retroactive punishment on affiliates
 

do these new regulations basically say

'look, we're saying that you - a secondary producer - should have been compliant the entire time, and that ANY pic you have ever published needs documented and we can come ask for that any time. even if you take all your images down now, you are still responsible for all the thumbs and images you have published over the years.'

is this what it says? if so, sponsors are basically being forced to choose whether to leave their affiliates vulnerable to the feds or give out their model's info. we're totally sitting ducks even if we take down all images.