Originally Posted by BV

first off needing a model release to publish is not a given in every circumstance

if you hired, or arranged the shoot, and the shots contain lascivious display of the genitals, yes, you would need to follow the same rules as if you were shooting hard core porn

hr4472 (adam walsh bill) amended 2257 and took care of that loophole

if the shots do not contain lascivious display of the genitals, then no you don't

if you did not hire or arrange the shoot and are shooting some random naked chick walking down a public street with no lascivious display of the genitals then that does not fall under 2257, if lascivious display, then yes technically it does, but still a grey area