Probably a good ideal for your personal copy, but, would the DOJ permit using it if your Custodian is listed somewhere else.
Here's an article by Paul Cambria that goes over some of the 3rd party issues, and more.
Quote:
Changes to the federal recordkeeping law raise questions and concerns.
Talk about a mixed bag. An adult business owner who does not have the expertise to feel comfortable running a 2257 database may now hire a third party to perform the task, yet he's blessed with full criminal liability for the third-party record-keeper's errors. Sure, he doesn't have to personally sweat over record-keeping issues, but he gets to lay awake at night wondering if someone else's negligence will someday come back to haunt him.
Moreover, third-party record-keeping is fraught with important unanswered questions, not the least of which involves the confidentiality of the process. Assume, for instance, that a single third-party record-keeper is central to numerous producers. When the inspectors arrive for the records of Producer A, will they be put in a position to observe the records (and possible deficiencies therein) of Producers B through Z? If the record-keeper makes a systemic error, does that put all of the producers for whom he keeps records at risk? (Seriously, if it comes to a federal agent's attention that a third-party record-keeper for multiple companies has made a fundamental record-keeping mistake - for instance, not cross-referencing - in one client's database, wouldn't she assume that the same fundamental error exists in all of that record-keeper's databases?) Non-criminally, will deficiencies in your record-keeping become the stuff of industry gossip, harming your sales? Bottom line: Look before you leap into third-party record-keeping, and make sure you've got a contract that keeps the record-keeper's feet to the 2257 compliance fire (including confidentiality clauses and a provision giving you or your representative the right to make unannounced inspections of your own records so that you can sleep at night).
http://business.avn.com/articles/33843.html
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BTW, June 16 is the last day to file for a 2257A exemption.