Return to tldapps Forum - Message Thread - FAQ

Username: jcrum
Date/Time: Sat, November 4, 2000 at 6:41 PM GMT
Browser: AOL Browser V5.0 using Windows 98
Score: 5
Subject: Objection to .FIN Proposal by FDIC


      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
Bank Technology Group
Federal Deposit Insurance Corporation
November 3, 2000



Message Thread:

Privacy Policy | Terms of Service | Cookies Policy