General comments on transfer issues

["Maria Silva Interdomain Org" <msilva@xxxxxxxxxxxxxxx>]

Dear Sirs: 

As for today date, the  transfers between registrars  has become  slow down 
again, because most of the high Registrars has adopted the policy to establish 
by default (this is to say, in ALL CASES, an not just in the specific  cases  
settle down within  the Transfer Policy)    a "REGISTRAR LOCK status" 
associated to the domain names against transfers , so if the registrant want to 
transfer their domain name, they must previously investigate how to un-lock the 
domain, which mainly supposes a "barrier" to   "non English speaker" clients

Also there are some registrars that in case of change of ownership, avoid ack 
transfers request send by other registrar, saying that "the domain registrant 
has recently changed". That is NOT  one of the instances in which a transfer 
request may legitimately be denied by the Registrar of Record.


Submitted on behalf of Interdomain SA, an ICANN Accredited Registrar

Yours.

Maria Silva
www.interdomain.org 

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