Business Constituency (BC) comment on IRTP Part C recommendations

[Steve DelBianco <sdelbianco@xxxxxxxxxxxxx>]

The Business Constituency thanks the working group for their work in developing 
recommendations for the Inter-Registrar Transfer Policy (IRTP) Part C.    Below 
are BC responses to working group questions.
What constitutes a “material change” that would trigger the change of 
registrant process?   The policy recommendations defined a “Change of 
Registrant” to be a material change to  Registrant name, organization, or email 
address.

The Business Constituency agrees with the definition of Change of Registrant to 
include any material change to the Registrant Name or Registrant Organization.

We do not agree that a change to the Registrant email address alone is always a 
"material change".  There may be many reasons for a registrant to change their 
email address without changing the status of an individual or the business 
organization.  We would recommend limiting the definition of Change of 
Registrant to Registrant name and Registrant Organization.

The prior and new registrant must authorize the change by using a unique, 
“change of registrant credential”.

Does the working group contemplate the “change of registrant credential” be 
used in addition to the auth code when the domain name is transferred between 
registrars and a change of registrant is implemented?

The registrar confirms that both registrants have authorized the change and 
that the name is eligible for change of registrant, i.e., there is no lock or 
restriction on the name.

We support the requirement of a confirmation from the gaining, or “new” 
registrant.  This would prevent transfers of domain names to entities without 
their knowledge or without any interest in owning the domain name.  Moreover, 
it would limit fraudulent use of a registrant’s information.   But sharing the 
“change of registrant credential” as described may hinder the transfer process 
if implemented.

The Business Constituency agrees that process for transmitting the change of 
registrant credential should be open to alternative methods — as long as they 
are secure.  This may include SMS to the phone number connected to the 
registrant’s account, requiring a two-factor authentication process or other 
methods.  But security should be of prime importance

Conclusion:

The Business Constituency once again applauds the working group for taking an 
innovative approach to the transfer process.

We are concerned that the requirement to share a “change of registrant 
credential” in a transfer will not be implemented in a way that guarantees 
security and addresses all reasons for transfer.   We suggest that the IRTP 
part C group rethink the implementation of the “change of registrant credential”

—
These comments were initially drafted by Susan Kawaguchi and approved in accord 
with the BC Charter.