Thank you Mr. Kisters for your detailed comments on the
whole of the questions put forward in the document.I like to add to your Answer
on Q68 (What measures should be in place to protect registrants from the possibility
of a registry operator's business failure?)
I agree with your proposal to reserve
10 % of the earnings to a special fund. But the basis should not be the total earnings,
but rather the total of inital registration fees.
The risk of business failure
does not increase with the periode of time the company runs the registry (it will
in fact decrease with the years to come). Nevertheless the possible damage (loss)
to registrants will increase with increasing number of registrants.
So my proposal
would be: 10 % of initial registration fee in the first year, 9 % in the second,
8 % in the third and so on down to 1 % for the tenth and all following years.
this
would prevent the fund to increase indefenitly, while the risk actually decreases.
Furthermore
the fund should (for obvisious reasons) not be external, but a part of the company's
capital stock and reserve.
Kind Regards
Rüdiger Schultz