New 2257 Compliance Guide

[DannyCox]

Originally Posted by RawAlex

Sorry, I have to disagree here. It says "The secondary producer is required to maintain records that identify the primary producer for any depiction and that verify that the primary producer checked the legal age of performers prior to the date of original production"

Read carefully. It doesn't say you have to maintain records of the participants, only records that identify the primary producer (the company that made the content) and that verify that the records were checked. A notarized "we have checked the documents" would cover this, no?

Alex, that's what I said. I said "I read it as I must maintain records of any primary producer I have content from" meaning that I must have a record of who the content is from, not the actual records from the talent. I also said "and that the primary producer must also send me a letter stating that they have checked the required records for the talent they are using". So basically, you just reiterated what I had already written

[RawAlex]

Originally Posted by DannyCox

Alex, that's what I said. I said "I read it as I must maintain records of any primary producer I have content from" meaning that I must have a record of who the content is from, not the actual records from the talent. I also said "and that the primary producer must also send me a letter stating that they have checked the required records for the talent they are using". So basically, you just reiterated what I had already written

Okay, good, sorry, I missed that. I am just thinking that this is the way that secondary producers get out of having to maintain duplicate records, by only having to know who the primary producer is. The downside for programs providing "sponsor content" is that they will have to identify to their affiliates who the primary producer actually is for each scene.