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Originally Posted by RawAlex
...you use to be able to use a third party to hold those records...
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Well, in certain cases yes a third party could be designated. You were allowed to designate an employee as your Custodian of Records,
i.e. a full time webmaster. Most of us that work from home don't have any employees other than me, myself and I, so a third party Custodian of Records has never been an option. Lawyers, Accountants, and Bookkeepers are contractors not employees, although many have used them as Custodians anyway.