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Public Comment: Initial Report on the Inter-Registrar Transfer Policy (Part A)

9 January 2009

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A public comment period opens today for 21 days on an Initial Report into the Inter-Registrar Transfer Policy (IRTP).

The IRTP Part A Policy Development Process is the first in a series of five planned PDPs to address areas for improvements in the existing Inter-Registrar Transfer Policy. The IRTP Part A PDP concerns three 'new' issues: (1) the potential need for exchange of registrant email information between registrars, (2) the potential need for including new forms of electronic authentication to verify transfer requests and avoid 'spoofing', and (3) to consider whether the IRTP should include provisions for 'partial bulk transfers' between registrars.

A Working Group, launched by the GNSO Council for this PDP, started its deliberations on 5 August 2008 and has now published an Initial Report.

PLEASE NOTE: The Working Group will not make a final decision on which solution(s), if any, to propose to the GNSO Council before a thorough review of the comments received during the public comment period and in the final constituency statements has taken place.

Following its deliberations, the Working Group has made some preliminary conclusions for each issue, which it hopes will inspire further comments from the public as well as the constituencies. These preliminary conclusions are as follows:

Issue I - Is there a way for registrars to make Registrant E-mail Address data available to one another?
The WG noted that WHOIS was not designed to support many of the ways in which it is currently used to facilitate transfers. Some members suggested that finding a way to make the Registrant e-mail address more readily available could be addressed as part of an overall technical modernization of the WHOIS protocol.  This could be through updates to the existing protocol, modification of the Extensible Provisioning Protocol (EPP) or adoption of the Internet Registry Information Service (IRIS) protocol. However, after review and discussion none of these options received broad agreement.

The WG did note that, in the absence of a simple and secure solution for providing the gaining registrar access to the registrant email address, future IRTP working groups should consider the appropriateness of a policy change that would prevent a registrant from reversing a transfer after it has been completed and authorized by the admin contact. This option would not change the current situation whereby a losing registrar can choose to notify the registrant and provide an opportunity to cancel a transfer before the process is completed.

Issue II - Whether there is need for other options for electronic authentication?
Based on the discussion in the Working Group, there appears to be broad agreement that there is a need for other options for electronic authentication. However, opinions in the Working Group differ as to whether these options should be developed by means of GNSO policymaking or should be left to market solutions.

Issue III - Whether the policy should incorporate provisions for handling partial bulk transfers between registrars?
Based on the discussion in the Working Group, there appears to be broad agreement that there is no need to incorporate provisions for handling partial bulk transfers between registrars at this stage. The Working Group believes that these scenarios can be addressed either through the existing Bulk Transfer provisions, or through existing market solutions.

As stated in the ICANN Bylaws, the Initial Report is posted for public comment for 20 days. The comments received will be analyzed and used for redrafting of the Initial Report into a Final Report to be considered by the GNSO Council for further action.

The Working Group would like to encourage everyone to review the complete Initial Report [PDF, 383K] before submitting comments.

Comments on the Initial Report should be sent to irtp-initial-report@icann.org.

Public comments received can be accessed at http://forum.icann.org/lists/irtp-initial-report/.

The deadline for submission of comments is 30 January 2009.

Related links:

Part A Initial Report:
http://gnso.icann.org/issues/transfers/irtp-a-initial-report-08jan09.pdf [PDF, 383K]

Existing Transfer Policy:
http://www.icann.org/en/transfers/policy-12jul04.htm