RE: [registrars] FYI: re transfers

["John Berryhill" <john@xxxxxxxxxxxxxxxxx>]

> Anyway, registrars will invoice/warning their clients BEFORE the end
> of the term.

There is an implicit requirement in the RAA for two reminders:

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http://www.icann.org/nsi/icann-raa-04nov99.htm#IIJ

Registrar shall register SLDs to SLD holders only for fixed periods. At the
conclusion of the registration period, failure by or on behalf of the SLD
holder to pay a renewal fee within the time specified in a second notice or
reminder shall, in the absence of extenuating circumstances, result in
cancellation of the registration.
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In classic ICANN drafting form, it is ambiguous whether these reminders
include pre-expiration reminders.   Although the sentence begins with "At
the conclusion of the registration period" the grammatical structure of the
sentence attaches this time point to "shall... result in cancellation of the
registration" as the "time specified in a second notice" may have been the
time specified in a notice sent previous to "At the conclusion of the
registration period".

The other long-cycle obligation with respect to any registration is to
retain records relating to that registration for a period of at least three
years.

Again, the primary problem here is one of accounting.  Any audit of a
registrar pursuant to, say, a public stock offering is going to require that
a registrar be able to specify with precision what are its contractual
obligations and what are the time periods associated with those contractual
obligations.  One cannot say, "I have a bunch of one year contracts, with
continuing record retention obligations for three years, and my obligations
under those contracts terminate 'a few days before 45 days after they say
they expire'".