to  specify  reasonable  changes  in  the  types  and  amounts  of  insurance
coverage  required  by  this  Section  7.  In  the  event  that  Developer  fails  or  refuses  to  obtain  or  maintain  the  required
insurance coverage from an insurance carrier acceptable to El Pollo Loco, Franchisor may, as its sole and absolute
right and without any obligations to do so, procure such coverage for Developer. In such event, Developer shall pay
the required premiums or reimburse such premiums to Franchisor upon written demand.

7.4.        Developer  shall  defend  immediately  upon  tender  of  defense,  at  its  own  cost,  the  Franchisor,  its
subsidiaries, parent and affiliates, shareholders, directors, officers, employees and agents (collectively for this section
only  known  as  “Franchisor”),  from  and  against  any  and  all  claims,  lawsuits,  complaints,  cross  complaints,
arbitrations,  demands,  allegations,  costs  embraced  by  indemnity,  loss,  costs,  expenses  (including  attorneys’  fees),
liens and damages (collectively for this section only known as “Losses”), however caused, and reimburse Franchisor
for all costs and expenses (including attorneys’ fees) incurred by the Franchisor in defense of any Losses, resulting
directly or indirectly from or pertaining to or arising out of, or alleged to arise out of, or in connection with Developer’s
activities under the Development Agreement, including any labor, any employee related claims whatsoever, including,
without  limitation  any  claims  made  by  an  employee  of  Developer  resulting  from  the  employee’s  training  in  a
Franchisor  operated  facility  or  restaurant,  and  including  Developer’s  failure  for  any  reason  to  fully  inform  any  third
party  of  Developer’s  lack  of  authority  to  bind  the  Franchisor  for  any  purpose.  Such  Losses  shall  include,  without
limitation, those arising from the death of or injury to any person or arising from damage to the property of Developer
or the Franchisor, or any third person, firm or corporation, whether or not resulting from any strict liability imposed by
fact,  law,  statute,  or  ordinance,  on  the  Franchisor.  Developer  further  agrees  that  Developer’s  duty  to  defend  the
Franchisor is separate from, independent of and free-standing of Developer’s duty to indemnify the Franchisor and
applies  whether  the  issue  of  Developer’s  negligence,  breach  of  contract,  or  other  fault  or  obligation  has  been
determined. Developer’s duty to defend is regardless of the outcome of liability even if Developer is ultimately found
not negligent and not dependent on the ultimate resolution of issues arising out of any claims, lawsuits, complaints,
cross  complaints,  arbitration,  demands,  allegations,  costs  embraced  by  indemnity,  loss,  costs,  expenses  (including
attorneys’ fees), liens or damages.

7.5.       Developer shall indemnify and hold harmless the Franchisor (as defined above) from and against any
and all Losses (as defined above), however caused, resulting directly or indirectly from or pertaining to or arising out
of or in connection with Developer’s activities under the Development Agreement, including any labor, any employee
related claims whatsoever, including, without limitation any claims made by an employee of Developer resulting from
the  employee’s  training  in  a  Franchisor  operated  facility  or  restaurant,  and  including  Developer’s  failure  for  any
reason  to  fully  inform  any  third  party  of  Developer’s  lack  of  authority  to  bind  the  Franchisor  for  any  purpose.  Such
Losses  shall  include,  without  limitation,  those  arising  from  latent  or  other  defects  in  the  restaurant  whether  or  not

discoverable by Franchisor, and those arising from the death of or injury to any person or arising from damage to the
property  of  Developer  or  the  Franchisor,  or  any  third  person,  firm  or  corporation,  whether  or  not  resulting  from  any
strict liability imposed by fact, law, statute, or ordinance, on the Franchisor. Developer further agrees to indemnify and
hold  harmless  Franchisor  from  all  said  Losses  and  shall  pay  for  and  be  responsible  for  all  said  Losses,  however
caused, whether by any individual, employee, third person or party, vendor, visitor, invitee, trespasser or any firm or
corporation whatsoever, whether caused by or contributed to by Franchisor, the combined conduct of Developer and
Franchisor,  or  active  or  passive  negligence  of  Franchisor,  but  for  the  sole  negligence  or  willful  misconduct  of
Franchisor.

7.6.    The provisions of this Section 7 shall expire as to each El Pollo Loco® Restaurant to be developed under
this Agreement upon execution of a Franchise Agreement for such El Pollo Loco® Restaurant. The provision of the
Franchise Agreement, in particular, Section 9 thereof (insurance and Indemnification) shall supersede this Section 7
and govern the rights and obligations of the parties prospectively.

8.    Transfer of Rights.

8.1.        This  Agreement  shall  inure  to  the  benefit  of  Franchisor  and  its  successors  and  assigns,  and  is  fully

assignable by El Pollo Loco.

8.2.    The parties acknowledge and agree that this Agreement is personal in nature with respect to Developer,
being entered into by Franchisor in reliance upon and in consideration of the personal skills, qualifications and trust
and confidence reposed in Developer and Developer's present partners, managing members or officers if Developer
is  a  partnership,  a  limited  liability  company  or  a  corporation.  Therefore,  the  rights,  privileges  and  interests  of
Developer under this Agreement shall not be assigned, sold, transferred, leased, divided or encumbered, voluntarily
or involuntarily, in whole or in part, by operation of law or otherwise without the prior written consent of El Pollo Loco,
which consent may be given or withheld as El Pollo Loco’s sole and absolute right. For purposes of this Section, a
sale of stock, or any membership or partnership interest in Developer, or a merger or other combination of Developer
shall be considered a transfer of Developer's interest prohibited hereunder. Notwithstanding the foregoing, Developer
shall be permitted to assign business organizations to serve as Franchisee after Developer individually executes the
Franchise  Agreements,  provided  the  ownership  mirrors  that  of  Developer  (e.g.,  Developer  consists  of  persons  A
(50%),  B  (25%)  and  C  (25%).  Franchisee  also  must  be  owned  and  controlled  by  the  same  three  (3)  persons  with
each retaining the same percentage of ownership). All other entity structures shall require the prior written approval of
Franchisor. Developer shall pay an administrative fee of Five Hundred Dollars ($500) per transfer for each permitted
transfer to an Entity where such transfer is for the convenience of ownership only and does not involve a change of
principals of the business. Where Developer desires to add new principals to the Developer or any Franchisee entity,
Developer  shall  pay  to  Franchisor  an  additional  Two  Thousand  Five  Hundred  Dollars  ($2,500)  per  new  principal  to
cover  Franchisor’s  administrative  costs  for  reviewing  the  application  and  suitability  of  each  new  principal  as
participants in the franchise business.

9.    Acknowledgment of Selected Terms and Provisions of the Franchise Agreement.

9.1.    Developer represents that it has read each of the terms and provisions of the current form of Franchise
Agreement and acknowledges and is willing to agree to each and every obligation of Franchisee thereunder (as they
may be modified in then-current forms of Franchise Agreement) including, but not limited to:

a.        The  obligation  to  deliver  execute  Personal  Guarantees  or  Investor  Covenants  Regarding
Confidentiality and Non-Competition in connection with the execution of each franchise agreement for El Pollo
Loco® Restaurants to be developed under this Agreement;

b.        The  obligation  to  obtain  the  consent  of  Franchisor  to  any  security  interests  to  be  granted  by
Developer in the assets or business of the El Pollo Loco® Restaurant to lenders or other financing sources in
advance of any agreement to provide those security interests to such third parties;

c.    All in-term and post-term restrictive covenants; and

d.        All  territorial  rights,  options  and  rights  of  first  refusal  retained  by  Franchisor  under  the  franchise

agreement.

10.    Termination by Developer; Expiration Date.

10.1.        This  Agreement  shall  terminate  immediately  upon  El  Pollo  Loco's  receipt  of  Developer's  notice  to
terminate. In such event, the Development Fee shall be forfeited to Franchisor in consideration of the rights granted
in the Territory up to the time of termination. Notwithstanding any provision to the contrary contained herein, unless

earlier terminated by either party, this Agreement shall expire on ______, 20___, and all rights of Developer herein
shall  cease  and  all  unapplied  or  unused  Development  Fees  paid  pursuant  to  Section  3  hereof  shall  be  forfeited  to
Franchisor.

11.    Events of Default.

11.1.    The following events shall constitute a default by Developer, which shall result in El Pollo Loco's right to

declare the immediate termination of this Agreement.

a.    Failure by Developer to meet the requirements of the Development Schedule within the time periods
specified therein, including failure by Developer to meet the Site Commitment Date or Opening Date for each
site for an El Pollo Loco® Restaurant in a timely manner as set forth in Exhibit “B” and Section 2 above.

b.        Any  assignment,  transfer  or  sublicense  of  this  Agreement  by  Developer  without  the  prior  written

consent of El Pollo Loco.

c.        Any  violation  by  Developer  of  any  covenant,  term,  or  condition  of  any  note  or  other  agreement
(including any El Pollo Loco®  Franchise  Agreement)  between  Developer  and  Franchisor  (or  an  affiliate  of  El
Pollo  Loco),  the  effect  of  which  is  to  allow  Franchisor  to  terminate  (or  accelerate  the  maturity  of)  such
agreement before its stated termination (or maturity) date.

d.    Developer's assignment for the benefit of creditors or admission in writing of its inability to pay its

debts generally as they become due.

e.    Any order, judgment, or decree entered adjudicating Developer bankrupt or insolvent.

f.    Any petition, or application, by Developer to any tribunal for the appointment of a trustee, receiver, or
liquidator of Developer (or a substantial part of Developer's assets), or commencement by Developer of any
proceedings  relating  to  Developer  under  any  bankruptcy,  reorganization,  compromise,  arrangement,
insolvency, readjustment of debt, dissolution, or liquidation law of any jurisdiction, whether now or hereinafter
in effect.

g.    Any filing of a petition or application against Developer, or the commencement of such proceedings,
in which Developer, in any way, indicates its approval thereof, consent thereto, or acquiescence therein; or the
entry of any order, judgment, or decree appointing any trustee, receiver, or liquidator, or approving the petition
in any such proceedings, where the order, judgment, or decree remains unstayed and in effect for more than
thirty (30) days.

h.        Any  entry  in  any  proceeding  against  the  Developer  of  any  order,  judgment,  or  decree,  which
requires the dissolution of Developer, where such order, judgment, or decree remains unstayed and in effect
for more than thirty (30) days.

i.    Developer's voluntary abandonment of any of Developer's restaurants.

11.2.    The following events shall constitute a default by Developer, which shall result in El Pollo Loco's right to
declare  the  termination  of  this  Agreement,  if  such  default  is  not  cured  within  thirty  (30)  days  after  written  notice  by
Franchisor to Developer:

a.    Developer's default in the performance or observance of any covenant, term, or condition contained

in this Agreement not otherwise specified in Section 11.1 above.

b.        The  creation,  incurrence,  assumption,  or  sufferance  to  exist  of  any  lien,  encumbrance,  or  option
whatsoever upon any of Developer's property or assets, whether now owned or hereafter acquired, the effect
of which substantially impairs Developer's ability to perform or observe any covenant, term, or condition of this
Agreement.

c.    Refusal by Developer or Developer’s partners, members, or shareholders to enter individually into

the then-current form of Franchise Agreements and Personal Guarantee as provided in Section 1 above.

d.    Any change, transfer or conveyance (“Transfer”) in the ownership of Developer, which Transfer has
not  been  approved  in  advance  by  Franchisor.  Franchisor  reserves  the  right  to  approve  or  disapprove  any
Transfer as its sole and absolute right.

11.3.    If Franchisor is entitled to terminate this Agreement in accordance with Sections 11.1 or 11.2 above,

Franchisor shall have the right to undertake the following action instead of terminating this Agreement:

a.    Franchisor may terminate or modify any rights that Developer may have with respect to protected
exclusive rights in the Territory, as granted under Section 1.1 above, effective ten (10) days after delivery of
written notice thereof to Developer.

11.4.    If any of such rights are terminated or modified in accordance with this Section 11.3, such action shall
be  without  prejudice  to  Franchisor’s  right  to  terminate  this  Agreement  in  accordance  with  Sections  11.1  or  11.2
above, and/or to terminate any other rights, options or arrangements under this Agreement at any time thereafter for
the same default or as a result of any additional defaults of the terms of this Agreement.

12.    Effect of Termination.

12.1.        Immediately  upon  termination  or  expiration  of  this  Agreement,  for  any  reason,  all  of  Developer's
development rights granted pursuant to this Agreement shall revert to El Pollo Loco. At the time of termination, only
restaurants  operating  or  to  be  operated  under  the  El  Pollo  Loco®  System  by  virtue  of  a  fully  executed  Franchise
Agreement shall be unaffected by the termination of this Agreement. Franchisor shall have no duty to execute any
Franchise  Agreement  with  Developer  after  the  termination  of  this  Agreement.  The  foregoing  remedies  are
nonexclusive,  and  nothing  stated  in  this  Section  12  shall  prevent  El  Pollo  Loco's  pursuit  of  any  other  remedies
available to Franchisor in law or at equity due to the termination of this Agreement.

12.2.    Developer understands and agrees that upon the expiration or termination of this Agreement (or in the
event of an exclusive development agreement, the failure of Developer to meet the Development Schedule and the
resulting loss of exclusive development rights), Franchisor or its subsidiaries or affiliates, as their sole and absolute
right,  may  open  and/or  operate  restaurants  in  the  Territory,  or  may  authorize  or  franchise  others  to  do  the  same,
whether it is in competition with or in any other way affects the sales of Developer at the restaurants.

13.    Non-Waiver.

13.1.       El  Pollo  Loco's  consent  to  or  approval  of  any  act  or  conduct  of  Developer  requiring  such  consent  or
approval  shall  not  be  deemed  to  waive  or  render  unnecessary  El  Pollo  Loco's  consent  to  or  approval  of  any
subsequent act or conduct hereunder.

14.    Independent Contractor and Indemnification.

14.1.       This  Agreement  does  not  constitute  Developer  an  agent,  legal  representative,  joint  venturer,  partner,
employee or servant of Franchisor for any purpose whatsoever, and it is understood between the parties hereto that
Developer shall be an independent contractor and is in no way authorized to make any contract, agreement, warranty
or  representation  on  behalf  of  El  Pollo  Loco.  The  parties  agree  that  this  Agreement  does  not  create  a  fiduciary
relationship between them.

14.2.       Under no circumstances shall Franchisor be liable for any act, omission, contract, debt, or any other
obligation of Developer. Developer shall indemnify and save Franchisor harmless against any such claim and the cost
of defending it arising directly or indirectly from or as a result of, or in connection with, Developer's actions pursuant to
this Agreement.

15.    Entire Agreement.

15.1.    This Agreement, including Exhibits "A", "B" and “C” attached hereto, constitutes the entire full and
complete agreement between Franchisor and Developer concerning the subject matter hereof and supersedes any
and all prior written agreements. No other representations have induced Developer to execute this Agreement, and
there  are  no  representations,  inducements,  promises,  or  agreements,  oral  or  otherwise,  between  the  parties,  not
embodied herein, which are of any force or effect with reference to this Agreement or otherwise. Notwithstanding the
foregoing, nothing in this Agreement shall disclaim or require Developer to waive reliance on any representation that
Franchisor  made  in  the  most  recent  disclosure  document  (including  its  exhibits  and  amendments)  that  Franchisor
delivered to Developer or its representative, subject to any agreed-upon changes to the contract terms and conditions
described in that disclosure document and reflected in this Agreement (including any riders or addenda signed at the
same  time  as  this  Agreement).  The  provisions  of  this  Agreement  may  not  be  contradicted  by  any  other  statement
concerning  the  subject  matter  herein.  No  amendment  or  modification  of  this  Agreement  shall  be  binding  on  either
party unless written and fully executed.

16.    Dispute Resolution

16.1.    Initial Meeting and Mediation - Except as otherwise provided in this Agreement, before any legal action
is filed involving any claim or controversy between Franchisor and Developer (including its affiliates, investors, and
Owners) relating to (a) this Agreement, (b) the parties business activities conducted as a result of this Agreement, or
(c) the parties’ relationship or business dealings with each other generally, the following procedure shall be complied
with:

a.       The  party  wishing  to  resolve  a  dispute  shall  initiate  negotiation  proceedings  by  first  requesting  in
writing a meeting with the other party or parties. Within forty-five (45) days of receipt of the initial request for a
meeting, the parties shall meet within the county in which Developer is then located, to discuss and negotiate
toward a resolution of the controversy.

b.        If  negotiation  efforts  do  not  succeed,  the  parties  shall  engage  in  mandatory  but  non-binding
mediation by a mediator jointly chosen by the parties or if the parties cannot agree upon a mediator, appointed
by, and in accordance with the procedures of, JAMS or, if JAMS is no longer in existence, an organization of
similar quality

c.    A mediation meeting will be held at a place and at a time mutually agreeable to the parties and the
mediator. The Mediator will determine and control the format and procedural aspects of the mediation meeting
which  will  be  designed  to  ensure  that  both  the  mediator  and  the  parties  have  an  opportunity  to  present  and
hear  an  oral  presentation  of  each  party’s  views  regarding  the  matter  in  controversy.  The  parties  act  in  good
faith to resolve the controversy in mediation.

d.        The  mediation  will  be  held  as  soon  as  practicable  after  the  negotiation  meeting  is  held.  The
mediator  will  be  free  to  meet  and  communicate  separately  with  each  party  either  before,  during  or  after  the
mediation meeting within 60 days of demand by either party.

16.2.        At  the  election  of  the  Franchisor,  the  provisions  of  this  Section  16  shall  not  apply  to  controversies
relating to any fee due the Franchisor by Developer or its affiliates, any promissory note payments due the Franchisor
by  Developer,  or  any  trade  payables  due  the  Franchisor  by  Developer  as  a  result  of  the  purchase  of  equipment,
goods or supplies. The provisions of this Section 16 shall also not apply to any controversies relating to the use and
protection  of  the  El  Pollo  Loco  Marks,  the  Manual  or  the  El  Pollo  Loco  System,  including  without  limitation,  the
Franchisor’s right to apply to any court of competent jurisdiction for appropriate injunctive relief for the infringement of
the El Pollo Loco Marks or the El Pollo Loco System.

17.    Severability.

17.1.    Each section, part, term and/or provision of this Agreement shall be considered severable, and if, for
any reason, any section, part, term and/or provision herein is determined to be invalid, contrary to, or in conflict with,
any existing or future law or regulation, by any court or agency having valid jurisdiction, then such shall be deemed
not  to  be  a  part  of  this  Agreement,  but  such  shall  not  impair  the  operation  of,  or  affect  the  remaining  portions,
sections,  parts,  terms  and/or  provisions  of  this  Agreement,  which  will  continue  to  be  given  full  force  and  effect  and
bind the parties hereto.

18.    Applicable Law; Choice of Forum; Waiver of Jury Trial.

18.1.        This  Agreement,  after  review  by  Developer  and  El  Pollo  Loco,  was  accepted  in  the  state  in  which
Franchisor’s  then-current  headquarters  (currently  the  State  of  California)  is  located  and  shall  be  governed  by  and
construed in accordance with the laws of such state, except that the provisions in Section 20.1 covering competition
following  the  expiration,  termination  or  assignment  of  this  Agreement  shall  be  governed  by  the  laws  of  the  state  in
which  the  breach  occurs.  THE  PARTIES  AGREE  THAT  ANY  ACTION  BROUGHT  BY  EITHER  PARTY  AGAINST
EACH OTHER IN ANY COURT, WHETHER FEDERAL OR STATE, WILL BE BROUGHT WITHIN THE STATE IN
WHICH  FRANCHISOR’S  HEADQUARTERS  (CURRENTLY  THE  STATE  OF  CALIFORNIA)  IS  THEN  LOCATED.
THE  PARTIES  HEREBY  WAIVE  ANY  RIGHT  TO  DEMAND  OR  HAVE  TRIAL  BY  JURY  IN  ANY  ACTION
RELATING TO THIS AGREEMENT IN WHICH THE FRANCHISOR IS A PARTY. THE PARTIES CONSENT TO THE
EXERCISE  OF  PERSONAL  JURISDICTION  OVER  THEM  BY  SUCH  COURTS  AND  TO  THE  PROPRIETY  OF
VENUE OF SUCH COURTS FOR THE PURPOSE OF CARRYING OUT THE PROVISION, AND THEY WAIVE ANY
OBJECTION  THAT  THEY  WOULD  OTHERWISE  HAVE  TO  THE  SAME.  ANY  ACTION  BETWEEN  DEVELOPER
AND  FRANCHISOR  SHALL  INVOLVE  ONLY  THE  INDIVIDUAL  CLAIMS  OF  DEVELOPER  AND  SHALL  NOT
INVOLVE ANY CLASS, GROUP, CONSOLIDATED, REPRESENTATIVE OR ASSOCIATIONAL ACTION. NOTHING
IN THIS SECTION 18.1 IS INTENDED BY THE PARTIES TO SUBJECT THIS AGREEMENT TO ANY FRANCHISE

OR  SIMILAR  LAW,  RULE  OR  REGULATION  TO  WHICH  THIS  AGREEMENT  WOULD  NOT  OTHERWISE  BE
SUBJECT.

19.    Document Interpretation.

19.1.    All terms and words used in this Agreement, regardless of the number and gender in which they are
used,  shall  be  deemed  and  construed  to  include  the  singular  or  plural  tense,  and  any  gender,  whether  masculine,
feminine or neuter, as the context or sense of this Agreement or any paragraph or clause may require, the same as if
such words had been fully and properly written in the appropriate number or gender. In the event of a conflict in the
language,  terms,  or  conditions  between  this  Agreement  and  any  Franchise  Agreement  issued  pursuant  to  this
Agreement, the Franchise Agreement shall control.

20.    Covenant Not to Compete.

20.1.        To  further  protect  the  El  Pollo  Loco®  System  while  this  Agreement  is  in  effect,  Developer  and  each
officer,  director,  shareholder,  member,  manager,  partner  and  other  equity  owner,  as  applicable,  of  Developer,  if
Developer is an entity, shall neither directly nor indirectly own, operate, control or any financial interest in any other
business which would constitute a “Competitive Business” (as hereinafter defined) without the prior written consent
of  Franchisor;  provided  further,  that  Franchisor  may,  as  its  sole  and  absolute  right,  consent  to  the  Developer’s
continued operation of any business already in existence and operating at the time of execution of this Agreement. In
addition, Developer covenants that, except as otherwise approved in writing by the Franchisor, Developer shall not,
for a continuous, uninterrupted period commencing upon the expiration, termination or assignment of this Agreement,
regardless  of  the  cause  for  termination,  and  continuing  for  two  (2)  years  thereafter,  either  directly  or  indirectly,  for
itself,  or  through  or  on  behalf  of,  or  in  conjunction  with  any  person,  partnership,  corporation  or  other  entity,  own,
operate,  control  or  have  any  financial  interest  in  any  Competitive  Business  which  is  located  or  has  outlets  or
restaurant  units  within  the  Territory.  The  foregoing  shall  not  apply  to  operation  of  an  El  Pollo  Loco®  restaurant  by
Developer  pursuant  to  a  Franchise  Agreement  with  Franchisor  or  the  ownership  by  Developer  of  less  than  five
percent  (5%)  of  the  issued  or  outstanding  stock  of  any  company  whose  shares  are  listed  for  trading  on  any  public
exchange  or  on  the  over-the-counter  market,  provided  that  Developer  does  not  control  or  become  involved  in  the
operations of any such company. For purposes of this Section 20.1, a Competitive Business shall mean a self-service
restaurant  or  fast-food  business  which  sells  chicken  and/or  Mexican  food  products,  which  products  individually  or
collectively represent more than twenty percent (20%) of the revenues from such self-service restaurant or fast-food
business  operated  at  any  one  location  during  any  calendar  quarter.  A  “Competitive Business”  shall  not  include  a
full-service restaurant.

20.2.        In  the  event  that  any  provision  of  Section  20.1  above  shall  be  determined  by  a  court  of  competent
jurisdiction to be invalid or unenforceable, this Agreement shall not be void, but such provision shall be limited to the
extent necessary to make it valid and enforceable.

20.3.    Developer understands and acknowledges that Franchisor shall have the right to reduce the scope of
any obligation imposed on Developer by Section 20.1, without Developer’s consent, and that such modified provision
shall be effective upon Developer’s receipt of written notice thereof.

20.4.       Developer  acknowledges  that  violation  of  the  covenants  not  to  compete  contained  in  this  Agreement
would result in immediate and irreparable injury to Franchisor for which no adequate remedy at law will be available.
Accordingly,  Developer  hereby  consents  to  the  entry  of  a  preliminary  and  permanent  injunction  prohibiting  any
conduct  by  Developer  in  violation  of  the  terms  of  those  covenants  not  to  compete  set  forth  in  this  Agreement.
Developer expressly agrees that it may conclusively be presumed that any violation of the terms of said covenants
not  to  compete  was  accomplished  by  and  through  Developer’s  unlawful  utilization  of  Franchisor’s  Confidential
Information, know-how, methods and procedures

21.    Notices.

21.1.    For the purpose of this Agreement, all notices shall be in writing and shall be sent to the party to be
charged with receipt thereof either (i) served personally, or (i) sent by certified or registered United States mail, or (ii)
sent  by  reputable  overnight  delivery  service,  or  (iv)  sent  by  facsimile.  Notices  served  personally  are  effective
immediately on delivery, and those served by mail shall be deemed given forty-eight (48) hours after deposit of such
notice in a United States post office with postage prepaid and duly addressed to the party to whom such notice or
communication is directed. Notices served by overnight delivery shall be deemed to have been given the day after
deposit of such notice with such service. Notices served via facsimile shall be deemed to have been given the day of
faxing such notice. All notices to El Pollo Loco® shall be addressed as follows:

El Pollo Loco, Inc.

Attn: Legal Department
3535 Harbor Blvd, Suite 100
Costa Mesa, CA 92626
(714) 599-5503 (fax)

21.2.        All  notices  to  Developer  shall  be  faxed  and  mailed  or  sent  via  overnight  service  to  the  Developer's
number and address shown on Exhibit "B". Either party may from time to time change its address for the purposes
of  this  Section  by  giving  written  notice  of  such  change  to  the  other  party  in  the  manner  provided  in  this  Section.
Notwithstanding  anything  to  the  contrary  contained  herein,  the  Franchisor  may  deliver  bulletins  and  updates  to  the
Developer by electronic means, such as by the internet (e-mail) or an intranet, if any, established by Franchisor.

22.    Section Headings.

22.1.    The section headings appearing in this Agreement are for reference purposes only and shall not affect,

in any way, the meaning or interpretation of this Agreement.

23.    Acknowledgments.

23.1.        Developer  acknowledges  that  it  has  received  a  complete  copy  of  the  El  Pollo  Loco®  Franchise
Disclosure Document, issuance date March 26, 2019 (Control No. 032619) at least fourteen (14) calendar days prior
to the date on which this Agreement was executed by Developer or payment of any monies to the Franchisor.

23.2.    Developer acknowledges that it has read and understands this Agreement, the Franchise Agreement,
the  attachments  thereto  and  the  agreements  relating  thereto  contained  in  the  Franchise  Disclosure  Document
received  by  Developer  on  _____,20__,  and  that  Franchisor  has  accorded  Developer  ample  opportunity  and  has
encouraged Developer to consult with advisors of Developer's own choosing about the potential benefits and risks of
entering into this Agreement.

24.    Counterparts.

24.1.        This  Agreement  may  be  executed  in  two  or  more  counterparts,  each  of  which  shall  be  deemed  an
original but all of which together shall constitute a single instrument. A signature on this Agreement transmitted via
facsimile or electronic mail shall be considered an original for all purposes hereunder.

IN  WITNESS  WHEREOF,  the  parties  hereto  have  duly  executed,  sealed  and  delivered  this  Agreement  in

duplicate original as of the dates set forth below.

FRANCHISOR:
EL POLLO LOCO, INC., a Delaware Corporation
By:
Name:
Title:
Date:

DEVELOPER:
____________________________, an individual
By:
Name:
Title:
Date:

An individual

25.    EXHIBIT "A" TO DEVELOPMENT AGREEMENT - TERRITORY

EXHIBIT "B" TO DEVELOPMENT AGREEMENT - DEVELOPMENT SCHEDULE

DEVELOPER NAME:
PRINCIPALS:
NOTICE ADDRESS:
FAX NUMBER:
EMAIL:
COMMENCEMENT DATE:
EXPIRATION DATE:
DEVELOPMENT FEE (SECTION 3):

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
DEVELOPMENT SCHEDULE:

INITIAL FRANCHISEE
AMOUNT

RESAC SUBMITTAL
DATES

SITE COMMITMENT
DATES
(Date for delivery of
signed leases or
purchase
agreements)

OPENING DATE
OF RESTAURANT

Restaurant # 1
Restaurant # 2
Restaurant # 3

$40,000.00
$30,000.00
$30,000.00

EXHIBIT “C” TO DEVELOPMENT AGREEMENT - EXISTING EL POLLO LOCO® RESTAURANTS IN THE
TERRITORY

 
 
 
 
 
 
 
 
 
 
    
EL POLLO LOCO HOLDINGS, INC.
2018 OMNIBUS EQUITY INCENTIVE PLAN
RESTRICTED SHARE AGREEMENT 
EMPLOYEE

Exhibit 10.24

This Restricted Share Award Agreement (this “Restricted Share Agreement”), dated as of __________, 2020
(the “Date of Grant”), is made by and between El Pollo Loco Holdings, Inc., a Delaware corporation (the “Company”) and
_____________ (the “Employee”). Capitalized terms not defined herein shall have the meaning ascribed to them in the El Pollo
Loco Holdings, Inc. 2018 Omnibus Equity Incentive Plan (as amended from time to time, the “Plan”). Where the context
permits, references to the Company shall include any successor to the Company.

Grant of Restricted Shares. The Company hereby grants to the Employee ___________ Shares (such
shares, the “Restricted Shares”), subject to all of the terms and conditions of this Restricted Share Agreement and the Plan.

1.

2.    Lapse of Restrictions.

(a)    Vesting. Except as otherwise set forth in this Section 2(a), the restrictions on Transfer (as defined in

Section 6(a)) set forth in Section 2(b) shall lapse with respect to 1/4 of the Restricted Shares on each of the first four
anniversaries of the Date of Grant (each anniversary of the Date of Grant, a “Vesting Date”), subject to the continued
employment of the Employee with the Company from the date hereof through the applicable Vesting Date, and provided that the
Employee has not given notice of resignation as of such Vesting Date.

(b)    Restrictions. Until the restrictions on Transfer of the Restricted Shares lapse as provided in Section

2(a), or as otherwise provided in the Plan, no Transfer of the Restricted Shares or any of the Employee’s rights with respect to the
Restricted Shares, whether voluntary or involuntary, by operation of law or otherwise, shall be permitted. Unless the
Administrator determines otherwise, upon any attempt to Transfer Restricted Shares or any rights in respect of Restricted Shares,
before the lapse of such restrictions, such Restricted Shares, and all of the rights related thereto, shall be immediately canceled
and forfeited.

(c)    Termination of Service. Upon termination of the Employee’s service with the Company and its
Affiliates for any reason (including the death or Disability of the Employee), any Restricted Shares in respect of which the
restrictions on Transfer described in this Section 2 shall not already have lapsed shall be immediately canceled and forfeited and
neither the Employee nor any of the Employee’s successors, heirs, assigns, or personal representatives shall thereafter have any
further rights or interests in such Restricted Shares.

3.    Adjustments. Pursuant to Section 5 of the Plan, in the event of a Change in Capitalization, the Administrator
shall make such equitable changes or adjustments to the number and kind of securities or other property (including cash) issued
or issuable in respect of outstanding Restricted Shares as it determines to be necessary in its sole discretion.

4.    Certain Changes. The Administrator may accelerate the date on which the restrictions on transfer set forth in

Section 2(a) shall lapse or otherwise adjust any of the terms of the Restricted Shares; provided that, subject to Section 5 of the
Plan, no action under this Section shall adversely affect the Employee’s rights hereunder.

5.    Notices. All notices and other communications under this Restricted Share Agreement shall be in writing and

shall be given by facsimile or first class mail, certified or registered with return receipt requested, and shall be deemed to have
been duly given three days after mailing or 24 hours after transmission by facsimile to the respective parties, as follows: (i) if to
the Company, addressed to the Company in care of its Vice President, Legal at the principal executive office of the Company and
(ii) if to the Employee, using the contact information on file with the Company. Either party hereto may change such party’s
address for notices by notice duly given pursuant hereto.

6.    Transferability.

(a)    Until such time as the Restricted Shares are fully vested in accordance with Section 2(a), no purported
sale, assignment, mortgage, hypothecation, transfer, charge, pledge, encumbrance, gift, transfer in trust (voting or other) or other
disposition of, or

-2-

creation of a security interest in or lien on, any of the Restricted Shares or any agreement or commitment to do any of the
foregoing (each a “Transfer”) by any holder thereof in violation of the provisions of this Restricted Share Agreement will be
valid, except with the prior written consent of the Administrator (such consent shall be granted or withheld in the sole discretion
of the Administrator).

(b)    In addition to Section 2(b), any purported Transfer of Restricted Shares or any economic benefit or

interest therein in violation of this Restricted Share Agreement shall be null and void ab initio, and shall not create any obligation
or liability of the Company, and any person purportedly acquiring any Restricted Shares or any economic benefit or interest
therein transferred in violation of this Restricted Share Agreement shall not be entitled to be recognized as a holder of such
Shares.

7.    Withholding Taxes. The Company shall be entitled to require a cash payment by or on behalf of the Employee

and/or to deduct from any compensation payable to the Employee the amount of any sums required by federal, state or local tax
law to be withheld with respect to the Restricted Shares, up to the maximum statutory tax rates in the Employee’s jurisdiction, as
determined by the Company.

8.    Section 83(b) Election. If the Employee makes an election under Section 83(b) of the Code, or any successor

section thereto, to be taxed with respect to the Restricted Shares as of the Date of Grant, the Employee shall deliver a copy of
such election to the Company immediately after filing such election with the Internal Revenue Service, together with any
required tax withholding. The Employee hereby acknowledges that it is the Employee’s sole responsibility, and not the
Company’s, to file timely the election under Section 83(b) of the Code. A form of such election is attached hereto as Exhibit A.

THE EMPLOYEE ACKNOWLEDGES THAT IT IS THE EMPLOYEE’S SOLE RESPONSIBILITY AND NOT THE
COMPANY’S  TO  FILE  TIMELY  THE  ELECTION  UNDER  SECTION  83(b)  OF  THE  CODE,  EVEN  IF  THE
EMPLOYEE  REQUESTS  THE  COMPANY  OR  ITS  REPRESENTATIVE  TO  MAKE  THIS  FILING  ON  THE
EMPLOYEE’S BEHALF.

9.    Governing Law. This Restricted Share Award Agreement shall be governed by and construed and enforced in
accordance with the laws of the State of Delaware applicable to contracts made and to be performed therein. Any suit, action or
proceeding with respect to this Restricted Share Agreement, or any judgment entered by any court in respect of any thereof, shall
be brought in any court of competent jurisdiction in the State of Delaware, and the Company and the Employee hereby submit to
the exclusive jurisdiction of such courts for the purpose of any such suit, action, proceeding or judgment. The Employee and the
Company hereby irrevocably waive (i) any objections which it may now or hereafter have to the laying of the venue of any suit,
action or proceeding arising out of or relating to this Restricted Share Agreement brought in any court of competent jurisdiction
in the State of Delaware, (ii) any claim that any such suit, action or proceeding brought in any such court has been brought in any
inconvenient forum and (iii) any right to a jury trial.

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10.    Incorporation of Plan. The Plan is hereby incorporated by reference and made a part hereof, and the

Restricted Shares and this Restricted Share Agreement shall be subject to all terms and conditions of the Plan and this Restricted
Share Agreement.

11.    Amendments; Construction. The Administrator may amend the terms of this Restricted Share Agreement

prospectively or retroactively at any time, but no such amendment shall impair the rights of the Employee hereunder without his
or her consent. Headings to Sections of this Restricted Share Agreement are intended for convenience of reference only, are not
part of this Restricted Share Agreement and shall have no effect on the interpretation hereof.

12.    Survival of Terms. This Restricted Share Agreement shall apply to and bind the Employee and the Company

and their respective permitted assignees and transferees, heirs, legatees, executors, administrators and legal successors.

13.    Rights as a Shareholder. During the period until the restrictions on Transfer of the Restricted Shares lapse as

provided in Section 2(a), the Employee shall have all the rights of a shareholder with respect to the Restricted Shares save only
the right to Transfer the Restricted Shares. Accordingly, the Employee shall have the right to vote the Restricted Shares and to
receive any ordinary dividends paid to or made with respect to the Restricted Shares.

14.    Agreement Not a Contract for Services. Neither the Plan, the granting of the Restricted Shares, this

Restricted Share Agreement nor any other action taken pursuant to the Plan shall constitute or be evidence of any agreement or
understanding, express or implied, that the Employee has a right to continue to be employed as an officer, director, employee,
consultant or advisor of the Company or any Subsidiary or Affiliate for any period of time or at any specific rate of
compensation.

15.    Authority of the Administrator; Disputes. The Administrator shall have full authority to interpret and

construe the terms of the Plan and this Restricted Share Agreement. The determination of the Administrator as to any such matter
of interpretation or construction shall be final, binding and conclusive.

16.    Waiver.  The Employee acknowledges that a waiver by the Company of a breach of any provision of this

Restricted Share Agreement shall not operate or be construed as a waiver of any other provision of this Restricted Share
Agreement, or of any subsequent breach by the Employee.

17.    Severability. Should any provision of this Restricted Share Agreement be held by a court of competent

jurisdiction to be unenforceable, or enforceable only if modified, such holding shall not affect the validity of the remainder of this
Restricted Share Agreement, the balance of which shall continue to be binding upon the parties hereto with any such modification
(if any) to become a part hereof and treated as though contained in this Restricted Share Agreement.

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18.    Acceptance. The Employee hereby acknowledges receipt of a copy of the Plan and this Restricted Share

Agreement. The Employee has read and understands the terms and provisions of the Plan and this Restricted Share Agreement,
and accepts the Restricted Shares subject to all the terms and conditions of the Plan and this Restricted Share Agreement. The
Employee hereby agrees to accept as binding, conclusive and final all decisions or interpretations of the Administrator upon any
questions arising under this Restricted Share Agreement.

19.    Clawback.  The Restricted Shares are subject to such recoupment policies of the Company as may be in

effect from time to time pursuant to Section 28 the Plan.

[Signature Page Follows]

IN WITNESS WHEREOF, the parties hereto have executed and delivered this Restricted Share Agreement on the

day and year first above written.

EL POLLO LOCO HOLDINGS, INC.

By     
Name     
Title     

EMPLOYEE

___________________________________

EXHIBIT A
ELECTION UNDER SECTION 83(b)

The undersigned taxpayer hereby elects, pursuant to Section 83(b) of the Internal Revenue Code of 1986, as amended, to include in taxpayer’s gross
income for the current taxable year the amount of any compensation taxable to taxpayer in connection with taxpayer’s receipt of the property
described below:

1.    The name address, taxpayer identification number and taxable year of the undersigned are as follows:

NAME OF TAXPAYER:                                 

NAME OF SPOUSE:                                     

ADDRESS:                                         

IDENTIFICATION NO. OF TAXPAYER:                         

IDENTIFICATION NUMBER OF SPOUSE:                         

TAXABLE YEAR:                                     

$0.01 per share, of El Pollo Loco Holdings, Inc., a Delaware corporation (the “Company”).

2.    The property with respect to which the election is made is described as follows: _______ shares of Common Stock, par value

3.    The date on which the property was transferred is: ________________, 20__.

4.    The property is subject to the following restrictions: The property may not be transferred and is subject to forfeiture under the

terms of an agreement between the taxpayer and the Company. These restrictions lapse upon the satisfaction of certain conditions in such
agreement.

terms will never lapse, of such property is: $ ______________.

5.    The fair market value at the time of transfer, determined without regard to any restriction other than a restriction which by its

6.    The amount (if any) paid for such property is: $ ______________.

The undersigned has submitted a copy of this statement to the person for whom the services were performed in connection with the undersigned’s
receipt of the above-described property. The transferee of such property is the person performing the services in connection with the transfer of said
property.

The undersigned understands that the foregoing election may not be revoked except with the consent of the Commissioner.

Dated: _________________, 20__        

Taxpayer

The undersigned spouse of taxpayer joins in this election.

Dated: _________________, 20__        

Spouse of Taxpayer

-5-

EL POLLO LOCO HOLDINGS, INC.
2018 OMNIBUS EQUITY INCENTIVE PLAN
RESTRICTED SHARE AGREEMENT

NON-OFFICER DIRECTOR

Exhibit 10.25

This Restricted Share Award Agreement (this “Restricted Share Agreement”), dated as of ____________,

______ (the “Date of Grant”), is made by and between El Pollo Loco Holdings, Inc., a Delaware corporation (the “Company”)
and _______________ (the “Non-Officer Director”). Capitalized terms not defined herein shall have the meaning ascribed to
them in the El Pollo Loco Holdings, Inc. 2018 Omnibus Equity Incentive Plan (as amended from time to time, the “Plan”).
Where the context permits, references to the Company shall include any successor to the Company.

1.

Grant of Restricted Shares. The Company hereby grants to the Non-Officer Director ___________

Shares (such shares, the “Restricted Shares”), subject to all of the terms and conditions of this Restricted Share Agreement and
the Plan.

2.    Lapse of Restrictions.

(a)    General. Except as otherwise set forth in this Section 2, the restrictions on Transfer (as defined in

Section 6(a)) set forth in Section 2 shall lapse with respect to 1/3 of the Restricted Shares on each of the first three anniversaries
of the Date of Grant (each anniversary of the Date of Grant, a “Vesting Date”), subject to the continued service of the Non-
Officer Director for the Company from the date hereof through the applicable Vesting Date, and provided that the Non-Officer
Director has not given notice of resignation as of such Vesting Date.

(b)    Following Certain Terminations of Service. Subject to the next sentence, upon termination of the

Non-Officer Director’s service with the Company and its Affiliates for any reason (including the death or Disability of the Non-
Officer Director), any Restricted Shares in respect of which the restrictions on Transfer described in this Section 2 shall not
already have lapsed shall be canceled and immediately forfeited and neither the Non-Officer Director nor any of the Non-Officer
Director’s successors, heirs, assigns, or personal representatives shall thereafter have any further rights or interests in such
Restricted Shares. Notwithstanding the foregoing:

(x)    in the event that the Non-Officer Director’s service with the Company is terminated without Cause, then

100% of the Restricted Shares that are not vested as of the date of such termination shall immediately vest on the date of
such termination of service, and the restrictions on Transfer of such Restricted Shares set out in this Section 2 shall lapse;
provided that if such termination occurs prior to a Change in Control, then such vesting will be subject to the Non-Officer
Director’s execution of a separation agreement prepared by the Company (or any Subsidiary of Affiliate) which includes,
inter alia, a general release of claims; and

(y)    in the event that the Non-Officer Director’s service with the Company is terminated as a result of the death or

Disability of the Non-Officer Director, then 100% of the Restricted Shares that are not vested as of the date of such
termination shall immediately vest, and the restrictions on Transfer of such Restricted Shares set out in this Section 2 shall
lapse.

(c)    Restrictions. Until the restrictions on Transfer of the Restricted Shares lapse as provided in this

Section 2, or as otherwise provided in the Plan, no Transfer of the Restricted Shares or any of the Non-Officer Director’s rights
with respect to the Restricted Shares, whether voluntary or involuntary, by operation of law or otherwise, shall be permitted.
Unless the Administrator determines otherwise, upon any attempt to Transfer Restricted Shares or any rights in respect of
Restricted Shares, before the lapse of such restrictions, such Restricted Shares, and all of the rights related thereto, shall be
immediately canceled and forfeited.

3.    Adjustments. Pursuant to Section 5 of the Plan, in the event of a Change in Capitalization, the Administrator
shall make such equitable changes or adjustments to the number and kind of securities or other property (including cash) issued
or issuable in respect of outstanding Restricted Shares as it determines to be necessary in its sole discretion.

4.    Certain Changes. The Administrator may accelerate the date on which the restrictions on transfer set forth in

Section 2 shall lapse or otherwise adjust any of the terms of the Restricted Shares; provided that, subject to Section 5 of the Plan,
no action under this Section shall adversely affect the Non-Officer Director’s rights hereunder.

5.    Notices. All notices and other communications under this Restricted Share Agreement shall be in writing and

shall be given by facsimile or first class mail, certified or registered with return receipt requested, and shall be deemed to have
been duly given three days after mailing or 24 hours after transmission by facsimile to the respective parties, as follows: (i) if to
the Company, addressed to the Company in care of its Vice President, Legal at the principal executive office of the Company and
(ii) if to the Non-Officer Director, using the contact information on file with the Company. Either party hereto may change such
party’s address for notices by notice duly given pursuant hereto.

6.    Protections Against Violations of Agreement.

(a)    Until such time as the Restricted Shares are fully vested in accordance with Section 2, no purported

sale, assignment, mortgage, hypothecation, transfer, charge, pledge, encumbrance, gift, transfer in trust (voting or other) or other
disposition of, or creation of a security interest in or lien on, any of the Restricted Shares or any agreement or commitment to do
any of the foregoing (each a “Transfer”) by any holder thereof in violation of the provisions of this Restricted Share Agreement
will be valid, except with the prior written consent of the Administrator (such consent shall be granted or withheld in the sole
discretion of the Administrator).

interest therein in violation of this Restricted Share Agreement shall

(b)    In addition to Section 2, any purported Transfer of Restricted Shares or any economic benefit or

-2-

be null and void ab initio, and shall not create any obligation or liability of the Company, and any person purportedly acquiring
any Restricted Shares or any economic benefit or interest therein transferred in violation of this Restricted Share Agreement shall
not be entitled to be recognized as a holder of such Shares.

7.    Taxes.

(a)    The Non-Officer Director understands that he or she (and not the Company) shall be responsible for

any tax liability that may arise as a result of the transactions contemplated by this Restricted Share Agreement. The Company
shall not be required to withhold any amounts in respect of any such taxes.

Section 83(b) of the Code. A form of such election is attached hereto as Exhibit A.

(b)    The Non-Officer Director shall promptly notify the Company of any election made pursuant to

THE  NON-OFFICER  DIRECTOR  ACKNOWLEDGES  THAT  IT  IS  THE  NON-OFFICER  DIRECTOR’S  SOLE
RESPONSIBILITY AND NOT THE COMPANY’S TO FILE TIMELY THE ELECTION UNDER SECTION 83(b) OF
THE CODE, EVEN IF THE NON-OFFICER DIRECTOR REQUESTS THE COMPANY OR ITS REPRESENTATIVE
TO MAKE THIS FILING ON THE NON-OFFICER DIRECTOR’S BEHALF.

(c)    The Non-Officer Director acknowledges that the tax laws and regulations applicable to the Restricted

Shares and the disposition of the Restricted Shares following vesting are complex and subject to change, and it is the sole
responsibility of the Non-Officer Director to obtain his or her own advice as to the tax treatment of the terms of this Restricted
Share Agreement.

BY SIGNING THIS RESTRICTED SHARE AGREEMENT, THE NON-OFFICER DIRECTOR REPRESENTS THAT
HE OR SHE HAS REVIEWED WITH HIS OR HER OWN TAX ADVISORS THE FEDERAL, STATE, LOCAL AND
FOREIGN TAX CONSEQUENCES OF THE TRANSACTIONS CONTEMPLATED BY THIS RESTRICTED SHARE
AGREEMENT  AND  THAT  HE  OR  SHE  IS  RELYING  SOLELY  ON  SUCH  ADVISORS  AND  NOT  ON  ANY
STATEMENTS  OR  REPRESENTATIONS  OF  THE  COMPANY  OR  ANY  OF  ITS  AGENTS.  THE  NON-OFFICER
DIRECTOR  UNDERSTANDS  AND  AGREES  THAT  HE  OR  SHE  (AND  NOT  THE  COMPANY)  SHALL  BE
RESPONSIBLE  FOR  ANY  TAX  LIABILITY  THAT  MAY  ARISE  AS  A  RESULT  OF  THE  TRANSACTIONS
CONTEMPLATED BY THIS RESTRICTED SHARE AGREEMENT.

-3-

8.    Failure to Enforce Not a Waiver. The failure of the Company to enforce at any time any provision of this
Restricted Share Agreement shall in no way be construed to be a waiver of such provision or of any other provision hereof.

9.    Confidentiality.

(a)    The Non-Officer Director acknowledges that during the period of the Non-Officer Director’s service

with the Company the Non-Officer Director shall have access to the Company’s Confidential Information (as defined below). All
books of account, records, systems, correspondence, documents, and any and all other data, in whatever form, concerning or
containing any reference to the works and business of the Company or its affiliated companies shall belong to the Company and
shall be given up to the Company whenever the Company requires the Non-Officer Director to do so. The Non-Officer Director
agrees that the Non-Officer Director shall not at any time during the term of the Non-Officer Director’s service or thereafter,
without the Company’s prior written consent, disclose to any person (individual or entity) any information or any trade secrets,
plans or other information or data, in whatever form, (including, without limitation, (i) any financing strategies and practices,
pricing information and methods, training and operational procedures, advertising, marketing, and sales information or
methodologies or financial information and (ii) any Proprietary Information (as defined below)), concerning the Company’s or
any of its affiliated companies’ or customers’ practices, businesses, procedures, systems, plans or policies (collectively,
“Confidential Information”), nor shall the Non-Officer Director utilize any such Confidential Information in any way or
communicate with or contact any such customer other than in connection with the Non-Officer Director’s service by the
Company. The Non-Officer Director hereby confirms that all Confidential Information constitutes the Company’s exclusive
property, and that all of the restrictions on the Non-Officer Director’s activities contained in this Restricted Share Agreement and
such other nondisclosure policies of the Company are required for the Company’s reasonable protection. Confidential
Information shall not include any information that has otherwise been disclosed to the public not in violation of this Restricted
Share Agreement. This confidentiality provision shall survive the termination of this Restricted Share Agreement and shall not be
limited by any other confidentiality agreements entered into with the Company or any of its affiliates.

(b)    With respect to any Confidential Information that constitutes a “trade secret” pursuant to applicable
law, the restrictions described above shall remain in force for so long as the particular information remains a trade secret or for
the two-year period immediately following termination of the Non-Officer Director’s service for any reason, whichever is longer.
With respect to any Confidential Information that does not constitute a “trade secret” pursuant to applicable law, the restrictions
described above shall remain in force during the Non-Officer Director’s service and for the two-year period immediately
following termination of Non-Officer Director’s service for any reason.

(c)    The Non-Officer Director agrees that the Non-Officer Director shall promptly disclose to the

Company in writing all information and inventions generated, conceived or first reduced to practice by the Non-Officer Director
alone or in conjunction with others, during or after working hours, while in the employ of the Company (all of which is
collectively

-4-

referred to in this Restricted Share Agreement as “Proprietary Information”); provided, however, that such Proprietary
Information shall not include (i) any information that has otherwise been disclosed to the public not in violation of this Restricted
Share Agreement and (ii) general business knowledge and work skills of the Non-Officer Director, even if developed or
improved by the Non-Officer Director while in the employ of the Company. All such Proprietary Information shall be the
exclusive property of the Company and is hereby assigned by the Non-Officer Director to the Company. The Non-Officer
Director’s obligation relative to the disclosure to the Company of such Proprietary Information anticipated in this Section shall
continue beyond the Non-Officer Director’s termination of service and the Non-Officer Director shall, at the Company’s expense,
give the Company all assistance it reasonably requires to perfect, protect and use its right to the Proprietary Information.

-5-

(d)    Defend Trade Secrets Act. Pursuant to Section 1833(b) of the Defend Trade Secrets Act of 2016, the

Non-Officer Director acknowledges that the Non-Officer Director shall not have criminal or civil liability under any federal or
State trade secret law for the disclosure of a trade secret that is made in confidence to a federal, state, or local government
official, either directly or indirectly, or to an attorney and solely for the purpose of reporting or investigating a suspected violation
of law; or that is made in a complaint or other document filed in a lawsuit or other proceeding, if such filing is made under seal.
Nothing in this Restricted Share Agreement is intended to conflict with Section 1833(b) of the Defend Trade Secrets Act of 2016
or create liability for disclosures of trade secrets that are expressly allowed by such Section. Notwithstanding anything set forth in
this Restricted Share Agreement to the contrary, the Non-Officer Director shall not be prohibited from reporting possible
violations of federal or state law or regulation to any governmental agency or entity or making other disclosures that are protected
under the whistleblower provisions of federal or state law or regulation, nor is the Non-Officer Director required to notify the
Company regarding any such reporting, disclosure or cooperation with the government.

10.    Governing Law. This Restricted Share Award Agreement shall be governed by and construed and enforced in

accordance with the laws of the State of Delaware applicable to contracts made and to be performed therein. Any suit, action or
proceeding with respect to this Restricted Share Agreement, or any judgment entered by any court in respect of any thereof, shall
be brought in any court of competent jurisdiction in the State of Delaware, and the Company and the Non-Officer Director hereby
submit to the exclusive jurisdiction of such courts for the purpose of any such suit, action, proceeding or judgment. The Non-
Officer Director and the Company hereby irrevocably waive (i) any objections which it may now or hereafter have to the laying
of the venue of any suit, action or proceeding arising out of or relating to this Restricted Share Agreement brought in any court of
competent jurisdiction in the State of Delaware, (ii) any claim that any such suit, action or proceeding brought in any such court
has been brought in any inconvenient forum and (iii) any right to a jury trial.

11.    Incorporation of Plan. The Plan is hereby incorporated by reference and made a part hereof, and the

Restricted Shares and this Restricted Share Agreement shall be subject to all terms and conditions of the Plan and this Restricted
Share Agreement.

12.    Amendments; Construction. The Administrator may amend the terms of this Restricted Share Agreement

prospectively or retroactively at any time, but no such amendment shall impair the rights of the Non-Officer Director hereunder
without his or her consent. To the extent the terms of Section 9 conflict with any prior agreement between the parties related to
such subject matter, the terms of Section 9 shall supersede such conflicting terms and control. Headings to Sections of this
Restricted Share Agreement are intended for convenience of reference only, are not part of this Restricted Share Agreement and
shall have no effect on the interpretation hereof.

13.    Survival of Terms. This Restricted Share Agreement shall apply to and bind the Non-Officer Director and the
Company and their respective permitted assignees and transferees, heirs, legatees, executors, administrators and legal successors.

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14.    Rights as a Shareholder. During the period until the restrictions on Transfer of the Restricted Shares lapse as

provided in Section 2, the Non-Officer Director shall have all the rights of a shareholder with respect to the Restricted Shares
save only the right to Transfer the Restricted Shares. Accordingly, the Non-Officer Director shall have the right to vote the
Restricted Shares and to receive any ordinary dividends paid to or made with respect to the Restricted Shares.

15.    Agreement Not a Contract for Services. Neither the Plan, the granting of the Restricted Shares, this

Restricted Share Agreement nor any other action taken pursuant to the Plan shall constitute or be evidence of any agreement or
understanding, express or implied, that the Non-Officer Director has a right to continue to provide services as an officer, director,
employee, consultant or advisor of the Company or any Subsidiary or Affiliate for any period of time or at any specific rate of
compensation.

16.    Authority of the Administrator; Disputes. The Administrator shall have full authority to interpret and

construe the terms of the Plan and this Restricted Share Agreement. The determination of the Administrator as to any such matter
of interpretation or construction shall be final, binding and conclusive.

17.    Severability. Should any provision of this Restricted Share Agreement be held by a court of competent

jurisdiction to be unenforceable, or enforceable only if modified, such holding shall not affect the validity of the remainder of this
Restricted Share Agreement, the balance of which shall continue to be binding upon the parties hereto with any such modification
(if any) to become a part hereof and treated as though contained in this Restricted Share Agreement.

18.    Acceptance. The Non-Officer Director hereby acknowledges receipt of a copy of the Plan and this Restricted

Share Agreement. The Non-Officer Director has read and understands the terms and provisions of the Plan and this Restricted
Share Agreement, and accepts the Restricted Shares subject to all the terms and conditions of the Plan and this Restricted Share
Agreement. The Non-Officer Director hereby agrees to accept as binding, conclusive and final all decisions or interpretations of
the Administrator upon any questions arising under this Restricted Share Agreement.

[Signature Page Follows]

IN WITNESS WHEREOF, the parties hereto have executed and delivered this Restricted Share Agreement on the

day and year first above written.

EL POLLO LOCO HOLDINGS, INC.

By     
Name     
Title     

NON-OFFICER DIRECTOR

___________________________________

EXHIBIT A
ELECTION UNDER SECTION 83(b)

The undersigned taxpayer hereby elects, pursuant to Section 83(b) of the Internal Revenue Code of 1986, as amended, to include in taxpayer’s gross
income for the current taxable year the amount of any compensation taxable to taxpayer in connection with taxpayer’s receipt of the property
described below:

1.    The name address, taxpayer identification number and taxable year of the undersigned are as follows:

NAME OF TAXPAYER:                                 

NAME OF SPOUSE:                                     

ADDRESS:                                         

IDENTIFICATION NO. OF TAXPAYER:                         

                                                                          
             
IDENTIFICATION NUMBER OF SPOUSE:                         

TAXABLE YEAR:                                     

2.    The property with respect to which the election is made is described as follows: _______ shares of Common Stock, par value

$0.01 per share, of El Pollo Loco Holdings, Inc., a Delaware corporation (the “Company”).

3.    The date on which the property was transferred is: ________________, 20__.

4.    The property is subject to the following restrictions: The property may not be transferred and is subject to forfeiture under the

terms of an agreement between the taxpayer and the Company. These restrictions lapse upon the satisfaction of certain conditions in such
agreement.

terms will never lapse, of such property is: $ ______________.

5.    The fair market value at the time of transfer, determined without regard to any restriction other than a restriction which by its

6.    The amount (if any) paid for such property is: $ ______________.

The undersigned has submitted a copy of this statement to the person for whom the services were performed in connection with the undersigned’s
receipt of the above-described property. The transferee of such property is the person performing the services in connection with the transfer of said
property.

The undersigned understands that the foregoing election may not be revoked except with the consent of the Commissioner.

Dated: _________________, 20__        

Taxpayer

The undersigned spouse of taxpayer joins in this election.

Dated: _________________, 20__        

Spouse of Taxpayer

-7-

EL POLLO LOCO HOLDINGS, INC. 
RESTRICTED SHARE UNIT AWARD AGREEMENT

Exhibit 10.26

You (the "Participant') are hereby awarded restricted share units (the "RSUs"), pursuant to the El Pollo Loco Holdings,

Inc. (the "Company") 2018 Omnibus Equity Incentive Plan (the "Plan"), on the terms and conditions in this Restricted Share
Unit Award Agreement (this "Award Agreement ") and on the terms and conditions in the Plan that are incorporated herein by
reference.

WHEREAS, pursuant to that certain Employment Agreement by and between the Company and the Participant, dated as

of __________________ (the "Employment Agreement "), the Company has agreed to make this grant to the Participant;

WHEREAS, capitalized terms used but not otherwise defined herein shall have the meanings set forth in the Plan.

NOW THEREFORE, in consideration of the mutual covenants hereinafter set forth, the parties agree as follows:

1.

Specific Terms. The RSUs shall have the following terms:

Name of Participant:

Number of RSUs:    

Award Date:    

Vesting

Settlement

The RSUs shall vest in four (4) equal installments on each of the first four (4) anniversaries of the
Award Date, subject to the terms and conditions of the Plan.

Each RSU shall be settled by the delivery of one (1) share of Common Stock to the Participant within
thirty (30) calendar days following the date on which such RSU becomes vested in accordance with
this Award Agreement.

2.
RSUs shall, to the extent not then vested, be forfeited upon such termination of employment for no consideration.

Termination of Employment. If the Participant's employment with the Company is terminated for any reason, the

Delivery of Shares of Common Stock. The shares of Common Stock deliverable upon the settlement of the RSUs may

3.
be either previously authorized but unissued shares of Common Stock or issued shares of Common Stock that have then been
reacquired by the Company. Such shares of Common Stock shall be fully paid and nonassessable.

4.

No Right to Continued Employment. The granting of the RSUs evidenced hereby and this Award Agreement shall
impose no obligation on the Company or any Affiliate to continue the employment of the Participant and shall not lessen
or affect the Company's or any Affiliate's right to terminate the employment of the Participant.

5.
Legend on Certificates. The certificates, if any, or book entries representing the shares of Common Stock deliverable
pursuant to this Award Agreement shall be subject to such stop transfer orders and other restrictions as the Administrator or its
delegate reasonably deems advisable under the Plan or the rules, regulations, and other requirements of the Securities and
Exchange Commission, any stock exchange upon which such shares of Common Stock are listed, and any applicable Federal or
state laws, and the Administrator or such other party may cause a legend or legends to be put on any such certificates or to be
notated on the stock register to make appropriate reference to such restrictions.

6.

Transferability.

(a)    The RSUs may not be assigned, alienated, pledged, attached, sold or otherwise transferred or encumbered by the

Participant other than by will or by the laws of descent and distribution, and any such purported assignment, alienation, pledge,
attachment, sale, transfer or encumbrance in contravention of the foregoing shall be void and unenforceable against the
Company or any Affiliate; provided, that the designation of a beneficiary shall not constitute an assignment, alienation, pledge,
attachment, sale, transfer or encumbrance. No such permitted transfer of the RSUs to heirs or legatees of the Participant shall be
effective to bind the Company unless the Administrator shall have been furnished with written notice thereof and a copy of such
evidence as the Administrator may deem necessary to establish the validity of the transfer and the acceptance by the transferee
or transferees of the terms and conditions hereof.

(b)    The RSUs shall not be liable for the debts, contracts or engagements of the Participant or the Participant's successors

in interest and shall not be subject to disposition by transfer, alienation, anticipation, pledge, hypothecation, encumbrance,
assignment or any other means whether such disposition be voluntary or involuntary or by operation of law or by judgment,
levy, attachment, garnishment or any other legal or equitable proceedings (including bankruptcy), and any attempted disposition
thereof shall be null and void and of no effect, except to the extent that such disposition is permitted by Section 6(a) hereof.

Withholding. The Participant may be required to pay to the Company or any Affi liate and the Company shall have the

7.
right and is hereby authorized to withhold from any payment due or transfer made under the RSUs or from any compensation
(including base salary) or other amount owing to the Participant the amount (in cash, shares of Common Stock, other securities
or other property) of any applicable withholding taxes in respect of the RSUs, or any payment or transfer under or with respect
to the RSUs and to take such other action as may be necessary in the opinion of the Administrator to satisfy all obligations for
the payment of such withholding taxes.

Exhibit 10.26

Securities Laws. The issuance of any shares of Common Stock hereunder shall be subject to the Participant making or

8.
entering into such written representations, warranties and agreements as the Administrator or any officer of the Company may
reasonably request in order to comply with applicable securities laws and government regulations.

Notices. Any notice necessary under this Award Agreement shall be addressed to the Company in care of its Vice

9.
President, Legal at the principal executive office of the Company and to the Participant at the address appearing in the personnel
records of the Company for the Participant or to either party at such other address as either party hereto may hereafter designate
in writing to the other. Any such notice shall be deemed effective upon receipt thereof by the addressee.

10.
Governing Law/Jurisdiction. This Award Agreement shall be governed by and construed and enforced in
accordance with the laws of the State of Delaware applicable to contracts made and to be performed therein. Any suit, action or
proceeding with respect to this Award Agreement, or any judgment entered by any court in respect of any thereof, shall be
brought in any court of competent jurisdiction in the State of Delaware, and the Company and the Participant hereby submit to
the exclusive jurisdiction of such courts (and their appellate courts, whether or not located in the State of Delaware) for the
purpose of any such suit, action, proceeding or judgment. The Participant and the Company hereby irrevocably waive (i) any
objections which it may now or hereafter have to the laying of the venue of any suit, action or proceeding arising out of or
relating to this Award Agreement brought in any court of competent jurisdiction in the State of Delaware, (ii) any claim that any
such suit, action or proceeding brought in any such court has been brought in any inconvenient forum and (iii) any right to a jury
trial.

Incorporation of the Terms of the Plan. By entering into this Award Agreement, the Participant agrees and

11.
acknowledges that the Participant has received and read a copy of the Plan as set forth on Exhibit A hereto. The RSUs are
subject to the Plan, as may be amended from time to time, and the terms and provisions of the plan are incorporated herein by
reference. In the event of any inconsistency between the Plan and this Award Agreement, the terms of the Plan shall control.

12.
Section  409A.  The  intent  of  the  parties  is  that  payments  and  benefits  under  this  Award  Agreement  comply  with
Section 409A of Code to the extent subject thereto, and, accordingly, to the maximum extent permitted, this Award Agreement
shall  be  interpreted  and  be  administered  to  be  in  compliance  therewith.  Notwithstanding  anything  contained  herein  to  the
contrary, to the extent required in order to avoid accelerated taxation and/or tax penalties under Section 409A of the Code, the
Participant shall not be considered to have separated from service with the Company for purposes of this Award Agreement and
no  payment  shall  be  due  to  the  Participant  under  this  Award  Agreement  on  account  of  a  separation  from  service  until  the
Participant would be considered to have incurred a "separation from service" from the Company within the meaning of Section
409A  of  the  Code.  Any  payments  described  in  this  Award  Agreement  that  are  due  within  the  "short-term  deferral  period"  as
defined  in  Section  409A  of  the  Code  shall  not  be  treated  as  deferred  compensation  unless  applicable  law  requires  otherwise.
Notwithstanding anything to the contrary

in this Award Agreement, to the extent that any RSUs are payable upon a separation from service and such payment would result
in the imposition of any individual income tax and late interest charges imposed under Section 409A of the Code, the settlement
and payment of such awards shall instead be made on the first business day after the date that is six (6) months following such
separation from service (or death, if earlier). The Company makes no representation that any or all of the payments described in
this Award Agreement will be exempt from or comply with Section 409A of the Code and makes no undertaking to preclude
Section 409A of the Code from applying to any such payment. The Participant shall be solely responsible for the payment of any
taxes and penalties incurred under Section 409A.

13.
original, with the same effect as if the signatures thereto and hereto were upon the same instrument.

Signature in Counterparts. This Award Agreement may be signed in counterparts, each of which shall be an

14.

Amendment and Termination. To the extent permitted by terms of the Plan, this Award Agreement may be wholly or
partially amended, altered or terminated at any time or from time to time by the Administrator or the Board, but no
amendment, alteration or termination shall be made that would materially impair the rights of the Participant under the
RSUs without the Participant's consent.

Entire Agreement. This Award Agreement (including all exhibits hereto, if any) constitute the entire agreement of the

15.
parties and supersede in their entirety all prior undertakings and agreements of the Company and the Participant with respect to
the subject matter hereof.

Electronic Signature; Electronic Delivery and Acceptance. The Participant's electronic signature of this Award

16.
Agreement shall have the same validity and effect as a signature affixed by hand. The Company may, in its sole discretion,
decide to deliver any documents related to the RSUs by electronic means. The Participant hereby consents to receive such
documents by electronic delivery and agrees to participate in the administration of the RSUs through an on-line or electronic
system established and maintained by the Company or a third party designated by the Company.

Waiver. The Participant acknowledges that a waiver by the Company of a breach of any provision of this Award

17.
Agreement shall not operate or be construed as a waiver of any other provision of this Award Agreement, or of any subsequent
breach by the Participant.

Severability. The provisions of this Award Agreement are severable and if any one or more provisions are determined

18.
to be illegal or otherwise unenforceable, in whole or in part, the remaining provisions shall nevertheless be binding and
enforceable.

[Signature Page Follows]

BY YOUR SIGNATURE BELOW, along with the signature of the Company's representative, you and the Company agree that
the RSUs are hereby awarded under the terms and conditions of this Award Agreement and under the terms and conditions of
the Plan.

Exhibit 10.26

EL POLLO LOCO HOLDINGS, INC.

By: ________________________________
Name:
Its:

PARTICIPANT

By:                         
Name:    

                                                                        
EL POLLO LOCO HOLDINGS, INC. 
2018 OMNIBUS EQUITY INCENTIVE PLAN
NONQUALIFIED STOCK OPTION AGREEMENT

Exhibit 10.27

THIS AWARD AGREEMENT (this “Option Agreement”), is made effective as of __________, ______ (the

“Date of Grant”), by and between El Pollo Loco Holdings, Inc., a Delaware corporation (the “Company”), and
___________________ (the “Participant”):

R E C I T A L S:

WHEREAS, the Company has adopted the El Pollo Loco Holdings, Inc. 2018 Omnibus Equity Incentive Plan (the

“Plan”), which Plan is incorporated herein by reference and made a part of this Option Agreement. Capitalized terms used but
not otherwise defined herein shall have meanings ascribed to such terms in the Plan; and

WHEREAS, the Administrator has determined that it would be in the best interests of the Company and its
stockholders to grant the Option provided for herein to the Participant pursuant to the Plan and the terms set forth herein.

NOW THEREFORE, in consideration of the mutual covenants hereinafter set forth, the parties agree as follows:

1.

Grant of the Option. The Company hereby grants to the Participant the right and option (the “Option”) to
purchase, on the terms and conditions hereinafter set forth, all or any part of an aggregate of _________ shares of Common Stock
(each a “Share” and collectively, the “Shares”). The purchase price of the Shares subject to the Option shall be equal to
$_________ per Share as of the Date of Grant (the “Option Price”). The Option is intended to be a non-qualified stock option,
and is not intended to be treated as an option that complies with Section 422 of the Code.

2.    Vesting. The Option granted hereunder shall vest and become exercisable with the passage of time. The

Option shall vest and become exercisable in four (4) equal installments on each of the first four (4) anniversaries of the Date of
Grant. Any portion of the Option which has become vested and exercisable in accordance with this section shall hereinafter be
referred to as the “Vested Portion.”

3.    Exercise of Option.

may exercise all or any part of the Vested Portion of the Option at any time prior to the earliest to occur of:

(a)    Period of Exercise. Subject to the provisions of the Plan and this Option Agreement, the Participant

(i)    the tenth (10th) anniversary of the Date of Grant; or

Company and its Affiliates for any reason other than for Cause or due to the Participant’s death or Disability; or

(ii)    ninety (90) days following the date of the Participant’s termination of employment with the

Company and its Affiliates due to the Participant’s death or Disability.

(iii)    six (6) months following the date of the Participant’s termination of employment with the

The entire Option (whether vested or unvested) held by the Participant immediately prior to the cessation of the

Participant’s employment shall immediately terminate upon such cessation if such cessation of employment was for Cause.

(b)    Method of Exercise.

(i)    Each election to exercise the Vested Portion shall be subject to the terms and conditions of the
Plan and shall be in writing, signed by the Participant or by his or her executor, administrator, or permitted transferee (subject to
any restrictions provided under the Plan), made pursuant to and in accordance with the terms and conditions set forth in the Plan
and received by the Company at its principal offices, accompanied by payment in full as provided in the Plan or in this Option
Agreement.

(ii)    The Option Price may be paid by (A) the delivery of cash or check acceptable to the

Administrator, including an amount to cover the applicable withholding taxes with respect to such exercise, or (B) any other
method, if any, approved by the Administrator, including (X) by means of consideration received under any cashless exercise
procedure, if any, approved by the Administrator (including the withholding of Shares otherwise issuable upon exercise) or
(Y) any other form of consideration approved by the Administrator and permitted by Applicable Laws.

(c)    Notwithstanding any of the foregoing, the Company shall have the right to specify all conditions of

the manner of exercise, which conditions may vary by country and which may be subject to change from time to time. Upon the
Company’s determination that the Vested Portion of the Option has been validly exercised as to any of the Shares, the Company
may issue certificates in the Participant’s name for such Shares. However, the Company shall not be liable to the Participant for
damages relating to any reasonable delays in issuing the certificates to such Participant, any loss of the certificates, or any
mistakes or errors in the issuance of the certificates or in the certificates themselves which it promptly undertakes to correct.

(d)    In the event of the Participant’s death, the Option shall remain exercisable by the Participant’s

executor or administrator, or the person or persons to whom the Participant’s rights under this Option Agreement shall pass by
will or by the laws of descent and distribution as the case may be, to the extent set forth in Section 3(a). Any heir or legatee of the
Participant shall take rights herein granted subject to the terms and conditions hereof.

4.    Termination of Employment.

reason, the Option shall, to the extent not then vested,

(a)    General. If the Participant’s employment with the Company and its Affiliates is terminated for any

-2-

terminate upon such termination of employment and the Vested Portion of the Option shall remain exercisable for the period set
forth in Section 3(a) and shall thereafter terminate.

Participant’s termination of employment with the Company and its Affiliates for Cause.

(b)    For Cause. The Option (including any Vested Portion thereof) shall terminate immediately upon the

5.    Conditions to Issuance of Stock Certificates. The Shares deliverable upon the exercise of the Option, or any

portion thereof, may be either previously authorized but unissued Shares, treasury Shares or issued Shares which have then been
reacquired by the Company. Such Shares shall be fully paid and nonassessable.

6.    Adjustments. Pursuant to Section 5 of the Plan, in the event of a Change in Capitalization, the Administrator
shall make such equitable changes or adjustments to the number and kind of securities or other property (including cash) issued
or issuable in respect of the Option as it determines to be necessary in its sole discretion.

7.    No Right to Continued Employment. The granting of the Option evidenced hereby and this Option Agreement
shall impose no obligation on the Company or any Affiliate to continue the employment of the Participant and shall not lessen or
affect the Company’s or any Affiliate’s right to terminate the employment of such Participant.

8.    Legend on Certificates. The certificates representing the Shares purchased by exercise of the Vested Portion

shall be subject to such stop transfer orders and other restrictions as the Administrator reasonably deem advisable under the Plan
or the rules, regulations, and other requirements of the Securities and Exchange Commission, any stock exchange upon which
such Shares are listed, and any applicable Federal or state laws, and the Administrator may cause a legend or legends to be put on
any such certificates to make appropriate reference to such restrictions.

9.    Transferability.

(a)    The Option may not be assigned, alienated, pledged, attached, sold or otherwise transferred or

encumbered by the Participant otherwise than by will or by the laws of descent and distribution, and any such purported
assignment, alienation, pledge, attachment, sale, transfer or encumbrance in contravention of the foregoing shall be void and
unenforceable against the Company or any Affiliate; provided, that the designation of a beneficiary shall not constitute an
assignment, alienation, pledge, attachment, sale, transfer or encumbrance. No such permitted transfer of the Option to heirs or
legatees of the Participant shall be effective to bind the Company unless the Administrator shall have been furnished with written
notice thereof and a copy of such evidence as the Administrator may deem necessary to establish the validity of the transfer and
the acceptance by the transferee or transferees of the terms and conditions hereof. During the Participant’s lifetime, the Vested
Option is exercisable only by the Participant.

Participant's successors in interest or shall not be subject to

(b)    The Option shall not be liable for the debts, contracts or engagements of the Participant or the

-3-

disposition by transfer, alienation, anticipation, pledge, hypothecation, encumbrance, assignment or any other means whether
such disposition be voluntary or involuntary or by operation of law by judgment, levy, attachment, garnishment or any other legal
or equitable proceedings (including bankruptcy) unless and until the Option has been exercised, and any attempted disposition
thereof prior to exercise shall be null and void and of no effect, except to the extent that such disposition is permitted by Section
9(a).

10.    Withholding. Subject to Section 3(b)(ii), the Participant may be required to pay to the Company or any
Affiliate and the Company shall have the right and is hereby authorized to withhold from any payment due or transfer made
under the Option or under the Plan or from any compensation or other amount owing to the Participant the amount (in cash,
Shares, other securities or other property) of any applicable withholding taxes in respect of the Option, its exercise or any
payment or transfer under or with respect to the Option or the Plan and to take such other action as may be necessary in the
opinion of the Administrator to satisfy all obligations for the payment of such withholding taxes, calculated up to the maximum
statutory tax rates in the Participant’s jurisdiction, as determined by the Company.

11.    Securities Laws. The issuance of any Shares hereunder shall be subject to the Participant making or entering

into such written representations, warranties and agreements as the Administrator may reasonably request in order to comply with
applicable securities laws and government regulations.

12.    Notices. Any notice necessary under this Option Agreement shall be addressed to the Company in care of its

Vice President, Legal at the principal executive office of the Company and to the Participant at the address appearing in the
personnel records of the Company for the Participant or to either party at such other address as either party hereto may hereafter
designate in writing to the other. Any such notice shall be deemed effective upon receipt thereof by the addressee.

13.    Governing Law/Jurisdiction. This Option Agreement shall be governed by and construed and enforced in

accordance with the laws of the State of Delaware applicable to contracts made and to be performed therein. Any suit, action or
proceeding with respect to this Option Agreement, or any judgment entered by any court in respect of any thereof, shall be
brought in any court of competent jurisdiction in the State of Delaware, and the Company and the Participant hereby submit to
the exclusive jurisdiction of such courts for the purpose of any such suit, action, proceeding or judgment. The Participant and the
Company hereby irrevocably waive (i) any objections which it may now or hereafter have to the laying of the venue of any suit,
action or proceeding arising out of or relating to this Option Agreement brought in any court of competent jurisdiction in the
State of Delaware, (ii) any claim that any such suit, action or proceeding brought in any such court has been brought in any
inconvenient forum and (iii) any right to a jury trial.

14.    Option Subject to Plan. By entering into this Option Agreement, the Participant agrees and acknowledges

that the Participant has received and read a copy of the Plan. The Option is subject to the Plan, as may be amended from time to
time, and the terms and

-4-

provisions of the Plan are hereby incorporated herein by reference. In the event of any inconsistency between the Plan and this
Option Agreement, the terms of the Plan shall control.

15.    Section 409A. It is intended that the terms of this Option Agreement be exempt from or comply with Section
409A of the Code. If it is determined that the terms of this Option Agreement have been structured in a manner that would result
in adverse tax treatment under Section 409A of the Code, the parties agree to cooperate in taking all reasonable measures to
restructure the arrangement to minimize or avoid such adverse tax treatment without materially impairing Participant’s economic
rights.

16.    Signature in Counterparts. This Option Agreement may be signed in counterparts, each of which shall be an

original, with the same effect as if the signatures thereto and hereto were upon the same instrument.

17.    Amendments and Termination.  To the extent permitted by the Plan, this Option Agreement may be wholly or

partially amended, altered or terminated at any time or from time to time by the Administrator or the Board, but no amendment,
alteration or termination shall be made that would materially impair the rights of the Participant under the Option without such
Participant’s consent.

18.    Entire Agreement  The Plan and this Option Agreement (including all Exhibits thereto, if any) constitute the

entire agreement of the parties and supersede in their entirety all prior undertakings and agreements of the Company and the
Participant with respect to the subject matter hereof.

19.    Electronic Signature; Electronic Delivery and Acceptance.  The Participant’s electronic signature of this

Option Agreement shall have the same validity and effect as a signature affixed by hand. The Company may, in its sole
discretion, decide to deliver any documents related to the Participant’s current or future participation in the Plan by electronic
means.  The Participant hereby consents to receive such documents by electronic delivery and agrees to participate in the Plan
through an on-line or electronic system established and maintained by the Company or a third party designated by the Company.

20.    Waiver.  The Participant acknowledges that a waiver by the Company of a breach of any provision of this

Option Agreement shall not operate or be construed as a waiver of any other provision of this Option Agreement, or of any
subsequent breach by the Participant.

21.    Severability.  The provisions of this Option Agreement are severable and if any one or more provisions are
determined to be illegal or otherwise unenforceable, in whole or in part, the remaining provisions shall nevertheless be binding
and enforceable.

22.    Clawback.  The Option is subject to such recoupment policies of the Company as may be in effect from time

to time pursuant to Section 28 the Plan.

-5-

[Signature Page Follows]

-6-

IN WITNESS WHEREOF, the parties hereto have executed this Award Agreement as of the date and year first above written.

EL POLLO LOCO HOLDINGS, INC.

____________________________________
Name:
Title:

PARTICIPANT

23.

___________________________________

-7-

Exhibit 10.30

EMPLOYMENT AGREEMENT 
HECTOR MUNOZ

EMPLOYMENT AGREEMENT (the “Agreement”) dated as of October ___, 2018 by and between El Pollo Loco, Inc.

(the “Company”) and Hector Munoz (the “Executive”).

WHEREAS, the Company desires to employ Executive as the Company's Chief Marketing Officer; and

WHEREAS, Executive is willing to accept such employment on the terms hereinafter set forth in this Agreement.

NOW, THEREFORE, in consideration of the premises and mutual covenants herein and for other good and valuable

consideration, the parties agree as follows:

1.

Term of Employment; Executive Representation.

(a)

Employment Term. Subject to the terms and conditions set forth in this Agreement, the term of Executive's
employment under this Agreement shall commence on December 1, 2018 (the “Effective Date”) and end on the
18th month anniversary of the Effective Date (the “Initial Employment Term”) and on such date and on each
subsequent anniversary of such date, the term shall, without further action by Executive or Company, be extended
by an additional one-year period (each such one year term, the “Renewal Employment Term”) subject to earlier
termination as provided in this Agreement; provided, however, that either Company or Executive may, by written
notice to the other given not less than 60 days prior to the scheduled expiration of the Initial Employment Term or
Renewal Employment Term (a “Non-Renewal Notice”), as applicable, cause the term not to extend (the period
during which Executive is employed under the terms of this Agreement, including the Initial Employment Term
and all Renewal Employment Terms, is referred to herein as the “Employment Term”). The Employment Term
shall also terminate earlier upon termination of Executive's employment as set forth in Section 7.

(b)

Executive Representation. Executive hereby represents to the Company that the execution and delivery of this
Agreement by Executive and the Company and the performance by Executive of the Executive’s duties hereunder
shall not constitute a breach of, or otherwise contravene, the terms of any employment agreement or other
agreement or policy to which Executive is a party or otherwise bound.

2.

Position.

(a)

During the Employment Term, Executive shall serve as the Company’s Chief Marketing Officer and shall
principally perform Executive’s duties to the Company and its affiliates from the Company’s offices in the Orange
County, California metropolitan area, subject to normal and customary travel requirements

in the conduct of the Company’s business. Executive shall have such authorities, duties and responsibilities as the
Chief Executive Officer may from time to time assign to him and reasonably consistent with those customarily
performed by a chief marketing officer of a company having a similar size and nature of the Company, and the
Executive shall report directly to the Chief Executive Officer.

(b)

During the Employment Term, Executive will devote Executive’s full business time and best efforts to the
performance of Executive’s duties hereunder and will not engage in any other business, profession or occupation
(including in an advisory capacity, consulting capacity, or otherwise) for compensation or otherwise which would
conflict with the rendition of such services either directly or indirectly, without the prior written consent of the
Board of Directors of the Company (the “Board”).

3.

Compensation.

(a)

During the Employment Term, the Company shall pay Executive a base salary (the “Base Salary”) at the annual
rate of $375,000 (less applicable withholding taxes), payable in regular installments in accordance with the
Company’s usual payment practices. Executive shall be entitled to such increases in Executive’s Base Salary, if
any, as may be determined from time to time in the sole discretion of the Board.

(b) With respect to each full calendar year during the Employment Term, Executive shall be eligible to earn an annual
bonus award (an “Annual Bonus”) based on the achievement of specified performance goals, which shall be
determined by the Board in its sole discretion within ninety (90) days following the commencement of each
calendar year, with a targeted bonus equal to seventy-five percent (75%) of Executive’s then current Base Salary
(the “Target Bonus”). The Annual Bonus, if any, will be paid between January 1 and March 15 of the year
following the year to which it relates.

(c)

At the discretion of the Board, during the Employment Term, starting in 2020, Executive will be eligible to receive
an annual discretionary equity grant, with the amount and terms thereof determined by the Board.

4.

Sign on Awards

(a)

Equity in 2018. As soon as reasonably practical following the Effective Date (but before the close of the scheduled
open trading window of the Company), Executive will receive the following equity grants (together, the “2018
Equity Grant”) with aggregate grant-date value targeted at approximately $250,000. The 2018 Equity Grant will
consist of the following:

(i)

Approximately $250,000 worth of time-vested restricted stock units (or restricted shares) that will vest
25%/year, and

2

(b)

Equity in 2019. Executive will receive the following equity grants during the Company’s annual equity grant
window in 2019, typically in May (together, the “2019 Equity Grant”) with the aggregate grant-date value targeted
at approximately $600,000. The 2019 Equity Grant will consist of the following:

(i)

Approximately $250,000 worth of time-vested 10-year options that will vest 25%/year;

(ii)

Approximately $350,000 worth of time-vested restricted stock units (or restricted shares) that will vest
25%/year; and

All the other terms of the 2018 Equity Grant and 2019 Equity Grant will be consistent with the Company’s standard
equity award practices and shall be determined in good faith by the Board.

(c)

Relocation. To assist the Executive with Executive’s relocation expenses, the Company will pay Executive cash
payments totaling $150,000, consisting of the following:

(i)

A lump sum payment in the amount of $25,000 paid no later than the date of Executive’s initial paycheck
issued by the Company; and

(ii)

A lump sum payment in the amount of $125,000 on January 2, 2019.

These cash lump sum payments shall be considered conditional payments until Executive has completed 18 months of
employment. In the event Executive’s employment is terminated by the Company for Cause or by Executive without
Good Reason (each as defined below) before 18 months of service, Executive will be responsible for 100% repayment of
the relocation amount within six (6) months thereafter.

(d)

Indemnification. The Executive shall be covered under the Company’s directors and officers liability insurance
during the Employment Term and thereafter to the same extent as such coverage is provided from time to time to
similarly situated officers of the Company.

5.

Employee Benefits. During the Employment Term, Executive shall be provided, in accordance with the terms of the
Company’s employee benefit plans as in effect from time to time, health insurance, retirement benefits and fringe benefits
(collectively “Employee Benefits”) on the same basis as those benefits are generally made available to other senior
executives of the Company. Company will also reimburse Executive for COBRA payments to cover the period of time
until Executive becomes eligible for medical insurance in accordance with the terms of the Company’s health insurance
plan. Executive shall be provided with annual vacation of four (4) weeks per each twelve (12) month period and
additional weeks on a basis consistent with Company policy. During the Employment Term, the Company shall provide
Executive with an automobile

3

6.

7.

allowance substantially similar to the allowance provided by the Company to other similarly situated senior executives of
the Company.

Business Expenses. During the Employment Term, reasonable, documented business expenses incurred by Executive in
the performance of Executive’s duties hereunder shall be reimbursed by the Company in accordance with Company
policies.

Termination. The Employment Term and Executive’s employment hereunder may be terminated early by either party at
any time and for any reason; provided that Executive will be required to give the Company at least ninety (90) days
advance written notice of any resignation of Executive’s employment. Notwithstanding any other provision of this
Agreement, the provisions of this Section 7 shall exclusively govern Executive’s rights upon termination of employment
with the Company and its affiliates prior to expiration of the Employment Term.

(a)

By the Company For Cause, By Executive’s Resignation without Good Reason or upon Non-Renewal of the
Employment Term.

(i)

(ii)

The Employment Term and Executive’s employment hereunder may be terminated by the Company for
Cause (as defined below) or by Executive’s resignation without Good Reason (as defined below).

For purposes of this Agreement, “Cause” shall mean (a) action by the Executive that constitute acts of (1)
fraud; (2) embezzlement; (3) gross insubordination; (4) gross misconduct; (5) material dishonesty which
causes material harm to the Company; (b) the Executive’s inability, failure, or refusal to perform any duty,
responsibility, or obligation of his position, which (to the extent such inability, failure, or refusal to perform
is curable in the judgment of the Company) is not cured by the Executive within five (5) days after
receiving written notice from the Company of such inability, failure; (c) Executive's commission of a
felony; (d) Executive’s substance abuse or alcohol abuse which renders the Executive unfit to perform his
duties; or (e) any breach of the covenants set forth in Section 8 of this Agreement by Executive. Any
voluntary termination of employment by the Executive in anticipation of an involuntary termination of the
Executive’s employment by the Company for Cause shall be deemed to be a termination for Cause.

(iii)

If Executive’s employment is terminated by the Company for Cause, if Executive resigns without Good
Reason or if the Employment Term expires as a result of the Company delivering to the Executive the
Non-Renewal Notice (such event, the “Company Non-Renewal”), Executive shall be entitled to receive:

(A)

the Base Salary through the date of termination;

4

(B)

(C)

(D)

(E)

except in the case of termination for Cause, any Annual Bonus earned but unpaid as of the date of
termination for any previously completed calendar year;

reimbursement for any unreimbursed business expenses properly incurred by Executive in
accordance with Company policy prior to the date of Executive’s termination; and

such Employee Benefits, if any, as to which Executive may be entitled under the employee benefit
plans of the Company;

any additional amounts or benefits due under any applicable plan, program, agreement or
arrangement of the Company or its affiliates or pursuant to applicable law (the amounts described
in clauses (A) through (E) hereof being referred to as the “Accrued Rights”). The Accrued Rights
under this Section 7 shall in all events be paid in accordance with the Company’s normal payroll
procedures, expense reimbursement procedures or plan terms, as applicable.

Following such termination of Executive’s employment by Company Non-Renewal, the Company for Cause or resignation by
Executive without Good Reason, except as set forth in this Section 7(a), Executive shall have no further rights to any contract
damages, other compensation or any other benefits under this Agreement.

(b)

Disability or Death.

(i)

The Employment Term and Executive’s employment hereunder shall terminate upon Executive’s death or
if Executive (A) is unable to engage in any substantial gainful activity by reason of any medically
determinable physical or mental impairment which can be expected to result in death or can be expected to
last for a continuous period of not less than twelve (12) months, or (ii) is, by reason of any medically
determinable physical or mental impairment which can be expected to result in death or can be expected to
last for a continuous period of not less than twelve (12) months, receiving income replacement benefits for
a period of not less than three (3) months under an accident and health plan, or disability plan, covering
employees of the Company or an affiliate of the Company (such incapacity is hereinafter referred to as
“Disability”).

Any question as to the existence of the Disability of Executive as to which Executive and the Company cannot agree shall be
determined in writing by a qualified independent physician mutually acceptable to Executive and the Company. If Executive and
the Company cannot agree as to a qualified independent physician, each shall appoint such a physician and those two physicians
shall select a third who shall make such determination in writing. The determination

5

of Disability made in writing to the Company and Executive shall be final and conclusive for all purposes of the Agreement.

(ii)

Upon termination of Executive’s employment hereunder for either Disability or death, Executive or
Executive’s estate (as the case may be) shall be entitled to receive:

(A)

the Accrued Rights; and

(B)

the Annual Bonus, if any, that the Executive would have been entitled to receive pursuant to
Section 3(b) hereof in respect of the year in which such termination occurs based upon the actual
achievement of the performance goals, multiplied by a fraction the numerator of which is the
number of days Executive is employed by the Company in such year and the denominator of which
is the total number of days in such year, payable when such Annual Bonus would have otherwise
been payable in accordance with Section 3(b) had the Executive’s employment not terminated (the
"Pro-Rata Bonus").

Following Executive's termination of employment due to death or Disability, except as set forth in this Section 7(b), Executive or
Executive’s estate (as the case may be) shall have no further rights to any contract damages, other compensation or any other
benefits under this Agreement.

(c)

By the Company Without Cause or by Executive’s Resignation with Good Reason.

(i)

The Employment Term and Executive’s employment hereunder may be terminated by the Company
without Cause or by Executive with Good Reason.

(ii)

For purposes of this Agreement, “Good Reason” shall mean:

(A)

(B)

(C)

(D)

Executive’s relocation, without his consent and other than for a temporary work assignment, by the
Company outside Orange County, California;

a material diminution of Executive’s authority, duties, title or responsibilities as set forth in Section
2(a) hereof;

a reduction of Executive’s Base Salary (as increased from time to time) as set forth in Section 3(a)
hereof;

the material failure of the Company to provide or cause to be provided to Executive any of the
Employee Benefits described in Section 5 hereof; or

6

(E)

a requirement that Executive report to anyone other than the Chief Executive Officer or the Board;
provided that none of the events described in clauses (A) through (E) of this Section 7(c)(ii) shall
constitute Good Reason unless Executive shall have notified the Company in writing describing the
event which constitutes Good Reason within thirty (30) days of the initial occurrence of such event
and then only if the Company shall have failed to cure such event within thirty (30) days after the
Company’s receipt of such written notice.

(iii)

If Executive’s employment is terminated by the Company without Cause (other than by reason of death or
Disability), by Executive with Good Reason, Executive shall be entitled to receive:

(A)

the Accrued Rights;

(B)

(C)

subject to Executive’s execution of a general release of claims in a form reasonably determined by
the Company (the “Release”), the expiration of the applicable revocation period with respect to
such Release within sixty (60) days following the date of termination and Executive’s continued
compliance with the provisions of Section 8 and 9, the Pro-Rata Bonus;

subject to Executive’s execution of a Release, the expiration of the applicable revocation period
with respect to such Release within sixty (60) days following the date of termination and
Executive’s continued compliance with the provisions of Section 8 and 9, continued payment of the
Base Salary in accordance with the Company's normal payroll practices for a period of twelve (12)
months following the date of such termination, which shall commence on the sixtieth (60th) day
following such termination (with the first payment equal to the cumulative amount that would have
been paid in such initial sixty (60) day period); and

Following Executive’s termination of employment by the Company without Cause (other than by reason of Executive’s death or
Disability) or by Executive’s resignation with Good Reason, except as set forth in this Section 7(c), Executive shall have no
further rights to any contract damages, other compensation or any other benefits under this Agreement or under any other plans,
programs or arrangements of the Company or its affiliates.

(d)

Notice of Termination. Any purported termination of employment by the Company or by Executive (other than
due to Executive’s death) shall be communicated by written Notice of Termination to the other party hereto in
accordance with Section 12(g) hereof. For purposes of this Agreement, a “Notice of Termination” shall mean a
notice which shall indicate the specific termination provision in this Agreement relied upon and shall set forth in
reasonable detail the

7

facts and circumstances claimed to provide a basis for termination of employment under the provision so
indicated.

8.

Non-Interference/Non-Solicitation. Executive acknowledges and recognizes that in the course of performing services for
the Company, Executive will have access to certain confidential and proprietary information of the Company and its
affiliates that is extremely valuable to the Company and its affiliates and is not known to the general public. Accordingly,
Executive agrees as follows:

(a)Executive agrees that during the term of employment and until the first anniversary of the date of termination of

Executive's employment with the Company or any subsidiary of the Company, as the case may be (the
"Restricted Period"), the Executive will not directly or indirectly, use any Company Confidential Information
(as defined in Section 9) to interfere with business relationships (whether formed before or after the date of this
Agreement) between the Company or any of its affiliates and customers, suppliers, partners, members or
investors of the Company or its affiliates.

(b)Executive further agrees that during the Restricted Period, Executive will not, directly or indirectly, (i) solicit or
encourage any employee of the Company or its affiliates to leave the employment of the Company or its
affiliates, or (ii) solicit or encourage to cease to work with the Company or its affiliates any consultant then
under contract with the Company or its affiliates; provided, however, that general advertising not directed
specifically at employees of the Company or any affiliate shall not be deemed to violate this Section 8(b).

(c)It is expressly understood and agreed that although Executive and the Company consider the restrictions contained in

this Section 8 to be reasonable, if a final judicial determination is made by a court of competent jurisdiction that
any restriction contained in this Agreement is an unenforceable restriction against Executive, the provisions of
this Agreement shall not be rendered void but shall be deemed amended to apply as to such maximum time and
territory and to such maximum extent as such court may judicially determine or indicate to be enforceable.
Alternatively, if any court of competent jurisdiction finds that any restriction contained in this Agreement is
unenforceable, and such restriction cannot be amended so as to make it enforceable, such finding shall not
affect the enforceability of any of the other restrictions contained herein.

9.

Confidentiality and Cooperation. Executive will not at any time (whether during or after Executive's employment with the
Company) disclose or use for Executive's own benefit or purposes or the benefit or purposes of any other person, firm,
partnership, joint venture, association, corporation or other business organization, entity or enterprise other than the
Company and any of its subsidiaries or affiliates, any trade secrets, information, data, or other confidential information
relating to customers, development programs, costs, marketing, trading, investment, sales activities, promotion, credit and
financial data, manufacturing processes, financing methods, plans, or the business and affairs of

8

the Company generally, or of any subsidiary or affiliate of the Company (“Company Confidential Information”); provided
that the foregoing shall not apply to information which is not unique to the Company or which is generally known to the
industry or the public other than as a result of Executive's breach of this covenant; provided further that the foregoing
shall not apply when Executive is required to divulge, disclose or make accessible such information by a court of
competent jurisdiction or an individual duly appointed thereby, by any administrative body or legislative body (including
a committee thereof) having supervisory authority over the business of the Company, or by any administrative body or
legislative body (including a committee thereof) with jurisdiction to order Executive to divulge, disclose or make
accessible such information. Executive agrees that upon termination of Executive's employment with the Company for
any reason, he will return to the Company immediately all memoranda, books, papers, plans, information, letters and
other data, and all copies thereof or therefrom, in any way relating to the business of the Company and its affiliates and/or
containing any Company Confidential Information, except that he may retain personal notes, notebooks and diaries that
do not contain Company Confidential Information of the type described in the preceding sentence. Executive further
agrees that he will not retain or use for Executive's account at any time any trade names, trademark or other proprietary
business designation used or owned in connection with the business of the Company or its affiliates. Except to the extent
that it could reasonably be expected to materially and unreasonably interfere with the Executive's professional and
personal responsibilities and commitments, upon reasonable notice from the Company to the Executive, Executive agrees
to cooperate, both during and after the Employment Term, at the Company’s sole cost and expense (including reasonable,
necessary and documented legal fees to the extent not otherwise paid by insurance), with respect to matters of which
Executive has knowledge.

10.

DEFEND TRADE SECRETS ACT.

(a)

(b)

Notwithstanding anything set forth in this Agreement to the contrary, Executive shall not be prohibited from
reporting possible violations of federal or state law or regulation to any governmental agency or entity or making
other disclosures that are protected under the whistleblower provisions of federal or state law or regulation, nor is
Executive required to notify the Company regarding any such reporting, disclosure or cooperation with the
government.

Pursuant to Section 1833(b) of the Defend Trade Secrets Act of 2016, Executive acknowledges that he shall not
have criminal or civil liability under any federal or State trade secret law for the disclosure of a trade secret that (i)
is made (A) in confidence to a federal, state, or local government official, either directly or indirectly, or to an
attorney and (B) solely for the purpose of reporting or investigating a suspected violation of law; or (ii) is made in
a complaint or other document filed in a lawsuit or other proceeding, if such filing is made under seal. Nothing in
this Agreement is intended to conflict with Section 1833(b) of the Defend Trade Secrets Act of 2016 or create
liability for disclosures of trade secrets that are expressly allowed by such section.

9

11.

Specific Performance. Executive acknowledges and agrees that the Company's remedies at law for a breach or threatened
breach of any of the provisions of Section 8 or Section 9 would be inadequate and, in recognition of this fact, Executive
agrees that, in the event of such a breach or threatened breach, in addition to any remedies at law, the Company, shall be
entitled to cease making any payments or providing any benefit otherwise required by this Agreement and obtain
equitable relief in the form of specific performance, temporary restraining order, temporary or permanent injunction or
any other equitable remedy which may then be available.

12. Miscellaneous.

(a)

(b)

(c)

(d)

(e)

Governing Law. This Agreement shall be governed by and construed in accordance with the laws of the State of
California, without regard to conflicts of laws principles thereof.

Entire Agreement/Amendments. This Agreement contains the entire understanding of the parties with respect to
the employment of Executive by the Company. There are no restrictions, agreements, promises, warranties,
covenants or undertakings between the parties with respect to the subject matter herein other than those expressly
set forth herein. This Agreement supersedes any other agreements or representations, oral or otherwise, express or
implied, with respect to the subject matter hereof which have been made by either party. This Agreement may not
be altered, modified, or amended except by written instrument signed by the parties hereto.

No Waiver. The failure of a party to insist upon strict adherence to any term of this Agreement on any occasion
shall not be considered a waiver of such party’s rights or deprive such party of the right thereafter to insist upon
strict adherence to that term or any other term of this Agreement.

Severability. In the event that any one or more of the provisions of this Agreement shall be or become invalid,
illegal or unenforceable in any respect, the validity, legality and enforceability of the remaining provisions of this
Agreement shall not be affected thereby.

Assignment. This Agreement shall not be assignable by Executive. This Agreement may be assigned by the
Company to a company which is a successor in interest to substantially all of the business operations of the
Company. Such assignment shall become effective when the Company notifies the Executive of such assignment
or at such later date as may be specified in such notice. Upon such assignment, the rights and obligations of the
Company hereunder shall become the rights and obligations of such successor company, provided that any
assignee expressly assumes the obligations, rights and privileges of this Agreement.

10

(f)

(g)

Successors Binding Agreement. This Agreement shall inure to the benefit of and be binding upon personal or legal
representatives, executors, administrators, successors, heirs, distributes, devises and legatees.

Notice. For the purpose of this Agreement, notices and all other communications provided for in the Agreement
shall be in writing and shall be deemed to have been duly given when delivered or mailed by United States
registered mail, return receipt requested, postage prepaid, addressed to the respective addresses set forth below
Agreement, or to such other address as either party may have furnished to the other in writing in accordance
herewith, except that notice of change of address shall be effective only upon receipt.

If to the Company:

El Pollo Loco, Inc.
3535 Harbor Boulevard, Suite 100
Costa Mesa, CA 92626
Attn: President and Chief Executive Officer
Attn: Vice President, Legal.

If to Executive: To the most recent address of Executive set forth in the personnel records of the Company.

(h) Withholding Taxes. The Company may withhold from any amounts payable under this Agreement such Federal,

state and local taxes as may be required to be withheld pursuant to any applicable law or regulation.

(i)

Section 409A. The intent of the parties is that payments and benefits under this Agreement comply with Section
409A of the Internal Revenue Code of 1986, as amended (the "Code"), to the extent subject thereto, and
accordingly, to the maximum extent permitted, this Agreement shall be interpreted and administered to be in
compliance therewith. Notwithstanding anything contained herein to the contrary, Executive shall not be
considered to have terminated employment with the Company for purposes of any payments under this Agreement
which are subject to Section 409A of the Code until the Executive has incurred a “separation from service” from
the Company within the meaning of Section 409A of the Code. Each amount to be paid or benefit to be provided
under this Agreement shall be construed as a separate identified payment for purposes of Section 409A of the
Code. Without limiting the foregoing and notwithstanding anything contained herein to the contrary, to the extent
required in order to avoid accelerated taxation and/or tax penalties under Section 409A of the Code, amounts that
would otherwise be payable and benefits that would otherwise be provided pursuant to this Agreement during the
six-month period immediately following an Executive’s separation from service shall instead be paid on the first
business day after the date that is six months following the Executive’s separation

11

from service (or, if earlier, the Executive’s date of death). To the extent required to avoid an accelerated or
additional tax under Section 409A of the Code, amounts reimbursable to Executive under this Agreement shall be
paid to Executive on or before the last day of the year following the year in which the expense was incurred and
the amount of expenses eligible for reimbursement (and in kind benefits provided to Executive) during one year
may not affect amounts reimbursable or provided in any subsequent year. The Company makes no representation
that any or all of the payments described in this Agreement will be exempt from or comply with Section 409A of
the Code and makes no undertaking to preclude Section 409A of the Code from applying to any such payment.

(j)

Counterparts. This Agreement may be signed in counterparts, each of which shall be an original, with the same
effect as if the signatures thereto and hereto were upon the same instrument.

[signature page follows]

IN WITNESS WHEREOF, the parties hereto have duly executed this Agreement as of the day and year first above

written.

_________________________     
Hector Munoz 

EL POLLO LOCO, INC.

By:              
    Name:     
    Title:    

12

Consent of Independent Registered Public Accounting Firm

Exhibit 23.1

El Pollo Loco Holdings, Inc.
Costa Mesa, California

We hereby consent to the incorporation by reference in the Registration Statement on Form S-8 (No. 333-197698) of El Pollo Loco Holdings, Inc. of our
reports dated March 6, 2020, relating to the consolidated financial statements, and the effectiveness of El Pollo Loco Holdings, Inc.’s internal control over
financial reporting, which appear in this Form 10-K.

/s/ BDO USA, LLP

Costa Mesa, California
March 6, 2020

Exhibit 31.1

I, Bernard Acoca, certify that:

1. I have reviewed this annual report on Form 10-K of El Pollo Loco Holdings, Inc.;

CERTIFICATIONS

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the
statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the
financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;

4. The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Exchange
Act Rules 13a–15(e) and 15d–15(e) and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f) for the
registrant and have:

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure
that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly
during the period in which this report is being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to
provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance
with generally accepted accounting principles;

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the effectiveness of
the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent fiscal
quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the
registrant’s internal control over financial reporting; and

5. The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the
registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to
adversely affect the registrant’s ability to record, process, summarize and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control over
financial reporting.

Date: March 6, 2020

/s/ Bernard Acoca

Bernard Acoca
President and Chief Executive Officer
(Principal Executive Officer)

 
 
 
Exhibit 31.2

I, Laurance Roberts, certify that:

1. I have reviewed this annual report on Form 10-K of El Pollo Loco Holdings, Inc.;

CERTIFICATIONS

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the
statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the
financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;

4. The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Exchange
Act Rules 13a–15(e) and 15d–15(e) and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f) for the
registrant and have:

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure
that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly
during the period in which this report is being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to
provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance
with generally accepted accounting principles;

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the effectiveness of
the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent fiscal
quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the
registrant’s internal control over financial reporting; and

5. The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the
registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to
adversely affect the registrant’s ability to record, process, summarize and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control over
financial reporting.

Date: March 6, 2020

/s/ Laurance Roberts

Laurance Roberts
Chief Financial Officer
(Principal Financial Officer)

 
 
 
CERTIFICATION

Exhibit 32.1

Under 18 U.S.C. section 1350, adopted by section 906 of the Sarbanes-Oxley Act of 2002, in connection with the attached periodic report, the undersigned
each certify that (i) the periodic report fully complies with the requirements of section 13(a) or 15(d) of the Securities Exchange Act of 1934 and (ii) the
information contained in the periodic report fairly presents, in all material respects, the financial condition and results of operations of the issuer.

Date: March 6, 2020

/s/ Bernard Acoca

Bernard Acoca
President and Chief Executive Officer

/s/ Laurance Roberts

Laurance Roberts
Chief Financial Officer