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Originally Posted by c-lo
I believe this would make it exempt from 2257 record keeping as it does not display the pubic region or a penetration thereof. I could be wrong but I believe only showing the face & tits would not require documentation.
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If you choose to interpret the rules in any but the strictest way, you run the risk that the FBI will charge you. Then you will need to find the money to for a decent lawyer, otherwise it really won't matter whether your defense has merit. Your site(s) may be closed down pending your trial, so expect to lose your income too.
It is up to the individual, but so much talk about pushing the envelope makes me wonder how many people have really thought about the implications of turning themselves into potential test cases.
As to your specific point, these rules are ostensibly about ensuring that minors are not used in the production of porn. So ask yourself, if the agents inspecting your site(s) see a headshot of a young-looking girl, are they going to skip past it, or are they more likely to require to see the whole picture, even the whole photoshoot? I haven't seen anything to suggest they cannot ask for the whole set and it would surely be logical to do so.