Choosing a 2257 Compliance Platform Is a Liability Decision
When you compare two 2257 compliance vendors, you are not comparing software features — you are comparing who carries your federal record-keeping liability and who satisfies your payment processor's AN 5196 / VIRP audit.
This guide walks through what Easy2257 includes today and the specific questions to ask any vendor (including SnapSign) before you commit. We won't claim numbers we can't verify on SnapSign's side; the goal is to give you a framework that lets you evaluate honestly.
What Easy2257 Includes
| Requirement | Easy2257 |
|---|---|
| Government-ID verification (bank-grade authentication + facial comparison) | Included on every plan |
| Cross-reference index (searchable by legal name, alias, screen name, content title) | Auto-generated as scenes close |
| Custodian of Records service (third-party physical address) | Included on every paid plan |
| 2257 statement page (named Custodian, address) | Included; public statement URL |
| Producer attestation (timestamped, IP-logged) | Included; required for scene close |
| Model releases (per performer per scene, PDF-archived) | Included; required for collab content |
| Depiction storage (28 CFR 75.2(a)(1) — actual file linked to record) | Included; AES-256 encrypted, SHA-256 hashed |
| Unauthenticated removal portal (VIRP / TAKE IT DOWN compliant) | Included at /report/removal |
| 48-hour TAKE IT DOWN Act NCII SLA enforcement | Automatic |
| Monthly acquirer compliance report (AN 5196) | Auto-generated 2nd of each month |
| Annual compliance archive (full ZIP for inspection) | Included |
| Solo Creator pricing | $9.95/month or $107.40/year |
| Per Scene pricing | From $19/scene |
| Producer / Studio / Enterprise plans | Available — quote on request |
Questions to Ask SnapSign (or Any 2257 Vendor)
These are the questions that determine whether a vendor actually carries your liability. Ask them, get specific answers, get them in writing.
On the Custodian of Records
- Do you provide a Custodian of Records service, or do I designate my own? Many vendors store records but do not become your Custodian — meaning the COR address on your 2257 statement still has to be yours.
- What is the physical address that appears on the 2257 statement? A real, staffed location during business hours is the federal requirement.
- How do you handle inspection requests? The Custodian must produce records on demand at the address.
On Records Themselves
- Is the cross-reference index searchable by every alias and screen name a performer has used? Federal regulation (28 CFR 75.2(b)) requires searchability by every name.
- Do you store the depiction itself or only the metadata? 28 CFR 75.2(a)(1) requires the actual content to be linkable to the performer record.
- What integrity hashing do you apply? SHA-256 hashing of every record is best practice for inspection-ready chain of custody.
On AN 5196 and VIRP
- Do you generate the monthly acquirer compliance report automatically, or is it a manual export? Manual reports get missed; automatic generation does not.
- Do you host an unauthenticated removal portal? VIRP and the TAKE IT DOWN Act require this. The portal cannot require an account.
- Do you enforce the 48-hour NCII removal SLA? Software enforcement beats human SLA tracking.
On Retention
- What is the retention period and how is it enforced at the record level? 28 CFR 75.5 requires 7+ years.
- Can you produce a full compliance archive on demand? If not, an inspection will be hard.
Decision Framework
The core question is: does this vendor become my Custodian of Records, or do I still have to figure that out separately?
If the answer is "you still need your own COR," you have not solved the most expensive problem. Renting a compliance office costs $2,000–5,000/month plus staffing. Listing your home address publicly is not an option for most creators.
If the answer is "yes, our address goes on your 2257 statement and we make records available for inspection," you have outsourced the federal liability. Everything else — UI, pricing, integrations — is a secondary consideration.
Easy2257's COR service is included on every paid plan. Ask any other vendor the same question.
Getting Started with Easy2257
Solo Creator: $9.95/month or $107.40/year (annual). Per Scene plans for collab shoots. Studio and Enterprise for higher-volume operations.
See pricing · How it works · Compare plans · Get started free
Related: Complete 2257 compliance guide (2026) · How to set up a Custodian of Records
Informational only — not legal advice. Verify vendor claims directly with each provider before committing.