Hi Manju.

Thanks for your input. TBH, I hadn’t considered the distinction or even specifying “business” days, and it has not been mentioned in the policy discussions. I had assumed calendar days, mainly because that is what is used when days are specified at all. I have observed that when a large number of days (30 or 60, for example) is specified in a policy document it does not come with a modifier however for smaller numbers (I have seen “5” and “7” mentioned), then it usually specifies calendar days.

Therefore, I am assuming the “30” is calendar” and if I ask for “business” I anticipate that I will hear that what constitutes a “business day” can vary across countries and is therefore avoided.

Perhaps others on the list can confirm my understanding.

If nobody objects, I would like to suggest 6 calendar weeks. Here’s why.

The noncommercial institutions I have helped obtain a domain name usually do not have any knowledge of, or experience with, domain registration. Someone in the institution is assigned as the focal point and becomes the administrative contact while a hosting company is retained to manage the e-mail and web presences and assigned the technical contact. Every once in a while, on a predictable schedule, the admin contact receives a renewal reminder, and generally budget for that. Receiving an unexpected notice of an involuntary transfer is something else and has the potential to cause confusion, which IMO can take some time to resolve. It seems to me that for institutions that operate in challenging locations or perform sensitive functions, the geographic location or some other aspect of the acquiring registrar might be an important factor, and I would prefer to give these entities the time to investigate alternative registrars and initiate the voluntary transfer.

I welcome all comments and thoughts. Of course, whatever emerges from the working group will go through a comment period, but probably it’s best to have our preferences recorded before then.

Thanks for everyone’s attention.

Ken

From: NCSG-Discuss <[log in to unmask]> On Behalf Of ??? Manju Chen
Sent: Sunday, October 8, 2023 3:22 AM
To: [log in to unmask]
Subject: Re: Input sought for Transfer Policy Review PDP Working Group discussions

Hi Ken,

Thank you for the thorough explanation!

I have a question: did the WG specify whether you're talking about calendar days or business days regarding the options?

Because '30 business days' would be almost the same as '6 weeks of calendar days'.

Following your rationale of 30 days being too short; would it solve the problem if we specify it's 30 business days? Or did you already have the business days in mind when suggesting 30 days is too short?

Thank you!

Best,

Manju 

On Fri, Oct 6, 2023 at 8:56 AM Tomslin Samme-Nlar <[log in to unmask]> wrote:

Thanks, Ken.

They are indeed points to consider. It would really be good and helpful if anyone on the list has had an experience with bulk transfers or know someone who has to share the experience. 

The only other point (and I don't know if it makes sense to consider it in such a policy) is registrants who might be experiencing say an Internet shutdown at the time of notification. But I guess such a case would not affect only bulk registrations but all transfer notifications for that matter.

Warmly,
Tomslin

On Fri, 6 Oct 2023, 06:42 Ken Herman, <[log in to unmask]> wrote:

Hi Tomslin. It’s hard to be sure about the actual process, but I believe that after the 30 (or whatever) days, options besides the chosen gaining registrar won’t be available to registrants before the transfer is complete.

So, it’s not just the decision to go somewhere else, that decision needs also to be acted upon and preferably completed before the deadline.  Registrars contractually have up to 5 business (I believe…I would have to look it up) days to respond to a request for transfer. Not all (in my experience) adhere to that requirement. Seeing as in these cases the registrar is getting rid of these gTLDs anyway, they may act faster. Or maybe they don’t particularly care, so won’t respond in a timely way.

Anyway, just to keep these points in mind.

Ken

From: Tomslin Samme-Nlar <[log in to unmask]>
Sent: Thursday, October 5, 2023 3:05 PM
To: Ken Herman <[log in to unmask]>
Cc: [log in to unmask]
Subject: Re: Input sought for Transfer Policy Review PDP Working Group discussions

Hi Ken,

My assumption is that the current "no less than 30 days" does not include the execution time, it gives the registrant 30 days to consider if the gaining registrar works for them. If that is the case, in my opinion the current 30 days time frame  is sufficient for a registrant to perform the assessment. 

Nevertheless, I would be keen to hear of people's personal experiences whether they struggled to do such an assessment within 30 days and why.

Warmly,

Tomslin

On Fri, 6 Oct 2023 at 01:12, Ken Herman <[log in to unmask]> wrote:

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:

1. Never mind, 30 days is sufficient.
2. 6 weeks (arbitrary, but perhaps enough)
3. 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_Policy

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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