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Originally Posted by Harmon
And if so, why can that record keeper not be my sponsor? In other words, just link all 2257 pages from my sites to the corresponding site/sponsor's 2257 infos? The records are there and available for inspection. 
Also, if you run a thumb TGP and link to FHG's, but in the thumb prewview you only use face shots, will that be exempt? This is all hitting me like a ton of bricks |
Specifically on record-keeping, they want to deal with one company at a time. The investigative scope of 2257 investigations is not extended to parent or child companies, etc, so basically what they want is a record-keeper who works at the place of business of the business that has done the publishing in question. Third-party record keeping was specifically rejected.
There is also a somewhat vague requirement to 'keep records separate', which, to my mind, translates to 'whatever you do you'd better know which model goes with which pics and where they have been used', but which could translate into a requirement to keep separate records for each company you own..... legal opinion needed from your lawyer on that one.