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Old 02-19-2015, 10:21 PM  
NALEM
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Quote:
Originally Posted by Joe Obenberger View Post
It's really hard to believe that any attorney who is knowledgeable in this area would advise a 2257 compliance statement that does not disclose a physical, on-the-ground address. Perhaps this is miscommunication between the two of you? I'd suggest that you go back to him and zero in exactly on that issue. Some provisions in the 2257 scheme are murky. This isn't. The statute (18 USC 2257 (e)) and the Regulations (28 CFR 75.6) could not be clearer.
Hi Joe, hope you are doing well.

Whenever something doesn't make sense, or doesn't follow the pattern that everyone else seems to follow, we will push back. I don't recall their exact reasoning, but I think a part of it has much to do with where the companies and third party vendors (hosting, billing, etc.) are based. Our agreements with legal counsel include indemnification clauses and professional liability insurance/bonds in case they are absolutely wrong and the advice followed caused harm.

See you in Tempe!
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