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Who the regs apply to or their roles in record keeping is not changing from the old regs to the new regs. Even if you didn't bother to read the old regs and the new ones, this was explicitly stated so by the DOJ in their original announcement.
Secondary producers have always been required to keep copies, but the Sundance case made this a possible grey area for certain secondary producers. This was something the updated regs do not address.
The part that got Sundance off the hook is still there and they could have easily re-worded it, but didn't.
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