FW: Request for Comment - Transfer Policy Review Preliminary Recommendations

Sat Apr 27 11:46:27 EEST 2024

Hello again NCSG. 

In this message I come back to the discussions regarding Change of
Registrant Data, which used to be simply Change of Registrant. To recap, the
TPR WG recommends removing the policy of changing the data about a
registrant from the transfer policy. Members feel that this has nothing to
do with "transfers" per se, and therefore would benefit from a separate
policy.

I have updated the working document I shared with you previously with a bit
more information on some of the recommendations, so feel free to have
another look and let me know if ther is anything here to be concerned about.

Current discussions are focused on whether or not there should be a transfer
restriction when making a change to registrant data. This could be a
concern, but WG members have pointed out that there are already many
controls regarding the security of registrants, and, more concretely, thee
has in the past been substantial confusion by RNHs regarding a lock after a
change in registrant data. The example often cited is that a RNH may update
their name or e-mail address in anticipation of a transfer only to discover
that they are now blocked from a transfer for 60 days simply because they
made those changes. 

I can see this point and others presented, so I still don't see any issues
with removing the restriction or with any of the other changes in the
proposed recommendations, however some of you with more experience may have
some concerns. If so, please let me know and certainly let me know if you
have any questions.

The document I prepared can be found here:
https://docs.google.com/document/d/1Z8wx8KXhrwGmeKQEt2SJ8r271YcQ8-yk/

Ken

From: NCSG-Discuss <NCSG-DISCUSS at LISTSERV.SYR.EDU> On Behalf Of Ken Herman
Sent: Friday, March 29, 2024 6:17 PM
To: NCSG-DISCUSS at LISTSERV.SYR.EDU
Subject: Request for Comment - Transfer Policy Review Preliminary
Recommendations

Hello fellow NCSG members.

As an NCSG representative to the Transfer Policy Review Working Group
(TPRWG), I seek your input on proposed preliminary recommendations currently
under discussion.

Specifically, the working group is looking for feedback on the section of
the transfer policy related to Change of Registrant.

This document contains the text of the preliminary recommendations under
discussion. Please use this document to add any comments that I can take
back to the working group or questions that I will try to answer. 

https://docs.google.com/document/d/1Z8wx8KXhrwGmeKQEt2SJ8r271YcQ8-yk/edit?us
p=sharing
<https://docs.google.com/document/d/1Z8wx8KXhrwGmeKQEt2SJ8r271YcQ8-yk/edit?u
sp=sharing&ouid=105988793481216121706&rtpof=true&sd=true>
&ouid=105988793481216121706&rtpof=true&sd=true

Note that the working group leadership emphasized that this is not final
language, but simply a way to gauge response from a wider audience.

Great if I can have all comments or questions by next Friday, April 5. If
there is enough interest, I can arrange a zoom session and invite some
speakers who are familiar with the working group.

Some background/context:

1.	The current transfer policy (see the link below) includes a section
"II. Inter-Registrant Transfer (Change of Registrant)" which the working
group charter (also linked below) considered to be a problem. As noted in
the charter, "According to the Transfer Policy Review Scoping Team Report,
the Change of Registrant policy 'does not achieve the stated goals' and 'is
not relevant in the current & future domain ownership system.' "
2.	The working group, as you can see in the preliminary
recommendations, suggests changing title from "Change of Registrant' to
"Change of Registrant Data" (aka CORD), in recognition of the fact that
changing a registrant is mainly the action of altering the contact
information associated with a domain name registration.
3.	The working group also suggests removing this section from the
transfer policy and creating a new, separate policy governing any change in
registrant information.
4.	One issue that the group contended with concerns a 60-day lock on
any transfer of a domain after changes to registration information and
decided to eliminate any transfer lock. The rationale was that the lock was
confusing and restrictive to registrants. The TPR WG Charter also refers to
this: "Survey responses and data provided by ICANN's Global Support Center
indicate that registrants do not understand the 60-day lock and express
frustration when it prevents them from completing an inter-registrar
transfer."
5.	A substantial amount of discussion within the WG has focused on the
ability of registrants to "opt out" of notifications of changes to
registration data. 

Personally, I did not see anything in the discussion or the recommendations
that would be a cause of concern, with the possible exception of the issues
around opting out of notifications of changes to registration data. But
there might be some issues I am not aware of so please have a look and let
me know what you think. 

Please feel free to contact me if you have any questions.

Thanks!

Ken Herman

NCUC EC NA Rep

ken at kherman.com <mailto:ken at kherman.com> 

Current transfer policy:

https://www.icann.org/resources/pages/transfer-policy-2024-02-21-en

TPR WG details:

https://community.icann.org/display/TPRPDP/Transfer+Policy+Review+PDP

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