This application, sponsored
by the Association Monegasquedes Banques, proposes a closed global top level domain
(gTLD) for financial industry participants using the string .FIN. While a
.FIN gTLD has the potential to provide real benefits to the public in identifying
legitimate, regulated financial industry participants, the Federal Deposit Insurance
Corporation (FDIC) objects to the Association Monegasquedes Banques application for
the following reasons:1. In its application, the Association Monegasquedes Banques
states that only those entities that are fully in compliance with applicable legal
and regulatory requirements will be allowed to register in the domain. The FDIC
strongly believes such a gTLD should be sponsored by a group of internationally recognized
regulators under a clear set of criteria for registrants. Nonetheless, at this
time, no consistent or reliable mechanism exists for determining the qualifications
of registrants seeking a domain name within such a gTLD. Licensing and supervisory
standards differ widely across segments of the financial services industry and across
individual nations regulatory agencies.
2. Use of a closed gTLD would appear
to imply certification as to the reliability and integrity of the registrants awarded
second and lower level domain names. However, absent firm standards for qualifying
registrants within a .FIN gTLD, the public may be exposed to unnecessary risk of
financial fraud or abuse by parties masquerading as legitimate financial services
providers. In its response to item E17 of the applications Description of
TLD Policies, the Association Monegasquedes Banques acknowledges that:
At the
present nor (sic) the SO (Sponsoring Organization) nor the registry are in the position
to describe accurately what will be the criteria which have to be met by the potential
registrants to register a .FIN domain name.
3. In Item E18 of the Description
of TLD Policies, the applicant proposes to create a direct membership application
process for proposed registrants that cannot provide a valid certificate for proof
of affiliation or certification by national regulators related to the financial industry.
In doing so, the Association Monegasquedes Banques proposes to establish itself as
qualified to judge qualifications of registrants across an extremely large range
of financial services something no internationally recognized banking regulator
has been willing to attempt. Further, recent statements by French officials,
as reported by the Reuters news service, appear to call into question Monacos financial
regulatory environment as an appropriate venue for such a sensitive and critical
function.
4. Although the proposal calls for limiting rights to use a .FIN domain
name for one-year periods, it does not address how the Association Monegasquedes
Banques would monitor interim changes in the qualifications of registrants nor does
it describe a process for re-validating certifications at annual renewal dates.
Maintaining currency of regulatory certification is critical to ensuring continuing
public confidence in the registrants operating within the proposed .FIN gTLD.
Christie
A. Sciacca
Director
Bank Technology Group
Federal Deposit Insurance Corporation
November
3, 2000