There is one thing that worries me about all of this.
That's the fact that these new regs have a retroactive effective date. Meaning the requirements are not based on the old regs before 6/23 and the new regs after 6/23. It's actually as if the old regs never existed, and that these new regs have always been there.
That's one of the things the FSC is fighting, but who knows what will happen.
So if you are a gallery submitter who has been using sponsor content for a number of years, come the 23rd you need to have on file all those model ID's even if you pulled the galleries a year ago.
Now of course most sponsors are refusing to release model ID's, and are instead coming up with other promo systems for affiliates. I don't blame them for this. I wouldn't release the docs to just anyone, but that's beside the point. It may be illegal.
Suppose for a second that the DoJ is on a witch hunt, and that's why they made the new regs retroactive. They may have been recording affiliate promo activities over the past couple years, and then on the 23rd they can legally nail you for not having model ID's for old long gone galleries.
Just something to think about.
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