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Allison, with due respect to your learned lawyers, I think that the DOJ intention is to make the rules as difficult to comply with as possible. The cross reference requirements, the single image to model release matching, the secondary producter provisions, etc, are all created specifically to make it somewhere between hard and impossible for people to have complete records AT THEIR BUSINESS LOCATION. I read no provision for remote access to third party locations for those documents.
It is clear also that they have made no provision for "custodian of records" this time around. You can't have your lawyer, your buddy, or some guy selling his services be your custodian of records - you have to have the records. This is another reason why I am not sure that electronic access would pass muster.
The idea is good, but I am not sure of the reality of the situation.
Scoreman, thanks for that info. I would like to see what more programs are considering doing here.
Alex
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