Originally Posted by TheDoc

You can keep records in digital form or hard copy form. The records must be kept at your place of business (the location that gets the records, files them, etc) The record holder must be at the place of business for at least 20 hours a week.

A producer is the primary and the secondary producer. So if they say the word producer it means both.

So, if you have a normal office and a studio and you to keep the records at the studio the records must be processed at that location and the studio must be owned/operated by the primary company, otherwise it's a 3rd party holder and that isn't legal. Having your records at a lawyers office that is on retainer is not legal, that is not your place of business, that is your lawyers place of business, unless you pay his rent each month, then you keep the records at his office.