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>*
>
>
>
>
>