First, I think calling these suggested changes in policy
*clarifications* is a misnomer.
For those involved in the Transfers Task Force that led to the current
policy, and those of us around at the time, it may be easy to talk
about
original intent. But for the hundreds of registrars that have come on
board since then, and those who have undergone significant changes, it
is neither easy nor fair to expect them to figure that out. They
became
accredited and signed their agreements based on what that agreement
and
the existing consensus policies required. To expect them to go back
through the archives, task forces and working group reports,
implementation reports, etc. to be sure they are implementing *what I
meant* not *what I said* is unreasonable.
Regardless, the policy is what the policy is - not perfect. But as
we go
down the road of deciding what if anything needs to change, I think we
should be clear that we're *changing* policy and give due
consideration
to the registrars who have relied on what it says, not what it meant
to
say. I don't want to see the Council brush it off as simply a
*clarification* to make it easy and fast.
Specific comments on the suggested changes:
1. Denial for nonpayment (reason 5)
The concern I have with the proposed changes is that they seem to
imply
that the Auto-Renew Grace Period is mandatory. It isn't, it is a
period
offered by the registry to the registrar. How the registrar chooses to
implement it, or not, varies from registrar to registrar. That's as it
should be in a competitive market. So we need to be careful not to
create a situation where many registrars feel there is no value in a
grace period of any length, and names end up in the RGP immediately on
expiry.
2. Lock/unlock procedures (reason 7)
There needs to be an exception made here for situations similar to
what's described in reason 6: Express written objection to the
transfer
from the Transfer Contact. (e.g. - email, fax, paper document or other
processes by which the Transfer Contact has expressly and voluntarily
objected through opt-in means).
Some registrars, including Go Daddy, have products/services that a
customer may opt-in to at the time of registration. The whole point of
it is addtional security and safety. So turning it off may be more
complicated than performing other functions, but the customer has
chosen
the more complicated option.
There needs to be an allowance for the registrant to choose something
else, and for the registrar to be able to provide it.
3. 60 days of initial registration (reason 8)
No comment.
4. 60 days of previous transfer (reason 9)
No comment.
Tim Ruiz
Vice President
Corp. Development & Policy
The Go Daddy Group, Inc.
-------- Original Message --------
Subject: [registrars] Transfer Policy Clarifications
From: Ross Rader <ross@xxxxxxxxxx>
Date: Thu, December 13, 2007 2:03 pm
To: Registrars Constituency <registrars@xxxxxxxxxxxxxx>
Registrars,
The GNSO Council is about to embark on a policy development process to
clarify some issues related to the existing transfer policy. These
issues are enumerated in this document:
http://gnso.icann.org/drafts/Transfer-Denial-
Clarifications-23aug07.pdf
The Council has chosen not to form a task force to undertake this
work. As a result, they have requested that each constituency submit
their views on the issues per the following clause of the bylaws:
"a. If the Council decides not to convene a task force, the Council
will request that, within ten (10) calendar days thereafter, each
constituency appoint a representative to solicit the constituency's
views on the issue. Each such representative shall be asked to submit
a Constituency Statement to the Staff Manager within thirty-five (35)
calendar days after initiation of the PDP."
I have volunteered to facilitate this process. If you have views on
the issues described in this document, please send me an email
outlining those views no later than 5pm EST. Thursday September 20th.
I will then incorporate the statements into a single document and
forward them to Council for their consideration.
If you have any questions, please let me know.
Ross Rader
Director, Retail Services
t. 416.538.5492
c. 416.828.8783
http://www.domaindirect.com
"To solve the problems of today, we must focus on tomorrow."
- Erik Nupponen