Transfer denial reasons: ambiguities

["Andrew Moulden" <andrew@xxxxxxxxxxx>]

I have no doubt that the nine denial reasons were a genuine attempt to put an 
end to issues involving registrars who were forcing registrants to jump through 
never-ending hoops just to have their domains transferred away. However, the 
new denial reasons suffer from so many ambiguities that in some cases these 
rogue registrars have just found other workarounds to the policy.

A few examples:

"Evidence of fraud" - in relation to what, specifically? In the event that the 
registrar suspects, or claims to suspect, that such evidence exists, how is the 
matter resolved? One registrar recently took it upon itself to set most/all of 
its registrants' phone numbers to something like +000.0000000 in whois. Does 
that constitute prima facie evidence of fraud on the part of the registrants?

What constitutes "reasonable dispute" over the identity of the name holder or 
admin contact? How is such a dispute to be resolved? Are such methods of 
resolution straightforward, inexpensive and secure? To what timescales should 
the losing registrar adhere in responding to the provision of evidence? What 
remedy has the registrant in the event of a spurious dispute?

Is it acceptable for a registrar to have within its interface a means to set a 
domain to Active status to faciliate a transfer, but have their systems 
configured so that the name automatically reverts to Registrar-Lock within too 
short a time for the transfer request to proceed? Such trickery appears to be 
within the letter, though obviously not the spirit, of the current rules.

Sincerely,
Andrew Moulden

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