Transfer Process Comments

[Gary Boyd <Gary.Boyd@xxxxxxxxxxxx>]

Dear Sirs

We would like to submit a number of comments regarding the transfer policy.

Transfers are being denied for reasons other than the 9 listed under article
C. In particular, at least one registrar is denying transfers where the
domain name status has been updated in the last 60 days, including when it
has been changed from registrar-lock to 'active'. This is clearly a bizarre
practice as one of the main reasons for unlocking a domain name is to
transfer it.

We have also experienced numerous incidents where resellers of registrars,
who are listed as the admin email address, are automatically rejecting
transfers. This is often after the registrant has informed the reseller of
their intent to transfer the domain. Whilst the policy enables the
registrant to overrule the admin contact, in practice this is not possible
as many registrars do not disclose the registrant email address in their
whois output.

Our final point is regarding the physical authorisation process. The
acceptable forms of physical identity do not adequately provide for the
relationship that registrars may have with their corporate clients. For
instance, if a client wishes to consolidate a number of domains with their
principle supplier, asking for a copy of their birth certificate, drivers
license or even article of incorporation proves what? You can guarantee that
the individual representing the client does not appear on the whois and in
many cases, the domain is registered in the name of a corporate brand and
not the corporate name.


Yours faithfully


Gary Boyd


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Gary Boyd
Group Operations Officer, Group NBT

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