Hello NCSG.

 

I seek your input on an issue being discussed within the Transfer Policy
Review PDP Working Group.

 

For the past couple of months, I have been following discussions within the
WG as a member representing non-commercial stakeholders. 

 

During the period when I have been there, the topic has been around
ICANN-Approved Transfers, and in particular, bulk transfers. These are
situations where a registrar transfers all (or a large number) of its names
to a different registrar. Mainly the issues under discussion concern the
relationship between the different registrars and the registry operators for
the gTLDs involved. 

 

One issue that I see that impacts registrants, and in particular our
constituencies, concerns the amount of time registrants are given when
notified of a pending involuntary transfer (i.e., a transfer of registrar
not initiated by a registrant). All the parties involved agree on the
importance of notifying registrants of a pending involuntary transfer as
well as the need to inform registrants of which registry will gain their
domain name and providing registrants with the option to select a different
registrar before the transfer. 

 

The default notification period is currently "no less than 30 days". 

 

Given my own experience with transfers, even of a voluntary nature, I would
find 30 days an insufficient amount of time for the following reasons (and
there may be others). First, a notification of this nature is unexpected
(unlike a renewal notice). Therefore, my feeling is that individuals and
organizations that are generally unfamiliar with the process of domain name
registration may find the notification confusing and will therefore take
time to understand what is happening and why. Second, knowing a change in
registrar is coming, I feel that registrants need time to evaluate the
proposed registrar and, if necessary, identify a registrar that meets their
needs, especially since the transfer could also involve moving web sites,
e-mail servers, etc. Finally, domain name transfers initiated by a
registrant can take more than a week to execute once a decision has been
made. 

 

Therefore, I seek the input of this group's guidance on what to suggest to
the working group. Options include:

a.	Never mind, 30 days is sufficient.
b.	6 weeks (arbitrary, but perhaps enough)
c.	Longer than 6 weeks (if so, how much).

 

Keep in mind that too much time can also be unhelpful with a tendency to
postpone the decision.

 

For more information the link below to the ICANNWiki page has a summary of
the working group.

 

https://icannwiki.org/Policy_Development_Process_to_Review_the_Transfer_Poli
cy

 

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

 

Thanks for your attention and I look forward to your input. The next WG
meeting is next Tuesday, October 10 @ 16:00UTC. It would be helpful to have
input by then.

 

Thanks!

 

Ken Herman

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