My Public Comment on Potential Change to Registrar Accreditation Insurance Requirement.
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 coverage. 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. lawrence@xxxxxxxxxxxxx (+234) 08033509558, 08070892705