Vick, this is going to be a major issue. Changing the record keeping requirements YEARS after the fact (depending on your read of this, this could affect content since the inplimentation of 2257), there is a very good chance that not all of the records are going to be that easy to pull up and distribute.
Imagine for a minute a generic content producer, call them "picturemasters". They have sold hundreds of CDs with thousands of images each, each set of images sources from a third party in different countries. Some of the those countries may have privacy laws or other legal restrictions regarding release of personal info. Now these companies have to go back and deal with each photographer and a lawyer in each country to assure they can meet the new 2257 for content that might have been shot 5 years ago. They may be forced to re-contact models that by now may be suffering from model's remorse, asking them to sign ANOTHER document to allow them to distribute thier private information.
You can imagine the headaches.
In the case you just mentioned, do you stop using the content, or do you use the content with a note in file regarding the legal issues?
What about content purchased from a company or photographer that is no longer in business? They should still have the custodian of records, but will that custodian be willing to extract and distribute model releases to all the buyers? Will they charge a fee?
This back dating thing makes this not only a burden, but effectively impossible.
Many many people will end up with gigs of useless content.
*sigh*
Alex
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