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Username: mathieu
Date/Time: Sun, November 5, 2000 at 4:22 PM GMT
Browser: Microsoft Internet Explorer V5.0 using Windows 98
Score: 5
Subject: answer to fdic


Dear Mr. Christie A. Sciacca
Netbay, the applicant to be the registry for the .FIN domain, and its shareholders wishe to respond to the objection by the FDIC:
1. Netbay and AMB agree with FDIC that “a .FIN gTLD has the potential to provide real benefits to the public in identifying legitimate, regulated financial industry participants”. This is precisely the goal spelled out in the application.
The FDIC comments reflect two misunderstandings regarding the AMB application.
First, the .FIN domain is not intended to be some kind of international accreditation for doing business in the financial sector.  .FIN is not intended to be a closed global top level domain; it is rather a tool to better categorize companies and professionals working in the global financial sector, with reasonable standards for qualification for second and third level domains.
Second (as stated in response to another comment), AMB is acting as a “starter” for the .FIN domain. AMB will not be the association that will establish the conditions and the rules under which second level names will be registered in .FIN.   AMB realized that the extremely short time frame for the preparation of applications for new top level domains precluded the immediate creation of a globally representative sponsoring organization. AMB will act as initial sponsoring organization in accordance with its application, and, as indicated in its application, it will take steps promptly to contribute to the establishment of the .FIN Sponsoring Organization, as a globally representative organization that will represent equitably all the components of the financial sector (e.g., by type of business and geographically). AMB strongly favors a situation in which professional organizations, such as SWIFT  (for banks) and other organizations (for insurance companies and other components of the financial world), would participate actively in the foundation and the management of the Financial Internet Domain Association.

Thanks to the initiative of AMB in responding quickly to the ICANN process, the recognized regulators and professional associations of banks, insurance companies and other financial institutions will have the opportunity to participate to the foundation of the .FIN Sponsoring Organization.

The first task of the .FIN Sponsoring Organization will be to establish a mechanism for determining the qualifications of potential registrants. While licensing and supervisory standards may “differ widely”, we believe that a reasonable standard for domain name registration is achievable by the type of sponsoring organization described in our application. It is true that there are no unique standards over the world for qualifying the entities of the financial sector; the rules have to be practical ones. We further believe that it would be a serious mistake to delay the obvious benefits of a .FIN domain until there is global uniformity in licensing and supervisory standards. Even if it is not possible to provide total security to the public, the goal is that all users will be fully informed of the qualification criteria, namely, that each holder of a .FIN domain name has been accredited in its own country for doing business in a defined sector.

2. As stated above, the application recognizes that the work of establishing standards will necessarily be undertaken by the “expanded” .FIN Sponsoring Organization. Such standards could not be developed in the short time frame for the preparation of this application. It will certainly be the goal of the standards to minimize risk of financial fraud or abuse.

3. AMB does not propose itself as qualified to “judge qualifications of registrants”. Qualifications will be established by the “expanded” .FIN Sponsoring Organization. The reference to news reports is entirely irrelevant. AMB has a well established international reputation for integrity and competence.

4. AMB agrees that maintaining currency of regulatory certification is an important aspect of the entire process of qualifying registrants, and a mechanism for monitoring and revalidating certifications will be part of the qualification process.


Patricia Jutheau-Husson
Chairman of Netbay (Monaco)

Patricia Jutheau-Husson
Chairman of Eurafnet (Luxembourg)

Siegfried Langenbach
Chairman of CSL(Germany)



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