That would make sense and would simplify things, but it ignores the biggest fact.
The Feds don't want it to be simple, they don't want it to be easy for us.
They want it to be easy for them to prosecute in the name of "protecting the children".
If that were not so then the rules would read more like the rules for selling cigearettes.. Something along the line of "records are required accept where it is obvious that the performer is not a minor" (like cigarettes do in missouri..."you need to check id on anyone under 27 years old")
They have turned what is a good concept... "Prove that the performer is of age" into a blatant attempt to get prosecutions from people being unable to fathom the paperwork maze.
just imho of course.
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