Expert: Dan Pepper - 2/18/2009

Question
Hi Dan
My name is Will And I'm a webmaster trying to build a adult site I have a couple of questions can you help!
(1) If I was to operate a adult web site and the pictures and content are being shot in various locations can I keep all my compliance's at my home like my 2257/custodian of records and model release forms.I will be operating a realty kinda of site like picking up women like at bars and stores walking down the street etc can I just keep them at my house all my documents.
(2) Can the webmaster also appear on the web site if chooses to.
(3) is there a difference between 2257 and the custodian of records and if there is where can I get the custodian  documents.
Thanks a whole lot Dan
William..

Answer
(1) If I was to operate a adult web site and the pictures and content are being shot in various locations can I keep all my compliance's at my home like my 2257/custodian of records and model release forms.I will be operating a realty kinda of site like picking up women like at bars and stores walking down the street etc can I just keep them at my house all my documents.

I assume from your question that you will be acting as the primary producer, doing the filming.  Provided that you are comfortable identifying your home on your location statement on your website, and your home otherwise qualifies under the rest of the requirements of 2257, including the number of hours that your "home" office is available for inspection, then yes.

(2) Can the webmaster also appear on the web site if chooses to

Do you mean in the films themselves or just on the website?  If you mean shooting yourself with your talent on film, you run the risk of a prostitution charge.

(3) is there a difference between 2257 and the custodian of records and if there is where can I get the custodian  documents.

The custodian of records is part of the 2257 regulations.  You may find this link helpful:  http://www.usdoj.gov/criminal/optf/links/2257-compliance-guide.html