Loyalfans Creators Are Still Primary Producers

Loyalfans runs platform-level 2257 verification for creators and performers appearing in uploaded content. That covers Loyalfans' secondary-producer obligations. Yours, as the person actually filming the content, are separate, non-transferable, and personally enforced under 18 U.S.C. § 2257.

This guide covers what records a Loyalfans creator actually owes in 2026, including the additions from Mastercard AN 5196 and Visa VIRP.

What "Primary Producer" Means

The federal regulations at 28 CFR Part 75 define a primary producer as anyone who actually films, videotapes, or photographs sexually explicit content. If you point a camera at yourself or anyone else and capture explicit content, you are a primary producer.

Where you upload the content is irrelevant to whether you owe records. Loyalfans is a secondary producer / distributor. Your records are independently yours.

The Five Records

Government-issued photo ID for every performer (including yourself)
Cross-reference index searchable by legal name, alias, screen name, content title
Custodian of Records at a physical address during business hours
2257 statement on every page or piece of content
7+ years retention under 28 CFR 75.5

For collab content, add a signed model release per performer per scene under AN 5196 / VIRP.

The Custodian of Records Problem

Federal law requires records to be available at a physical address during business hours. For a solo creator, the three real options are:

Home address — becomes public record on every 2257 statement
Office rental — $2,000–5,000/month with staffing
COR service — third party becomes Custodian; their address goes on your statement

Easy2257 includes Custodian of Records on every paid plan. Our address appears on your 2257 statement, not yours.

AN 5196 and VIRP for Direct Sales

If you sell anything outside Loyalfans — your own site, off-platform tips, custom content invoiced separately — your processor will ask for documented age verification, signed model releases, and a monthly acquirer compliance report under Mastercard AN 5196 and Visa VIRP. Loyalfans' platform compliance does not extend to your direct sales.

What Easy2257 Handles

Self-verification — bank-grade ID + facial comparison
Content log — register every piece of content; index builds itself
Custodian of Records included
Model releases for collab content
Removal portal — VIRP / TAKE IT DOWN compliant, 48-hour SLA
Monthly acquirer report for direct sellers

Solo Creator plan: $9.95/month or $107.40/year.

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Informational only — not legal advice.

Loyalfans 2257 Compliance Requirements for Creators (2026 Guide)