I truly doubt there is a single secondary producer that is completely compliant... unless they only have a few sites.

C'mon! Don't tell me that you have a database that has every single url of every depiction of your hundreds of models on hundreds of sites/galleries! That would take years to accomplish. And no one has ever shown me a script/program that can accomplish this task yet.

I'm sorry but I don't think people are being honest about their compliance. Sure, I believe that many primary producers are compliant with the old regs. But I seriously doubt that most are truly compliant with the new regs.