Here’s how it seems to me:
Paysite owners are collecting the models docs and keeping them on file.
Everyone else, i.e. adult bloggers, TGPs, freesites, link lists, review sites etc (everyone who didn’t produce the content) seem to be pretty much ignoring 2257. Some have a statement that says, “The 2257 docs are maintained by the producer” or something similar.
I might be wrong, but I haven’t heard of a secondary site like an affiliate blog ever getting hit with an inspection or a problem. In fact, it’s been a long time since I heard of an inspection of anyone in the news.
So I’m not sure where 2257 even stands legally ain’t more.
Are affiliates in infrigement of the law? Don’t really know. I don’t really care because I’m in Canada and my government has laws protecting people’s privacy, so even if I did have the docs of a porn model appearing on my blog, and I don’t because SC isn’t giving them out, I couldn’t even show the DOJ if they came knocking without breaking my own country’s laws, and the DOJ couldn’t even come here to inspect.