Proposed CPA Regulations for Statutory Licenses

There has been some activity at the Copyright Office regarding the proposed regulations for statements of account under the compulsory mechanical royalty license.  (Or as we call it around here, “the woefully inadequate regulations for statements of account”, but that’s another story.)

I commend to those of you who are interested (and all songwriters) the proposed regulations regarding certified statements of account filed jointly by the Harry Fox Agency, the Nashville Songwriters Association International, the National Music Publishers Association and the Songwriters Guild of America.

In fairness, this is a knotty subject because at the end of the day the compulsory licensee has to find a CPA who is willing to put their name to an Annual Statement (not to mention their E&O carrier’s name).  So you can’t make the hurdle of transparency so high that the CPA has to take on undue risk (these folk are not risk takers, in case you haven’t noticed), but at the same time there has to be a process that instills enough confidence in songwriters that there is not open revolt.  (Which seems nigh, if you read the songwriter comments.)

We’re going to continue to review these proposed regulations as will many others, but I have to say that at first blush it is as fine a piece of legal work as one could hope for and all concerned should be commended for a fine personal showing, doing good by our business and demonstrating thoroughness in the best traditions of the legal profession.