[registrars] FYI: re transfers

["John Berryhill" <john@xxxxxxxxxxxxxxxxx>]

>Of course, all requirements to validate a transfer should be 
>established according the RAA rules.

Not all registrars provide RGP service, nor does Verisign require a
registrar to be configured to do so.  RGP is an optional registry service.
There seems to be some creep between a registry providing a service, such as
auto-renew and RGP, and registrars being required to perform additional
tasks because the registry offers a service. 

The transfer requirements themselves are the source of one of the problems
with "after expiration" transfers.  A domain registrant will frequently
purchase other services in addition to domain name registration, such as
hosting, dns, or email. 

If 

(a) the registrant is using <user>@<domain>.<tld> as the administrative
contact address for <domain>.<tld>, and 

(b) the registrant is using a registrar's bundled email service for that
address,

then the requirement to permit transfers after expiration of the domain name
would appear to require registrars to continue to provide email service
after expiration of the contract for email service.  Otherwise, the
registrant is not going to be able to confirm transfer via that email
address to the gaining registrar, because email service was discontinued at
the end of the contracted term.

A registrar cannot be required to provide bundled services, such as email,
for longer than the contracted term, unless the idea is to impose a
requirement for maintenance of expired email accounts which is not imposed
on ISPs or other email service providers.

Some registrars change DNS on expired names and point them to a "Renew your
domain name" page upon expiration of the domain name, so that the registrant
can renew *during* the AGP and be notified of the expiration before the name
slides into the more expensive RGP.  Even if the admin contact email address
through that domain is being serviced elsewhere, the email is going to be
shut down.  It is debatable whether operating in this manner helps more
registrants become aware of the need to renew their domain names less
expensively than using RGP.  However, whether "renewal notification by DNS
change) is or is not, a preferable "act now" notification to the registrant
is purely a matter of opinion.  

Another class of "edge" cases at the end of the auto-renew grace period.
Even if the registrant requests transfer to the gaining registrar near the
end of the auto-renew grace period, the time periods between (a) the
registrant's request, (b) the gaining registrar's confirmation, (c)
transmitting the transfer to registry, and (d) the transfer at registry, are
all variable.  Hence, the domain name may be deleted by the registry at the
end of the auto-renew period, even if the registrant requested transfer
prior to the end of the auto-renew grace period.  

Alternatively, we could make the default registration term 13 months instead
of 12 months.  Then, no one could possibly fail to renew a domain
registration, right?