[gnso-irtpd] FOA

[Alan Greenberg <alan.greenberg@xxxxxxxxx>]

I haven't been actively participating in this WG, but have been monitoring.

I understand that the issue of whether the FOA is still really needed 
has come up.
I do have some thoughts on this.

It *might* be true that the FOA is an archaic thing of the past, but 
we do not have any evidence of it at the moment.
There have been a lot of changes with respect to inter-registrar 
transfers recently, and more to come. But we do not yet fully 
understand how these are working or will work. At the moment, 
transfers are still the number one complaint that Contractual 
Compliance receives after Whois accuracy. For the period of 
February-June 2014, there were 2427 transfer complaints received, 
totally over 13% of all registrar-related complaints logged, and 
almost 10 times the number of the next-highest non-Whois related complaints.
Accordingly, it may well be that case that once all of the dust 
settles, the FOA may be seen as of minimal value. But that time is not now.
The WG on Policy and Implementation is actively discussing how issues 
such as this one could be addressed after a PDP has completed if 
needed. I would suggest the IRTP-D WG flag this issue as one to be 
reviewed in a couple of years, and that a recommendation then be 
issued to consider the removal of the requirement if the evidence 
supports it at that time.
Alan