[gnso-irtpc] IRTP - My View

["Rob Golding" <rob.golding@xxxxxxxxxxxxxxx>]

Inter-Registrar-Transfer-Policy

Registered Name Holders (Registrants) should be free to choose which
Registrar they would like to manage their gTLD domains, based on their own
selection criteria, be that
* cost based
* service level
* cultural reasons
* add-on services
* management selection
etc

To facilitate this choice, Transfers of domains between Registrars should be
a simple, standard and documented process (although exact methods of
implementation to be under the Registrars control).

All current gTLD Registries utilise EPP, and it should be proposed that the
final decided Transfer Policy should be implemented in a common manner
across all Registries, current and future.

As gTLDs can only be registered by ICANN Accredited Domain Registrars - who
each have a unique IANA Number for their Registrar - Registries should use
that unique reference in all communications, making it possible to
Registrants and Registrars to know who each party in a Transfer refers to.

In summary, the domain should be "unlocked" for transfer at the existing
Registar, an "EPP Transfer Code" (Auth-Code) obtained from the existing
registrar, a request to the Registry submitted by the gaining Registrar,
including the Auth-Code, various email/telephone/fax communications to
validate the authenticity of the request, the ability to Cancel (NAK) the
Transfer by the current Transfer Contact (Admin/Registrant) and then finally
the migration of the domain to the gaining Registrar.

There are a number of reasons a Transfer should not be allowed, these
(can/do/should) include:
* domain is subject to a UDRP
* domain is "locked" at the existing (losing) registrar
 - there should be a clear procedure for removing such lock
* domain is "super-locked" at the existing registrar
- a "blanket" lock at the express request of the registrant, with
multi-stage authentication processes required to remove such lock
* the domain has expired
* the domain is less than 60 days since initial registration
* the domain is less than 60 days since previous transfer
* the domain is less than 60 days since a Change-of-Control
* an express denial of the specific Transfer is received from the
Admin/Registrant
* the gaining Registrar is no-longer an accredited registrar
* the domain is under a "proxy service" (hidden contacts)

Questions .... ?
# do we have a firm definition of "Transfer" contact ?
# what do we do if Admin says Yes and Registrant says No (of vice-versa) -
who has the final say ? 
# as registries can/do "expire" EPP codes, is an FOA even necessary now ?

Rob