he was referred to me by a large content provider, and seemed very well acquainted with 2257.

he feels that the bottom line is risk. if one wants to take as little risk as possible, then one must use their PRINCIPAL place of business as custodian and follow all labeling for the website as described by the new law. you must have your name on your website as the custodian of records.

EVERY DAY mon-fri, you must have someone at that principal place from 8am to 6pm. if you take off to go to the bank, someone should be left there during that time who is capable of giving any law enforcement officials what they need in a timely fashion.

all of this has always applied to the primary producer as custodian. the only difference is that now it applies to secondary producers.

anything else is not according to law, and you can get into trouble - even do up to five years.