Originally Posted by Joe Obenberger

The Department of Justice has promulgated massive amendments to the regulations implementing Sections 2257 and 2257A that will be published in tomorrow's Federal Register and will become effective ninety days later.

The changes are substantial and far-reaching. The most positive change, especially for small companies and individuals is that Third Party recordkeeping will be permitted. 2257 notices will legally be able to provide the name and address of the Third Party custodian, which will go far to increase privacy and security and reduce the costs of compliance.

The regulations also implement the Adam Walsh Act's requirement that a Notice appear on every page of a website. The small piece of good news is that the Notice can be linked, which is different from last year's DOJ Proposal. The burdensome news is that the official comments make it clear that every covered constituent element of a website needs to be individually covered in a Notice, video clips, gallery images, etc.

Lots of nuts and bolts changes, including such things as the kind of ID required of US citizens doing a shoot abroad.

Look for details tomorrow on xxxlaw.com or sign up for our Legal Bulletin.

I'll also cover the changes in my Legal Seminar at Internext, 9:00 am, Tuesday, January 13.

JD