New 2257 Compliance Guide

[RawAlex]

Who is not required to maintain records?

A. Individuals or entities are not covered producers if their role with respect to covered materials is limited to photo or film processing; distribution; services that do not involve the hiring, managing, or arranging of the participation of depicted performers; providing telecommunications or Internet services; transmission, storage, retrieval, hosting, formatting, or translation of a communication, without selection or alteration of the content of the communication; or dissemination of a depiction without selection or alteration of its content. See 28 C.F.R. § 75.1(c)(4).

I am particular on "services that do not involve the hiring, managing, or arranging of the participation of depicted performers" - this pretty much makes all free websites using sponsor content as exempt, because they are not involved in the hiring, managing, or arranging for performers".

This version is funny as hell.

[pornlaw]

Originally Posted by RawAlex

Who is not required to maintain records?

A. Individuals or entities are not covered producers if their role with respect to covered materials is limited to photo or film processing; distribution; services that do not involve the hiring, managing, or arranging of the participation of depicted performers; providing telecommunications or Internet services; transmission, storage, retrieval, hosting, formatting, or translation of a communication, without selection or alteration of the content of the communication; or dissemination of a depiction without selection or alteration of its content. See 28 C.F.R. § 75.1(c)(4).

I am particular on "services that do not involve the hiring, managing, or arranging of the participation of depicted performers" - this pretty much makes all free websites using sponsor content as exempt, because they are not involved in the hiring, managing, or arranging for performers".

This version is funny as hell.

Not true -- here's the important part of the text

transmission, storage, retrieval, hosting, formatting, or translation of a communication, without selection or alteration of the content of the communication; or dissemination of a depiction without selection or alteration of its content

Its the selection and/or alteration of the content that is the deciding factor.

Is a secondary producer required to check identification documents of performers?

A. A secondary producer is not required to check identification requirements. The secondary producer is required to maintain records that identify the primary producer for any depiction and that verify that the primary producer checked the legal age of performers prior to the date of original production.

Again, this looks like secondary producers don't have to keep actual 2257 records, just a list of content providers and some sort of "we assure you that we checked the records" notification.

Again, not true. This just means that a secondary can rely on copies of ID and 2257 docs given to them by the primary. See the bolded text above. You cannot verify unless you have the records. A simple link back is not allowed.