Hello ken and all,
I do agree to your position.
I believe that will be the best compromise.
Best regards,
Stephen.
On Sun, Apr 21, 2024, 18:32 Ken Herman <[log in to unmask]> wrote:
> Hello Fellow NCSG Members:
>
>
>
> I request your input regarding an issue under discussed by the Transfer
> Policy Review Working Group (TPRWG).
>
>
>
> *The issue concerns whether to allow for the transfer of a domain to a
> different registrar in fewer than 30 days after an initial transfer. *
>
>
>
> *My recommended NCSG position: Under no circumstances should a registrar
> allow for a transfer in fewer than 30 days.*
>
>
>
> *Please review the points below and let me know if you agree with my
> position or prefer for me to present some other position. *
>
>
>
> Certainly, let me know if you have any questions.
>
>
>
> I look forward to hearing from you.
>
> Ken
>
>
>
> Major points regarding the issue include:
>
> 1. Current policy imposes a 60-day restriction on any inter-registrar
> transfers after a transfer. In other words, if I move my registered domain
> name to a new registrar, I could not move my domain name again for 60 days.
> No exceptions (at least that I am aware of). My understanding is that this
> is a measure to protect against domain name theft.
> 2. In previous discussions, the working group recommended changing the
> lock to 30 days and would require all registries to adhere to this
> timeframe. The proposed preliminary recommendation reads as follows:
>
> *GROUP 1(a) Rec 17(a): The Registrar MUST restrict the Registered Name
> Holder (RNH) from transferring a domain name to a new Registrar within 30
> days / 720 hours of the completion of an inter-Registrar transfer. To the
> extent that a Registry and/or Registrar has an existing policy and/or
> practice of restricting the RNH from transferring a domain name to a new
> Registrar for a different period of time following an inter-Registrar
> transfer, all policies and practices MUST be updated to be consistent with
> this new requirement.*
> 3. This preliminary recommendation has been reopened in light of
> current discussions around the Change of Registrant Data policies.
> 4. The proposed revision would allow a registrar to initiate a
> transfer in fewer than 30 days under certain circumstances. The
> circumstances proposed include cases where the registrant has an
> established relationship with the registrar.
> 5. Some registrants have a problem with the lock, as indicated in the
> Charter for the WG, which notes in paragraph d4 that “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.”
> 6. Some registrars have explained that in a small number of cases the
> 30-day lock imposes a business hardship, and this is mentioned in the
> charter in paragraph d7, “In its survey response, the Registrar Stakeholder
> Group indicated that the 60-day lock hinders corporate acquisitions,
> consolidations, and divestitures of large lists of domains to new legal
> entities”.
> 7. Some registrars even suggest that having any lock after a transfer
> only offers limited protection from domain theft (which is the main reason
> for imposing a lock in the first place). Some registrars report many
> complaints about having a lock.
> 8. Some stakeholder groups express in the WG meetings discomfort with
> any reason to remove the lock, and feel the lock remains an important
> security control..
> 9. In my opinion, evidence of the impact of a lock for reducing domain
> theft is slim. As noted, my understanding is that the lock was initially
> included in the policy since moving domains quickly across many registrars
> was an indication of potential domain theft and locking the domain for a
> period of time allowed for registrants to recover these domains.
> 10. *Given that:*
> 1. *Evidence of the impact of the lock is inconclusive, and*
> 2. *Professional domain managers have for many years coped with
> having the lock, and*
> 3. *Providing the ability of registrars to undo a lock enables a
> registrar to manipulate, and potentially undermine, the trust of
> registrants, and*
> 4. *Reducing the lock to 30 days provides a reasonable compromise.*
>
>
>
> *My suggestion is for NCSG to take the position to retain the current
> language of recommendation 17(a); i.e. to maintain the 30-day lock. I
> further suggest that the working group call on ICANN to more intensively
> study the impact of having a transfer lock, both of the *
>
> *While I would need to confirm, I believe ALAC and the Business
> Constituency have a similar position.*
>
>
>
> *References: all documents (Charter, preliminary reports, etc) can be
> found here: https://community.icann.org/display/TPRPDP
> <https://community.icann.org/display/TPRPDP>*
>
>
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