FW: Draft Comments - FW: Transfer Policy Review Preliminary Report - NCSG Public Comment Discussion

Fri Sep 27 08:41:49 EEST 2024

Hello Adebunmi.

Thanks for your question. The proposed recommendations include many areas where notifications of registration changes are sent to registered name holders throughout the process. One key notification can be found in recommendation 11, “Notification of TAC issuance” which states:

“The working group recommends that the Registrar of Record MUST send a “Notification of TAC

Issuance” to the RNH without undue delay but no later than 10 minutes after the Registrar of

Record issues the TAC. For the purposes of sending the notification, the Registrar of Record

MUST use contact information as it was in the registration data at the time of the TAC request.”

Also, Recommendation #19: Notification of Transfer Completion contains a requirement to notify when the transfer has been completed.

There are other places where notifications to registered name holders have been added to the policy.

When it comes to quantity of notices, it is only going to be one per instance. And, as far as whether or not a message goes to a RNH’s spam folder, well, that isn’t under the control of the sender, in this case the registrar involved.

As the non-commercial community, we may want to do more outreach to constituents to ensure the adoption of good practices, like taking advantage of multi-factor authentication when it is available and whitelisting messages from important senders, like the registrars we use. Also, as a constituency, we can advocate for registrars who have not already done so to put in place security measures such as MFA.

I am sorry to hear of your bad experience with a notification, and keep in mind that the policy mandates a 30-day transfer restriction after a transfer, so if a domain is taken maliciously, there is time to address the problem.

I hope this helps and once again, thank you for the question.

Ken

From: Adebunmi Akinbo <adebunmi.akinbo at gmail.com> 
Sent: Wednesday, September 25, 2024 7:51 PM
To: Ken Herman <ken at kherman.com>
Cc: NCSG-DISCUSS at listserv.syr.edu
Subject: Re: FW: Draft Comments - FW: Transfer Policy Review Preliminary Report - NCSG Public Comment Discussion

Apologies for missing the meeting. 

I will do my best to read the reworked comments, but I want to respond briefly to your comment on the 30 days.

We should factor out the following questions and processes:

Question: What is the communication strategy to ensure the non-commercial registered name user respond to any supposed malicious transfer? Would it be once? When does it start counting? How sure are we that such mails do not go to junk or spam mail? 

>From experience, I failed to respond to an ownership and my domain name was restricted from use. My website stopped loading and my mails failed. Apparently, the initial mail sent went to junk.

If the policy reflects a mandatory communication strategy, it may help the seemingly non-commercial registered name holder an opportunity to respond on time to a malicious domain name transfer. 

My 2kobo! 

On Thu, Sep 26, 2024, 12:31 AM Ken Herman <ken at kherman.com <mailto:ken at kherman.com> > wrote:

Dear NCSG Members

I would like to thank everyone who attended today’s session on the Transfer Policy Review. I hope you all found the presentation useful and for those unable to make it, Andrea has circulated a link to the recording.

As a result of this review, and after examining the process for submitting comments, I have reworked and edited the responses, and you can find it at this link:

https://docs.google.com/document/d/1uM38-A98TYK-bED30l4Ue1cFJdNuHaZl/edit?usp=sharing <https://docs.google.com/document/d/1uM38-A98TYK-bED30l4Ue1cFJdNuHaZl/edit?usp=sharing&ouid=105988793481216121706&rtpof=true&sd=true> &ouid=105988793481216121706&rtpof=true&sd=true

As you will see, we won’t be uploading this document per se, but the comments remain basically the same.

Please have a look and provide any comments in the document or to me by 23:00 UTC on Sunday, September 29, 2024. This will give me time to incorporate into the responses prior to the submission deadline on Monday, September 30.

Thanks again and I look forward to any input you may have.

Best regards

Ken

From: NCSG-Discuss <NCSG-DISCUSS at LISTSERV.SYR.EDU <mailto:NCSG-DISCUSS at LISTSERV.SYR.EDU> > On Behalf Of Ken Herman
Sent: Monday, September 23, 2024 7:44 PM
To: NCSG-DISCUSS at LISTSERV.SYR.EDU <mailto:NCSG-DISCUSS at LISTSERV.SYR.EDU> 
Subject: Draft Comments - FW: Transfer Policy Review Preliminary Report - NCSG Public Comment Discussion

Hello again fellow NCSG members

In preparation for our discussion on Wednesday, or as a way for members unable to attend to contribute, you can find in the link below some suggested text for our public comment.

*Link Removed

The public comment is due next Monday, September 30, 2024, so I welcome any additional points that you feel are important to raise for this policy.

One aspect of the policy that I have been wondering about is the transfer restrictions imposed after registration or a transfer. The recommendation regarding this aspect of the policy imposes a 30-day restriction (with some exceptions, which you can see I addressed in the draft comments). I have no issue with the restriction itself, but my question is whether or not 30-days (720 hours) is enough time. Keeping in mind that the transfer restrictions are in place for security reasons, my experience is that the average non-commercial registered name holder does not have substantial knowledge of domain name management activities and may take some time to understand what might be happening in the case of a malicious transfer. Therefore, would 30 days be enough time to understand the issues and respond? If not, what timeframe would be better and why? Or, is my assumption incorrect and 30 days is generally sufficient.

Your thoughts on this, or any of the other policy recommendations, are most welcome and I look forward to our discussion on Wednesday.

Best regards.

Ken

From: NCSG-Discuss <NCSG-DISCUSS at LISTSERV.SYR.EDU <mailto:NCSG-DISCUSS at LISTSERV.SYR.EDU> > On Behalf Of Ken Herman
Sent: Thursday, September 19, 2024 11:47 PM
To: NCSG-DISCUSS at LISTSERV.SYR.EDU <mailto:NCSG-DISCUSS at LISTSERV.SYR.EDU> 
Subject: Transfer Policy Review Preliminary Report - NCSG Public Comment Discussion

Dear fellow NCSG members:

As I reported previously, the Transfer Policy review Working Group (TPR WG) has completed its consideration of the issues outlined in its charter and have produced its preliminary report. We are now in the public comment period for this report, which closes at the end of September. Recently, the TPR WG support team have run two webinars describing the recommendations, along with an opportunity to ask questions. The links to the recordings of these webinars are below.

As the deadline for comments approaches, your TPR WG NCSG representatives (Juan and I) welcome all NCSG members to a working session to consider any issues we may wish to include in our public comment contribution.

We have arranged the call for Wednesday, September 25, 2024 @ 13:30 UTC with the connection details below. I have also requested Andrea to send these details as calendar invitations.

For your reference I have placed below links to the relevant materials, including the NCSG public comment to the interim report published in 2022.

I look forward to your participation in this discussion, but if you cannot attend we welcome any written comments anyone may have.

As always, please feel free to contact me if you have any questions.

Best regards

Ken

Join Zoom Meeting: https://icann.zoom.us/j/98878189584?pwd=ZVpkSVVuaXVqeGRMelNEWW1LMkxQUT09

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PHONE ONLY DETAILS:

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Meeting ID: 988 7818 9584

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

TPR Public Comment page:

https://www.icann.org/en/public-comment/proceeding/initial-report-on-the-transfer-policy-review-01-08-2024

Transfer Policy Review Webinar 1: https://community.icann.org/x/OgKkFQ

Transfer Policy Review Webinar 2: https://community.icann.org/x/PAKkFQ

NCSG Response to preliminary report in 2022: https://itp.cdn.icann.org/public-comment/proceeding/Initial%20Report%20on%20the%20Transfer%20Policy%20Review%20-%20Phase%201(a)-21-06-2022/submissions/NCSG/NCSG%20Response%20-%20Transfer%20Policy%20Review-15-08-2022.pdf

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