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
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.
(+234) 08033509558, 08070892705