[gnso-impl-irtpc-rt] question re: FOA expiration and COR

[Caitlin Tubergen <caitlin.tubergen@xxxxxxxxx>]

Hi All,

Thank you to everyone for your helpful feedback on the Transfer Policy.

An IRT member flagged an issue with respect to section I.2.2.3(c), or the
FOA expiration in conjunction with a Change of Registrant.  The text of
section I.2.2.3(c) is:

"The FOA labeled "Initial Authorization for Registrar Transfer" shall expire
under the following circumstances (c) a Change of Registrant is completed
further to Section II.3."

The issue is that it may be difficult for the gaining registrar to know if
there has been a Change of Registrant.

(1) One option would be to leave the text as is, which would require the
Gaining Registrar to determine if certain contact information (registrant
name, registrant org, registrant email) matches at the time the transfer is
requested and the time the transfer is completed, by taking Whois snapshots,
for example. The consistent Whois format of the 2013 RAA may mitigate this
burden, since the data should be easier to parse.

(2) Another option would be to remove this section, since Section II.3.3
requires a registrar to lock the domain name for 60 days after a Change of
Registrant.  Since the new language of I.2.2.3(a) provides that FOAs will
expire after 60 days, this may make the requirement for an FOA to expire
after a Change of Registrant unnecessary.

I welcome everyone¹s thoughts, preferences, or other proposed solutions on
this issue.  I would appreciate any feedback by Tuesday, 17 March.

Thank you!

Kind regards,

Caitlin

Attachment: Transfer Policy.docx
Description: Microsoft Office

Attachment: smime.p7s
Description: S/MIME cryptographic signature