SECOND-RATE `NOT YET RATED'.

Byline: Glenn Whipp Film Critic

Kirby Dick's ``This Film Is Not Yet Rated'' is everything you ever wanted to know about the MPAA ratings system -- and less. It's distorted, meandering and devoid of constructive criticism, but Dick somehow manages to make us sympathetic to the arbitrary, anonymous moralizers of the Motion Picture Association of America.

Dick divides his movie evenly between attempting to expose what he sees as the history of the MPAA's censorship and hypocrisy and exposing the identities of MPAA members themselves. To accomplish the latter goal, he hires a good-natured private investigator whose personal life, for some reason, becomes part of the movie -- to set up surveillance outside the MPAA's Encino headquarters.

Dick wants us to know who these people are, but it doesn't take a rocket scientist to realize that the MPAA's policy of shielding its members' identities is actually a good idea. Anonymity keeps the lobbyists at bay and minimizes attempts at influence and intimidation.

But Dick doesn't really bother to think these things out, subscribing to the Michael Moore school of firebrand filmmaking where facts never stand in the way of emotional manipulation. To that effect, Dick doesn't mention how the MPAA's voluntary rating system dramatically improved filmmakers' lives after the restrictive Production Code, or how the MPAA works in partnership with movie theater owners.

Instead, he goes traipsing through MPAA raters' garbage cans and offers the oft-repeated claims that the MPAA gives a free pass to violence while freaking out over sex (true), grades indie films more harshly than studio-backed movies (questionable) and possesses a grade-A phobia over scenes of female sexual pleasure (which probably has more to do with the fact the most directors are men) and homosexual sex (did Dick see ``Brokeback Mountain?'').

Dick interviews indie filmmakers like John Waters, Kevin Smith, Kimberly Peirce (``Boys Don't Cry'') and ``South Park'' agitator Matt Stone, and somehow manages to get actress Maria Bello to say, ``That's what made me want to fight for my pubic hair,'' in relation to the MPAA's objection to her sex scene in ``The Cooler.''

As important as her pubic hair may be to Bello, you get the nagging feeling while watching ``This Film Is Not Yet Rated'' that there are more important issues facing us today. Yes, the MPAA's rating system is screwy, but talented filmmakers have been working around their eccentricities for years, creating adventurous, provocative movies.

Is there a better system? Probably. But I don't hear Dick offering any answers.

Glenn Whipp, [phone].

glenn.whipp(at)dailynews.com

THIS FILM IS NOT YET RATED - Two Stars

(Not rated: graphic sexual content)

Director: Kirby Dick.

Running time: 1 hr. 37 min.

Playing: Landmark's Nuart in West Los Angeles.

In a nutshell: Undernourished documentary that does the unthinkable -- makes you sympathize with the arbitrary, anonymous moralizers of the MPAA.

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