JD - thank you for clearing up that misconception I had on the regulatory process - thought it would have to follow the normal route
I have to agree with Paul that there are some content producers out there that already do meet the proposed and old secondary producer requirements and the WMs buying their content have the required info when they sign the agreements up to and including the URL requirements - where I think most of us are a little fuzzy is the requirement of where and how to put the statement on our domains, as the way we have read it in the past is that it could be on the root domain index page and cover all sub sites on that domain, as long as it covered all of the content on the domain?
Pam makes a good point - there are provisions in the proposal to allow you to email or write to the contact point with what you think this will cause you in monetary costs and what you agree with or disagree with - since these guys are not savvy on the different aspects of the industry, it might be a good idea to somehow give them a big picture look at the different functions of WMs and how they use content so that they can revise or at least clarify the rule before acceptance.