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Registrar Stakeholder Group Position on Inter-Registrar Transfer Policy Part B

  • To: "irtp-b@xxxxxxxxx" <irtp-b@xxxxxxxxx>
  • Subject: Registrar Stakeholder Group Position on Inter-Registrar Transfer Policy Part B
  • From: "Clarke D. Walton" <clarke.walton@xxxxxxxxxxxxxx>
  • Date: Mon, 5 Oct 2009 19:44:17 -0400

October 5, 2009

Registrar Stakeholder Group Position on Inter-Registrar Transfer Policy Part B 
Policy Development Process


In September 2009, the Registrar Stakeholder Group ("RSG") was asked to provide 
feedback regarding the Inter-Registrar Transfer Policy Part B Policy 
Development Process ("IRTP B").  This Position Paper captures the overall 
sentiment expressed by the RSG Members who provided feedback about this matter. 
 Due to time constraints, however, no formal vote regarding this Position Paper 
was taken.


The RSG notes that there are five issues published for consideration in IRTP B 
and these issues are of great interest to RSG Members.  As such, RSG Members 
look forward to gathering more information about each issue, discussing the 
issues, and sharing additional comments with the IRTP B Working Group in the 

The RSG's position on each of the five issues contained in IRTP B is currently 
as follows:

 1.  Whether a process for urgent return/resolution of a domain name should be 
developed, as discussed within the Security and Stability Advisory Committee 
(SSAC) hijacking report (SAC-40)1.

The Registrar Transfer Dispute Resolution Policy ("TDRP") already exists to 
deal with disputes related to Inter-Registrar domain name transfers.  The RSG 
recognizes, however, that the timeframes in the TDRP may not currently serve 
its users as well as possible.  As such, it may be time to consider adjusting 
and refining the TDRP to make it more effective.  For example, by adjusting the 
existing TDRP, it may be possible to resolve domain name transfer disputes more 
quickly in cases where there is sufficient evidence of fraud.

The RSG encourages more discussion about whether the TDRP is currently serving 
the needs of its users, and if not, what specific adjustments can be made to 
improve its effectiveness.  Moreover, the registrar community should discuss 
potential best practices for the voluntary transfer of names in cases of fraud.

 1.  Whether additional provisions on undoing inappropriate transfers are 
needed, especially with regard to disputes between a Registrant and Admin 
Contact (AC). The policy is clear that the Registrant can overrule the AC, but 
how this is implemented is currently at the discretion of the registrar.

In the RSG's view, the current policy regarding disputes between a Registrant 
and Admin Contact ("AC") is clear.  This policy exists for security purposes.  
While RSG Members are willing to consider changes to this policy, the security 
impact of any proposed change cannot be overlooked.  Further, if some 
registrars are not enforcing this policy, or applying it inconsistently, then 
ICANN might consider publishing an advisory notice, providing guidance for 
registrars on the implementation of current policy.

 1.  Whether special provisions are needed for a change of registrant when it 
occurs near the time of a change of registrar. The policy does not currently 
deal with change of registrant, which often figures in hijacking cases.

 2.  Whether standards or best practices should be implemented regarding use of 
a Registrar Lock status (e.g. when it may/may not, should/should not be 

 3.  Whether, and if so, how best to clarify denial reason #7: A domain name 
was already in 'lock status' provided that the Registrar provides a readily 
accessible and reasonable means for the Registered Name Holder to remove the 
lock status.
The RSG offers two suggestions regarding issues "C", "D", and "E" for 
consideration by the IRTP B Working Group.

First, it is important to agree upon clear definitions of terms prior to 
considering these issues.  For example, regarding issue "C" above, it is 
important to note that a difference exists between a "change of registrant" and 
a "transfer."  The RSG strongly encourages the IRTP B Working Group to agree on 
definitions for terms such as these prior to discussing the issues.

Second, domain name transfer issues must always be considered along with 
relevant security issues.  For example, regarding issues "D" and "E" above, the 
Security and Stability Advisory Committee ("SSAC") has published Reports 
recommending that security implications be seriously considered when dealing 
with domain name transfer related issues.[i]  The RSG agrees with the SSAC's 
view regarding the importance of security, and encourages the IRTP B Working 
Group to also be cognizant of security implications of policy change.

The RSG looks forward to providing additional comments about IRTP B in the 


The opinions expressed by the RSG in this Position Paper should not be 
interpreted to reflect the individual opinion of any particular RSG Member.


[i] SAC 40, Measures to Protect Domain Registration Services Against 
Exploitation or Misuse, available at: 

Attachment: RSG Position - IRTP B FINAL.pdf
Description: RSG Position - IRTP B FINAL.pdf

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