The Insanity Of The MLC.
No One Stands A Chance.
For almost eight hundred days we have been trying to get one of our client’s catalogs registered to Word Collections at The MLC. The below is the latest email of many that have been sent on this issue. I wanted to share
From: Jeff Price
Subject: More detailed response Re: xxxxxx Works Review
Date: February 29, 2024 at 6:10:15 PM EST
To: Maurice Russell
Cc: Sean McNamara , Jake Smith Melanie Santa Rosa , Kris Ahrend
Hi Maurice
Jake Smith is sending you a specific detailed response to your below email that provides concrete dates and requests that The MLC has not done or responded to.
From the top of the trees, the facts are that we were first notified that there were conflicting claims on these works in Sean’s email on 2/9/2024, after almost three years after our initial submission of these works.
We submitted the works to The MLC almost 800 days ago and they still are not associated with our account. In addition, there are the ISRCs that should be attached to the works which we have zero insight into as to which works they are associated with.
We submitted to The MLC the xxxx works with all associated metadata and ISRCs for those works again, and again and again and again over the years using every method of submission The MLC has (manual, bulk upload and CWR). No matter what we did/do, the MLC did not/will not register all the works nor provide the needed information to allow us to resolve conflicts or have ISRCs correctly attached to the works.
In addition, until we sent the works and ISRCs for the fourth or fifth time via CWR, there was zero response from The MLC in regard to indicating which works it was not registering to us and why. There was no response/return file for the bulk uploads or manual entry. Nothing. The MLC operates like a black hole. You submit works and information and it literally says nothing back to you. Can you please provide me a reference point to another entity on the planet in the same space as The MLC that does this? There are over 90+ MRO/PRO/CMOs around the world not to mention more entities like MRI. Every single one of them say something back. Not the MLC with, one exception.
Note that The MLC does have ACK files it sends back to CWR submissions so clearly it believes it should have some sort of response file or it would not bother with ACK files. But note, the response files are ONLY to CWR submissions meaning you provide NO response file back if someone uses the bulk or manual entry to submit. CWR is extremely complex and complicated limiting its use only to those with large tech budgets and tech teams. As you are aware of 95% of The MLC’s individual members do not use CWR to submit works. This means you have created a prejudicial and tiered system working to the detriment of the majority of your members. Why?
And as far as the ACK response files we get from our CWR submissions, here is a copy and paste of a typical ACK message we get back:
ERROR: CONFLICT: THE SUBMITTED MECHANICAL CLAIMS ARE IN CONFLICT WITH SPLITS CURRENTLY AT SESAC/HFA. TOO MUCH OF THE WORK HAS PREVIOUSLY BEEN CLAIMED AND THERE IS NOT ENOUGH ROOM FOR YOUR SUBMISSION.
There is zero information in this message beyond The MLC stating it refuses to add us to the composition despite our valid LOD, effective date, clean metadata and associated ISRCs. You do not even bother to give us The MLC work ID in the return file. So now what? I have to go to your website and manually search through your database loaded with bad and incorrect data to try to find this one work (and recall we have tens of thousands of works) and when I do manually scroll through screen after screen to even see the associated ISRCs.
And once I do this, there is nothing in the MLC site that allows me to communicate with the other entities on the work that The MLC and its back-office entity HFA wrongly associated or connected the work. So now I have to try to find a contact email or phone number to reach out to the other entities all because The MLC does nothing. No feedback, not putting the composition into conflict, no holding our royalties. The MLC ignores our data, uses the bad data from its back office vendor, pays the wrong entities, provides no resolution path. And this is the GOOD response.
If you use the bulk upload and manual entry you don’t even get this pittance of a response. You get nothing. We cannot administer works if the entity we are collecting from (in this case The MLC) is literally non-responsive and hides data. We send you data, you send nothing back. Then we have to play Sherlock Holmes in order to try to solve the problem by auditing royalty statements and works associated with our account from a MLC download as The MLC pro-actively tells us nothing. And when we do find the issues (which we did again and again and again) and email them to you (as you have no other way to resolve or communicate the issues) we then have to hope someone at The MLC does the research and responds. If they do not, we have zero recourse.
And here we are almost 800 days later with the works still not registered. Like me or hate me, you can’t dodge the valid point. We know what we are doing, we do it well, and The MLC is not paying us, our songwriters and/or publishers their earned royalties.
We only have this issue with The MLC. Not with any other entity on the planet. This is unique to The MLC. We do not have the same no response/black hole issue the we have with the MLC with MRI, YouTube, Meta, Peloton, DSPs outside of the US such as Amazon, Spotify, Apple, Deezer TikTok etc etc etc. Let me repeat, this issue is unique and specific only to The MLC. Your system does not work as it should. Your back-office vendor HFA has bad and wrong data. Your conflict “policy” appears to be to reject data that is correct and not bother to notify the entity submitting the data unless its submitted by CWR in which case at some point you will send back a ACK return file with zero specificity. And we have not even begun to touch on the issue of ISRCs.
We submit data to The MLC and we have ZERO insight into which ISRCs are/are not associated with the work unless we manually troll through your website (hoping its working when we go to use it), type in a work, scroll through pages of works until we find the right one then manually scroll through pages of ISRCs line by line trying to identify if the twelve alphanumeric digits that identify the ISRC are present. And if they are not, then what? I have no way to find an ISRC that should be attached to our work in The MLC system. It does me no good to have a work registered to Word Collections if you don’t bother to connect the sound recording embodying the work to the ISRC as its the stream of the recording that generates the mechanical royalty.
When we remit our metadata to The MLC via CWR, bulk upload or manual entry, the MLC provides NO feedback of any sort in regard to the ISRCs. We have some works like Rockin’ Around The Christmas Tree with thousands and thousands of recordings embodying that one work. When we deliver these ISRCs to The MLC connected to our work we get no feedback at all on the ISRCs. Are they connected to the work/not connected? If they are not connected, where are they and what are they connected to? How much money have they generated in mechanicals and who has been getting our money and for how long? How do we even resolve this issue beyond sending an email and hoping someone bothers to respond? And when they do, how long do we have to wait as our money is paid to others or not paid at all but sits in the accrued but unpaid bucket? And what if it’s distributed out in a market share allocation despite us delivering the data?
And now let’s move to response times to CWR files. When we send them we first get a “Transaction Accepted” response indicating that according to The MLC the submitted work passed an initial check that it was correctly formatted according to CWR spec. Then we sit and wait for random time periods that can literally take over eight weeks for the submitted work to be added or updated by the MLC. As an example, we submit at the start of January, 2023 and over sixty days later we are still waiting for our work to get associated to us. In the interim two pay cycles have gone by and the prior administrator is getting our money.
Then there are the “reprocessing” files. The October 2023 usage paid to us in January 2024 had reprocessing royalties for us from two years prior for works/ISRCs The MLC had been paying us on prior to the reprocessing date. The MLC sat on our money for over two years earning bank interest that it keeps. Why? Was it The MLC or the DSPs that were negligent?
You cannot fix a problem if you do not admit you have one. The sad part is, there are zero repercussions to the MLC’s actions in the MMA. It can act (and does) with impunity. The beneficiaries are your board members who get to take our (and other) songwriter’s money or The MLC who sits on our money and earns over 4% bank interest year to year.
In the meantime, the constituency you were theoretically built to serve does not get paid all their royalties.
I do hope there will be forthcoming incremental requirements added to the law. As right now, we are all suffering due to its actions.
Thank You
Jeff Price
