4472 is really sort of 2257a, the new requirements, most of which deal with shooting down the loopholes created by the Sundance decision (that secondary producers don't have to keep records)

I think that very few people really take the time to read the regs and even fewer really understand them. I've read them a dozen times and there's still stuff that I don't understand... though I'm not a lawyer so I at least have an excuse

I think there is a fair amount of "head in the sand" on the issues.