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My Public Comment on Potential Change to Registrar Accreditation Insurance Requirement.

  • To: comments-raa-insurance-15jan15@xxxxxxxxx
  • Subject: My Public Comment on Potential Change to Registrar Accreditation Insurance Requirement.
  • From: Lawrence Olawale-Roberts <lawrence@xxxxxxxxxxxxx>
  • Date: Wed, 11 Mar 2015 14:27:52 +0100

The insurance sector in my part of Africa has had to go through great reforms 
over the last 10 years, and the process is still evolving owing to sharp 
practises from operators within the sector. This has resulted in a great lack 
of trust by many would be clients who are forced to seek insurance covers, 
because premiums when due are not paid or lost to hidden clauses imbedded into 
the insurance package. For this reason and more Africans from my divide view 
insurance companies as a drain pipe, as their insurance cover amounts to 
nothing tangible where claims are eventually made. The time through which 
claims are paid out where they are eventually approved, devalues such claims 
and almost always leaves the claimant with terrible experiences going back and 
forth for months or years in some cases. 

Nigeria’s local content law also does not allow businesses with its 
headquarters in Nigeria to seek such covers outside the shores of the country.

The value of the local currency in Nigeria to 1USD currently stands at over 
200Naira, an insurance cover of $500,000usd thus amounts to approximately 
seeking insurance in the sum of (N100,000,000.00k) one hundred million Naira.

For this reason, seeking and paying premiums over an insurance bond of 
$500,000USD would not only pose a difficult condition to fulfil but will put 
any registrar operating in my region at a great disadvantage especially with 
their peers in the west and other developed economies as they would be forced 
to pass the cost of servicing their premiums to their clients, thereby 
inflating the cost of acquiring a domain name locally. The ripple effect of 
this is that the local DNS market would keep securing their domain names from 
western companies, as their pricing would remain cheaper whilst capital flight 
would continue.

Are there valid reasons why ICANN should continue to require CGL insurance? The 
CGL concept does not transfer the required benefits to the end user as 
envisioned by ICANN, so it should be discontinued or made optional for 
companies that desire to use it as a marketing clause for their clients. 
Has any registrar or gTLD or ccTLD registry found CGL coverage useful in 
running their businesses? I do not have adequate information in this regard, 
but i am sure every statement issued by ICANN accredited Registrar’s to their 
clients offering a 30day money back guarantee is not because of the CGL 
Are there alternatives to CGL insurance that would provide similar or better 
protections for registrants that could be instituted either as new contractual 
requirements or as "best practice" recommendations? As an option to what 
presently exist’s, I propose a contributory floating fund of between $5,000 to 
$10,000 (possibly managed by 2 or 3 Insurance firms) which all Registrar’s 
contribute to based on the volume of domain names registered or maintained 
within a period. Once the fund contributed by a Registrar is drawn down on 
claims to a certain extent, it should be replenished by the participating 
Registrar. This floating fund contribution where not uterlised, stands in the 
credit of the Registrar. 
If the CGL requirement is maintained, is the $500,000 limit appropriate? Where 
the CGL requirement is to be maintained as an option for insurance, it’s value 
(an equivalent of 100million naira) should be reduced by 80% in the least.
If ICANN eliminates the CGL requirement, should the elimination apply to all 
registrars or should "waivers" be granted only on a case-by-case basis? The 
requirement i believe should apply to all Registrar’s.

Lawrence Olawale-Roberts is a Fellow of ICANN and the CEO of MicroBoss 
Technologies, operating out of Nigeria. MicroBoss is a company staging to 
become an accredited Registrar of ICANN.

Lawrence Olawale-Roberts
Managing Director,
Microboss Technologies.
(+234) 08033509558, 08070892705

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