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Untrue. The proposed rule changes are as sure to become the regulations unless somebody sues to stop them.
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Not likely. But even if they are they will have to have some back ruling like the june 3, 1995 rule for the original 2257.
"this media was produced prior to "insert date" and does not require the secondary producer to maintain records blah blah blah the custodian of records is "blah blah blah at blah city in blah state."
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I would suggest seperating it, in fact the new regulations suggest seperating it.
75.2 (e) Records required to be maintained under this part shall be segregated from all other records, shall not contain any other records and shall not be contained within any other records.
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Again there is "NO" paragraph (d) or (e) in the current 28 CFR 75. These are only "proposed" rules and not likely to be approved as they are.