Smokey,
Obviously I don't know CCBill's policies, but I believe reporting underage content and stolen or unlicensed content are two completely different issues.
To use your example,
If they get a site with many playboy.com watermarked images, they have no way to tell if they are licensed by playboy.com or not. Thus the site would be approved for processing, but upon first official complaint, they would then lose their processing.
If they review a site that looks underage, I guess it would fall into three categories:
1) Blatantly underage. Immediate rejection during site review process.
2) Questionable (say they look 16-17, but could be 19-20). My guess is they will ask the site for some kind of proof before approving them.
3) Looks of legal age. Gets approved.
I'd also guess then that if they get complaints about the age of models in point 2 or even point 3, that doesn't require a DMCA to take action as it has nothing to do with copyrights.
If they receive complaints from people questioning the age of models on the site, all they have to do is ask the site owner for verification/proof of age. Does this mean a site could be processing with them right now with 17-year old models? Sure, but I can't think of any processor this situation would not apply to. As long as they do investigate upon receiving complaints, I think they are doing their job.
Disclaimer: This doesn't represent any official CCBill views, it's solely my own 2 cents
