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>* > > > > >