Comment pertaining to new registrar transfer policy

[Ben McGinnes <ben@xxxxxxxxxxxxx>]

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The recent events surrounding the unauthorised transfer and
redelegation of panix.com has illustrated that the current changes to
ICANN policy are inappropriate at best.

The current method of approval, requiring a specific rejection, does
not allow for the possibility that smaller organisations may not have
someone monitoring the contact address in a given five-day period.
Which means that any falsified request made during a period when the
recipient of such mail is known to be away (e.g. through illness or
vacation) will result in an unwanted transfer of domain.

The panix.com affair has proven the amount of disruption which an
unauthorised change has the potential to induce and so greater care
must be taken to prevent such events from occurring in future.  The
process should definitely return to approval of registrar transfer
being dependent on the explicit approval of an authorised contact for
the domain.

Currently it is harder to subscribe to most mailing lists, where a
subscription request must be specifically approved, than it is to
transfer a domain between registrars or owners.  We should be working
to improve security on the Internet, not reducing it as this policy
clearly has.


Sincerely,
Ben McGinnes

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