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.
Regards
Patricia Jutheau-Husson
Chairman
of Netbay (Monaco)
Patricia Jutheau-Husson
Chairman of Eurafnet (Luxembourg)
Siegfried
Langenbach
Chairman of CSL(Germany)