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Originally Posted by Randomonium
That is part of the question that I had in mind, let's follow it out a little bit.
I agree that 20 hours/week is not much to work. However, it's quite a commitment to be at the office 20 hours/week.
Paysite owners are one thing, but let's just focus on an individual webmaster. Not a newbie, but maybe not a "whale".
Let's say that he/she submits to TGPs, has some free sites, etc. Let's also say he/she has found their conversions to be much better when using sexually explicit images, instead of PG-13 images.
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In this example, I think if someone is doing that well, and they choose to use content that requires docs, and assuming they are provided docs by the sponsor, they should be able afford a small office to store the records. For 2-300 dollars a month, it is certainly worth it for them to seek out a small office or some office space somewhere. Alternately, there is nothing wrong with using a home as an office. It's a little different I think for a webmaster to use his/her home address for records storage, as they have a less than likely chance of being visited as say a model would. Is it bullshit? Yup, I think it is, but it's also about choices and commitment. If an affiliate chooses to use content requiring records, they should be commited to following the law that comes with doing so.
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Coming up next week is Internext. This is a great chance for webmasters to not only have a great time, but one of the best networking opportunities.
If that webmaster goes to Internext, then either they have to have an employee at the office for 20+ hours covering for them, or they are violating 2257.
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AaronM and I actually talked about this a couple of months ago. What do you do in the event you get visited while away at a convention? Well, this part of the issue has a lot to do with the size of your company. As a single webmaster just submitting galleries, you could be in a world of hurt if your number gets called while you were away. My "I-A-N-A-L" advice is to clearly post your hours of operation to not include the times/dates you will be gone. For example this show coming up will not in most cases require someone to be gone for an entire week. Also this show for the most part is held over a weekend. Most smaller webmaster cannot afford to be gone that long anyway. If you are gone for four days, you could adjust your posted hours to the other 3 days of that week.
Now then, if you are a meduim-to-large company, you will probably already have a complaince officer/custodian in place on your staff. Even a part time employee could satisfy the 20 hour requirement. For example Adult.com, I am sure they have someone available at the office while most of the other work-force is away.
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If they don't go, they miss out on all of the knowledge, and opportunities that networking at the shows brings. This means lost opportunities, missed relationships, less than current learning, and quite frankly less fun or quality of life for some.
Once again we see the gap increasing.
Some webmasters (like myself) will react by not using images that require 2257 documentation. That works for me because I mostly do organic SEO, and webmastering is a tertiary income for me. If I had to make my living 100% from webmastering I would want to be able to use explicit images.
But what about full time solo webmasters, who now have an additional burden that is tough for them to afford?
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Again, this is a choice the webmaster will have to make. No matter what business you are in, commitments to time and money will be a huge part of your succesc and ROI. So if a webmaster wants to make it big, they need to do whatever it takes to make it big, even if it means breaking even or even taking some losses in the beginning.
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Most likely, a webmaster who chooses to go to Internext will be just fine. Odds are they won't get a summons or have a records inspection during those 3 days.
But I could certainly see next year, or the year after that as part of the "War on Porn" the government scheduling suprise inspections during major industry events, as well as through the holiday season.
I wouldn't like to have that kind of vulnerability hanging over my head like the sword of Damocles.
It's not so much the 20+ hours/week, as it is the every single week without exception.
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Again, I think they could just adjust the posted ours of business for hat week, and not be gone any longer than absolutely neccesary.
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It's not just conventions/conferences. Want to go on vacation? Got a funeral to attend? Opportunity to fly around the world and close a major deal? - Too bad, there are no exceptions written into the law.
Maybe we will see more and more alliances/partnerships developing amongst the solo webmasters.
If you and three other webmasters you trust team up, then it becomes a lot easier to comply. (Of course forming relationships with other webmasters is easier in person, so you want to go to the show but don't have someone to cover for you ...)
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That's a warm and fuzzy idea, and I know a couple of groups that are doing something like that, and rotationg shows they attend based on several factors like who can afford what and who can sit this show out, etc.
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So for those of you who are keeping 2257 docs, but don't have a large operation, how are you handling this?
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There are some other things people can do to avoid some of the hassle, but they need to talk to their own attorney to make sure he agess with the idea. For example, a small group of people could form an LLC in Nevada (just as an example). Hire a management company to manage your LLC. Name the Manager of the LLC as your Custodian. The management company is open for business and inspection 40 hours a week, and therefore fits within the regulations.