Most of the attorneys have recommended having a separate office for your 2257 records that has absolutely nothing but the records, a work desk, chair, and maybe a poster of the local football team.

Idea being to keep the scope of what the feds review limited to what's in plain sight and avoid raising any other questions.

I'm no lawyer, but from the people i've talked to, if you have an office space that is a place of business, that is open a set number of hours, and has the records available for review, you are compliant. So, for example, if you place your records in an office inside of another office, as long as there is someone there to show them to the records and answer questions, you are in compliance, as far as I know.

Chad is going to be offering a shared lease arrangement that in his view is in compliance with 2257 regulations where producers can share a lease on some space in his office, and he (or his secretary) will provide access to the records. I don't think they are the actual custodians, but simply the people who provide access.