Anonymous (faceless) content vs. 2257 question

Xtube got me thinking about this, because I have some really hot ideas for content, and they include getting random guys to do faceless posing (among other things) in very specific postions. Since the position is the niche, there is no need for this one group of guys to show their faces during their video shoots.

So then... how can 2257 docs be kept on these guys without an online face to prove who they are? Is this a recipe for trouble? Are any other sites doing this and doing fine with what documention they have?

It is still possible for a model's body to look under 18, so I don't want to cause no ruckus.

Paul Morris does this with his gang bang videos, and even refers to them as "Don't show my face #1" and "Don't show my face #2" etc.

Any tips?

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Originally Posted by Rimmates.com

Xtube got me thinking about this, because I have some really hot ideas for content, and they include getting random guys to do faceless posing (among other things) in very specific postions. Since the position is the niche, there is no need for this one group of guys to show their faces during their video shoots.

So then... how can 2257 docs be kept on these guys without an online face to prove who they are? Is this a recipe for trouble? Are any other sites doing this and doing fine with what documention they have?

It is still possible for a model's body to look under 18, so I don't want to cause no ruckus.

Paul Morris does this with his gang bang videos, and even refers to them as "Don't show my face #1" and "Don't show my face #2" etc.

Any tips?

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I'm just guessing here, but their isn't anything in the 2257 requirements that say you have to prove who that guy is. If you have the model Id and everything that 2257 requires, I don't think they can prosecute you because the model doesn't show his face on film. We have done that many times, as has many studios, by allowing the model to wear a mask or hood. We have all the files.....we have the ID's, with signature. All the DoJ has to do is call the model and verify.

Bill

this is what we've been told by a reliable attorney

take a photo of the model as shown in your video WITHOUT face exposed then, take a photo of the model in the exact same position with FACE exposed and holding their two id's (one on either side) of their head - these photos should accompany your 2257 records

I would still consult your own 2257 attorney for information you can depend upon without hesitation

we always check 3 sources for their differing views and interpretations of this complex set of codes

To be safe, I would make sure that you shoot some video (which doesn't make it into the final product) that had the model's face and ID in a similar pose/situation to the "faceless" scene, and keep that as part of your 2257 records. To be extra double safe, maybe take a pic of the model (face and faceless) holding a copy of the day's newspaper with his name and DL # written in magic marker across the front of the newspaper.

I agree with Bill, there's absolutely nothing in 2257 requiring that, but I believe that overcompliance (taking an extra step to do your best to comply with the spirit as well as the letter of the law) can't possibly hurt and if you to happen to get inspected/investigated, will show intent to comply as best you can.

Methinks you veterans are just baiting me to get me to post!


2257 does not care whether your published images have faces or not. In order to comply with the records keeping requirements, an investigator should be able to select one of your images and say "Where are the records for this?" and your records should show that Model X is the model in that image and here is his ID. And if the faceless model in the image appears to be 6'4" and 140 pounds, the model ID for Model X better not be for a 5'6" musclehunk that is 200 pounds of hard red meat.

I do not believe for one minute that any one of you has an entire set of images of a model without the face showing. I am sure that even if you agree not to publish a model's face, you must have at least a couple of pics of the model from his audition that show a face.
You do not need to duplicate poses or go to any great lengths to create an image set that shows (1) this body goes with this cock (2) this face goes with this body (3) this face then goes with this body and this cock and then (4) this ID goes with this face, body and cock.

Your records for Model X should also show where those images are located, so when the investigator looks at the file for Model X it shows "Image Set 16B" which matches up with that set of 50 faceless pics labeled "16B" and the non-published images from the same shoot that show his face. Once you can show that you have a copy of the model ID, that the model was 18 at the time of the shoot, that the ID and records match the images you have published, and that you have your records in order, you have probably satisfied the typical investigator. Only if something does not match up or looks sketchy would you need to provide more meticulous evidence.

2257 requires one ID. If you are shooting young men, it is recommended to require 2 forms of ID. If the models look young, the daily newspaper is a good way to show that the model was on your set that day and not 2 months before when he was still 17. I encourage producers to take a digital image of the model holding his ID near his face.

By the way, the X Tube business model is probably different than your situation as a producer. Personalized advice is a good idea before taking on any adult venture.