http://www.regulations.gov/freddocs/04-13792.htm
" Pursuant to the RFA, the Department encourages all affected
commercial entities to provide specific estimates, wherever possible,
of the economic costs that this rule will impose on them and the
benefits that it will bring to them and to the public. The Department
asks affected small businesses to estimate what these regulations will
cost as a percentage of their total revenues in order to enable the
Department to ensure that small businesses are not unduly burdened."
Might be good to fill their files with 1000 letters detailing the effect.
Truly the most reasonable approach is to have the photographers and content providers keep the model records... and have the webmasters keep the URL lists... And then each have the contact info for the other. That way, the entity with the most first-hand involvement with each facet has the records.
Oh.. and for those proposing to just rent a closet for an office:
"Sec. 75.4 Location of records.
Any producer required by this part to maintain records shall make
such records available at the producer's place of business."
"Sec. 75.5 Inspection of records.
(a) Authority to inspect. Investigators designated by the Attorney
General (hereinafter ``investigators'') are authorized to enter without
delay and at reasonable times (as defined in subsection (c)(1)) any
establishment of a producer where records under Sec. 75.2 are
maintained to inspect, within reasonable limits and in a reasonable
manner, for the purpose of determining compliance with the record-
keeping requirements of 18 U.S.C. 2257.
(b) Advance notice of inspections. Advance notice of record
inspections shall not be given.
(c) Conduct of inspections.
(1) Inspections shall take place during normal business hours and
at such places as specified in Sec. 75.4. For the purpose of this
part, ``normal business hours'' are from 8 a.m. to 6 p.m., local time,
and any other time during which the producer is actually conducting
business relating to producing depiction of actual sexually explicit
conduct."
So... basically.. you need to be with the records from 8 AM to 6 PM (all 7 days a week??) And they can just show up unannounced. Which, frankly..they can easily justify because that's the only way you "catch" the guilty. Which we are all presumed to be. e.g. That model is under 18 until YOU prove she isn't.