New 2257 Regulations As Published A Few Minutes Ago..

I'm so tempted to put the 2257 page in a password protected directory and then post my email address to the "inspectors" and have them request a password if they want to know where my records can be found.

I can't find anywhere in the regs that say the page has to be freely accessible. It just has to be posted on, or linked to from the main site entry page.

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...the final rule permits web sites to contain a hypertext link that
states, ``18 U.S.C. 2257 Record-Keeping Requirements Compliance
Statement,'' that will open in a separate window that contains the
required statement.

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Originally Posted by IntenseCash.com

WOW that is crazy. Now I just have to figure out what to do because there is no way I want to put my home address.

Mark

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Just sublet a small room from someone with a file drawer. ;)
Oh and leave a camcorder with a digital camera there too.

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Originally Posted by MWCren

I'm so tempted to put the 2257 page in a password protected directory and then post my email address to the "inspectors" and have them request a password if they want to know where my records can be found.

I can't find anywhere in the regs that say the page has to be freely accessible. It just has to be posted on, or linked to from the main site entry page.

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Yeah me neither.

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Originally Posted by Dzinerbear

Essentially, do whatever you need to do to appear compliant so billing companies and sponsors don't freak out, but just know that no one is ever going to come knocking on your door.

In their own country, the Department of Justice would require an army of thousands to start tracking down producers of porn and requesting proof of age. And even if they had that army, I doubt they'd be wasting resources flying around the world, aside from the fact that they don't have the jurisdiction to do so.

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YAY!!! Finally someone saying exactly what I am saying too!!! But let me strengthen this by saying it is illegal for any USA citizen to fly to another country and enforce this law which ONLY exists in the USA. It is also not possible for them to request local authorities check your 2257 docos since 2257 only exists in the USA.

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Originally Posted by basschick

Dzinerbear - having models who look old enough may not protect you. remember, this law is about closing porn sites, not protecting minors.

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The law is NOT about closing porn sites. As a matter of fact it is not a law at all, it is 2257 REGULATIONS which outline how the DOJ bureaucrats should enforce the laws. The laws themselves are about keeping things legal and legit.

People, stop panicking, read the new regulations and go get a real legal opinion if you feel they affect you, isn't a couple hundred dollars worth it???

cheers,
Luke

Well said and put Luke & Michael :)

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Originally Posted by basschick

what Dzinerbear is recommending is now a crime, as of june 24. you cannot put a post office box address on your pages.

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I'm not suggesting the U.S. residents get post office boxes and try and trick of DoJ into thinking that's their physical business address. What I'm suggesting is that if you live in Peru and you run your porn sites out of your home, you may not want everyone on the planet to know exactly where you live. If you actually listed the location of the records as P.O. Box 204, then perhaps a sponsor or processor may decide you're not compliant and refuse to deal with you. So, since no one is ever going to fly to Peru to see you, you gather up all your records, make sure they're all a-ok, keep them in a separate location in your home, and list your address as 123 Ave Maria, Suite 204, Lima Peru. This way, those sponsors and processors will say, "Hey look he's compliant" and you get to continue doing business.

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Originally Posted by basschick

making up the law as you go along can cost you everything. it isn't worth it.

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Yes, you're exactly right. And basing any action you might decide to take on anything you read on this board is insanity. Because everything you're reading right now is just opinion. Anyway, I don't know why we continue to do this, I think I'm going to go down the road, I heard that they're converting a low-revenue producing Walmart into a gas chamber and I don't want to miss it, oh wait, I saw Paris Hilton smearing her tits all over some car while eating a hamburger, I think I'm actually hungry.

dzinerbear

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Originally Posted by Dzinerbear

Yes, you're exactly right. And basing any action you might decide to take on anything you read on this board is insanity. Because everything you're reading right now is just opinion. Anyway, I don't know why we continue to do this, I think I'm going to go down the road, I heard that they're converting a low-revenue producing Walmart into a gas chamber and I don't want to miss it, oh wait, I saw Paris Hilton smearing her tits all over some car while eating a hamburger, I think I'm actually hungry.

dzinerbear

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lol! Yeah..I think chilling a bit and educating yourself as best as possible is a good idea right now.

P.S. Don't forget to get laid too if you can. It HELPS! :P

My 2 big concerns (now that it is clear that webmasters promoting affiliate sales are custodians of record as secondary producers) are:

1. Getting the electronic copies of the model information on my existing sexually-explicit banners/buttons, free sponsor content, and paid content-provider content. I have the model information from one content provider already. Sponsor-hosted galleries should not be a problem as they are hosted on another domain, provided I am not using a sexually-explicit image link. I may have to remove some content or switch to text links or nonsexually-explicit banners/buttons.

2. Creating segregated 2257 records which are indexable by model names, URL's, etc. with the image/video attached. I'll see if I can whip something up using a spreadsheet program like Excel (which I know) or a database program like Access (which I know little about). I'd be reluctant to pay more than $200 for a 2257 record-keeping program if I can't do it myself.

Inspection/business hours? I work at home and live alone, so I'd be safest posting hours of say 3AM to 7AM M-F. At least, I can guarantee being here or having a house/dog sitter here when I am out of town.

And I'll be even more vigilant in avoiding association with sites that do not emphasize 18+! I'd rather not get a 2257 audit just like I'd rather not get an income tax audit.

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Originally Posted by Fister

. . .

2. Creating segregated 2257 records which are indexable by model names, URL's, etc. with the image/video attached. I'll see if I can whip something up using a spreadsheet program like Excel (which I know) or a database program like Access (which I know little about). I'd be reluctant to pay more than $200 for a 2257 record-keeping program if I can't do it myself.

. . .

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When you get that record keeping process working let us all know . . . and name your price. I'd bet it'll be worth more than $200 to a lot of secondary producers.

Would be interesting to know what 2257 Compliance.com is asking for their service.

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Originally Posted by Dzinerbear

basing any action you might decide to take on anything you read on this board is insanity. Because everything you're reading right now is just opinion.

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Re-read that paragraph people.. Its true.

If you are concerned about these 2257 regs then you should consult an attorney.

Regards,

Lee

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Originally Posted by jonjayw

When you get that record keeping process working let us all know . . . and name your price. I'd bet it'll be worth more than $200 to a lot of secondary producers.

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Interesting idea...but I see lots of hurdles in using my suggested approach as a commercial product for resale as it uses a third party's software.

Fister . . . don't sell the end product (you're right it's based on licensed software) . . . sell the "how to do it" instruction manual. "How to keep 227 records using XXXX"

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Originally Posted by jonjayw

Fister . . . don't sell the end product (you're right it's based on licensed software) . . . sell the "how to do it" instruction
manual. "How to keep 227 records using XXXX"

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Hmmm, perhaps a downloadable ebook priced well under the products made by the software programmers.

if an adult text site has ZERO adult images on it, is it still required
to have a 2257 statement with home address ??

google cached versions of our sites - that will have images we have
now removed - cached pages would be exempt - wouldn't they ??

2257 has nothing to do with text or audio, correct ??

~Bell

for text, i'd say no. for audio, if someone is reading sexually explicit materials, i could see 2257 applying, although i've never heard of that.

best ask a lawyer on that one - it's an interesting question.