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glowlite, by the "new" 2257 rules as written, if you a primary producer (and they tried to make it secondary as well, which is up for legal debate right now) you are required to have the records at your "principal place of business" and that office must be manned I think it is 20 hours per week (I don't remember the exact words).
So, let's say you work at home, and run a paysite with some nice exclusive content that you have shot yourself (or have entirely purchased as a work for hire) and you have those nice 2257 required model releases and proof of ID. If you don't have an office that you use 20 hours per week, then you have to list your home address as your "custodian of records" and give the name of the person responsible for those records. That person must be an employee or owner of the business, no third party record holders are permitted.
It effectively eliminates the idea of a PO box as a business address, and means that you cannot use your lawyer or accountant or whatever's office as your record holder.
It is way more complicated than that, but it is one of the reasons the newer 2257 rules have driven many amateurs either out of the business or into partnership with existing programs to allow them to hold the records for them and accept to be the primary producer.
Alex
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