Quote:
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Originally Posted by Pleasurepays
"Two commenters commented that the implicit requirement that
records be kept at a place of business is unreasonable and argued that
the regulation should permit third-party custody of records. The
Department declines to adopt this comment. Permitting a third party to
possess the records would unnecessarily complicate the compliance and
inspection processes by removing the records from the physical location
where they were initially collected, sorted, indexed, and compiled. For
example, producers could provide false names and addresses to the third
party as a means to avoid scrutiny by law enforcement. Historically,
producers have used front corporations in order to evade both law
enforcement and tax authorities. Permitting third-party custodianship
would exacerbate this problem. Custodians could, for example, disclaim
any responsibility for the condition or completeness of the records or
be unable to provide additional information regarding the status of the
records. Permitting such third-party custodians in the final rule would
thus require additional regulations to ensure that the third-party
custodian could guarantee the accuracy"
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I'm not talking about a 3rd party. I'm talking about hiring someone, as an employee to be the custodian of records in another office that you rent. That is not 3rd party. That is hiring a custodian of records.
If someone were to have an office building they were willing to rent space in, and/or even supply a service to help hire the new employee, that is still not a 3rd party holding the records. That employee would work for you and only you, get paid by you.
Now it would be a third party if say YOU paid ME to hold your records and I had nothing to do with your company.
BTW... I never said it was a "great idea", I said I was looking into it. Personally MY records are getting moved off shore because that IS where I do business and will be living in 4 weeks. THAT part is indeed a great idea.