OK, maybe this is a dumb question, but as AJ and I have been working on version 2.0 of our content management system it suddenly occurred to me how many staffing hours our company spends on compliance... not just recordkeeping, but on development and maintenance of the systems that support the recordkeeping required.

And then it occurred to me that Congress passed the Paperwork Reduction Act years ago, the specific purpose of which was to ease burdens on individuals and small businesses on paperwork and recordkeeping required by the federal government.

One of the parts of the Act says that government is required tol

(1) minimize the paperwork burden for individuals, small businesses, educational and nonprofit institutions, Federal contractors, State, local and tribal governments, and other persons resulting from the collection of information by or for the Federal Government;

Another part says that the Act requires the government to:

(8) ensure that the creation, collection, maintenance, use, dissemination, and disposition of information by or for the Federal Government is consistent with applicable laws, including laws relating to—
(A) privacy and confidentiality, including section 552a of title 5;
(B) security of information, including section 11332 of title 40 [1]

So it seems to me that 2257 *very* clearly violates portions of the Paperwork Reduction Act, particularly with regard to the publication of the custodian's information, when the custodian works out of his/her home and particularly when the custodian is also the performer, and it also seems that 2257 is unduly burdensome.

Now... I know that some of these arguments were made, but they were mostly in the realm of "technical impossibility" rather than a violation of the Paperwork Reduction Act.

I wonder if anyone has seriously looked into this?