How to Set Up a Custodian of Records for 2257

What Is a Custodian of Records?

A Custodian of Records (COR) is the person or entity designated by a producer to maintain 18 U.S.C. § 2257 compliance records and make them available for inspection. Every producer of sexually explicit content must designate a COR.

The COR is responsible for:

• Maintaining all required records (performer IDs, cross-references, production dates)
• Making records available for inspection during normal business hours
• Producing records on demand when requested by authorized inspectors
• Keeping records organized so that any performer's records can be found by searching any name they've used

Option 1: Self-Manage (DIY)

You can designate yourself as the Custodian of Records. This means:

Requirements:

• You must provide a physical address where records are stored and inspectable
• Records must be available during normal business hours
• Your name and address appear on all content as the COR

Pros:

• No ongoing cost
• Full control over your records

Cons:

• Your home address becomes public (it must be displayed on content)
• You must be available during business hours to produce records on demand
• You're responsible for physical security of government IDs and sensitive documents
• No backup — if records are lost or damaged, you're non-compliant

Best for: Producers who have a dedicated business address separate from their home and can commit to maintaining an organized record system.

Option 2: Hire a Compliance Professional

Some producers hire attorneys, paralegals, or compliance professionals to serve as their COR.

Requirements:

• Formal agreement designating them as COR
• They maintain records at their office
• Their name and address appear on content

Pros:

• Professional management
• Keeps your address private
• Legal expertise available

Cons:

• Expensive: $300–500/hr for attorney time, $200–500/mo for ongoing service
• Dependent on a single person's availability
• May not understand industry-specific workflows
• Record access limited to their business hours

Best for: Large studios with legal budgets who want hands-on legal counsel integrated with compliance.

Option 3: Use a COR Service (Recommended)

A COR service like Easy2257 serves as your designated Custodian of Records with a technology platform that handles the entire workflow.

Requirements:

• Subscribe to a paid plan
• Talent completes verification through the platform
• Display the COR service's address on your content

Pros:

• $39.95/scene — fraction of the cost of alternatives
• Records accessible 24/7 (not just business hours)
• Bank-grade ID verification included
• Your home address stays private
• Automated workflows — talent verifies themselves via invite links
• Digital backup — records are never lost
• Audit-ready reports generated on demand

Cons:

• Ongoing subscription cost
• Dependent on the service's continued operation (mitigated by data export options)

Best for: Independent producers and small studios who want hassle-free compliance without exposing their home address.

Setting Up Your COR: Step by Step

If using Easy2257:

1. Create an account and buy a scene ($39.95) or choose a monthly plan
2. Sign the COR designation agreement (we become your designated custodian)
3. Create your first production and add scenes
4. Invite talent via secure links — they handle ID verification and document signing
5. Add the COR statement to your content: *"2257 Records Maintained by Easy2257, [address]"*

If self-managing:

1. Designate yourself as COR in writing
2. Set up an organized filing system (physical or digital with physical access)
3. Create ID collection and cross-referencing procedures
4. Add your name and address as the COR statement on all content
5. Ensure you can produce records during business hours

The COR Statement

Every piece of content must include a statement identifying the COR. For online content, this is typically a dedicated page on your website. The statement must include:

• The COR's name (or entity name)
• The physical address where records are maintained

Example: *"18 U.S.C. § 2257 Record-Keeping Requirements Compliance Statement: The records required by 18 U.S.C. § 2257 and 28 C.F.R. Part 75 for materials contained herein are kept by Easy2257, [address]."*

This guide is for informational purposes only and does not constitute legal advice.