There are several implications arising from the new 2257 regulations, both legal and practical, in respect of "anyone" having access to model information.
For whatever it is worth, I submitted my comments on the regulation changes. You can do the same by visiting
http://www.regulations.gov/ do a keyword search on
2723-2004 and then scroll down the page for "Submit a Comment on this Regulation" [comments have to be in by August 24th].
But in the meantime, although I understand those concerns, my view is that if the excrement hits the fan, it's me that could be facing 5 years inside. Therefore unless the rules are changed to specifically allow something else, once they are in effect I shall not be buying content from anyone who does not provide complete, in-clear records.
If I screw up, that is my fault, but I'm just not ready to run the risk of being a test case for someone else's theories on what may or may not be acceptable.