Ross - this is a very useful statement.
I have the following recommendations, stemming primarily from ICANN's March 31st WDRPS report.
1) In the background section, we should point out that ICANN report reflects well on registrars' compliance with accuracy requirements:
a) Only 16,045 domain names (out of about 30 million) were the subjects of inaccurate whois reports;
b) ICANN received only 19 follow up complaints indicating dissatisfaction with registrars' compliance or follow up - i.e., In over 16 thousand cases, registrars took satisfactory action toward accuracy;
c) in a large number of cases, inaccuracy was caused by technical or legal reasons (name on hold, server change, etc.) - i.e., this will continue to happen regardless of any new verification requirements.
2) Another important point to glean from this report is that 40% of all reports were made by just 20 individuals (0.3% of all reporters), suggesting that we have a few watchdogs paying attention probably for business reasons, but that this is not a broadly shared concern. This is not to say that it is not a legitimate interest, but just that we should measure the cost of any new compliance requirements against the size of the group that really focuses on this.
3) In terms of suggestions, I would also:
a) ask that the TF identify how and why current safeguards and requirements have not worked. For example, the data problem reporting system or the accuracy announcements - where have they fallen short? Otherwise, we will continue to suggest new mechanisms without knowing what specific problem we are addressing.
b) do you think there is a value to also looking at ccTLD accuracy requirements?