Proposed 2257 changes

[patandsam]

All “secondary producers” should be aware of this little item in the PROPOSED changes:

“proposed 28 CFR 75.2(a)(1)
would require computer site or service producers to maintain a ``hard'' physical or electronic copy of the actual depiction with the identification and age files, along with and linked to all accession information, such as each URL used for that depiction.”

What does this mean to you?

Read all about it here:

http://www.regulations.gov/freddocs/04-13792.htm

DOJ Comment deadline is August 24, 2004. Have your attorney draft a letter. How much would that cost? How much might that help?

[patandsam]

"Pursuant to the RFA, the Department encourages all affected
commercial entities to provide specific estimates, wherever possible, of the economic costs that this rule will impose on them and the benefits that it will bring to them and to the public. The Department asks affected small businesses to estimate what these regulations will cost as a percentage of their total revenues in order to enable the Department to ensure that small businesses are not unduly burdened."

Right..."unduly burdened".

[Scorpio]

Thanks Sam,
I finally understand better.. I also printed it for future references.

The only thing i was afraid of, is that we had to also put the physical address of the models on the internet. And now reading the proposed regulation, they only need a picture and date of birth so i'm fine with that.

Also if i understand correctly: ``hard'' physical... meaning we have to print all the pictures with the legal documents and keep all that in a folder (indexed and everything..)?

[patandsam]

Of course they are not clear. But, they do say “hard physical or electronic copy”, so that tells me it can be electronic. CD or DVD? Not to be trite, but isn't a hard drive hard?

“....maintain a ``hard'' physical or electronic copy of the actual depiction with the identification and age files....”

But, who can say?

[patandsam]

I think I’ll build a closet (ironic) by the front door to hold everything. I can just open the door and have them look right there. Draw a curtain so they can’t see anything else.

It sounds like some kind of strange movie.

Also, do primary producers have to show them copies or originals? I keep the originals in a safety deposit box to avoid loss from fire or natural disaster. Will that no longer be allowed? If not and they are destroyed by some unforeseen event, what then? Am I just out of luck because I've complied with their regulations?

Merde!

[Scorpio]

yeah kinda confusing.
I'll just print all thumbs for each sets of pictures and keep that in my records with all legal documents... so it's easier just in case someone comes to inspect my content. I'll just send them the bill for the ink cartridges LOL that'd be funny to do.

[Scorpio]

Originally posted by patandsam
Merde!

Where the hell does your French come from? LOL

[patandsam]

Here, I’ll answer my own question.

They don’t mention model release forms at all that I can tell. They simply want copies of ID’s that show age. I guess then all we need is a copy of their ID with the names cross-referenced.

I guess.

[patandsam]

I've been watching too many Cadinot movies.

[Scorpio]

The model release forms i guess must be kept in your files at home.
Online, they just want a link to an ID - passport... to verify the age.

And is it me or they say the same thing over and over?

[patandsam]

It’s a government thing.

They explain what they are about to explain, then they explain it, and then they explain what they’ve just explained.

Clear as mud.

In this case, the first part is where they say WHY they are doing what they want to do, and they kind of explain it a bit. The second part (starting here: PART 75--CHILD PROTECTION RESTORATION AND PENALTIES ENHANCEMENT ACT OF 1990 AND PROTECT ACT; RECORD-KEEPING AND RECORD INSPECTION PROVISIONS) about 2/3 down is where the actual meat is.

But, that’s just my reading of it.

[Scorpio]

hahah too funny
It's actually the first "government" thingy i read. I think i did pretty good to understand them. But once gain, they always have some "in between" lines we can't see.

[patandsam]

And, it raises many questions.

Unfortunately, in this day and age it’s frightening to contemplate asking them questions directly. It’s like waving a red flag at a brain damaged bull.

(Again, images of some bizarre movie or cartoon.)

I think I’m going to have my attorney write a letter. Then I can stand behind her and try to get answers.

[Scorpio]

Yeah i think it's the way to go.

[Eyesusneen]

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