Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.
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The Registrar Stakeholder Group (RrSG) thanks the Transfer Policy Review Working Group members, leadership, and ICANN Staff for their many hours of dedicated work on this important project, and appreciates the opportunity to provide a comment on this Final Report, which is attached in full.
The security and availability of domain transfers is a crucial aspect of the Domain Name System. This Working Group has issued Recommendations to support these goals, improving security while ensuring that domains can be moved among registrars and standardizing communications to ensure the right information is provided at the right time in the process. The RrSG appreciates the level of attention to the transfer process and registrant experience that the Working Group has demonstrated.
However, we note the importance of a sufficient implementation buffer window for changes of this significance, to ensure appropriate communication to registrants and development time for implementers. The RrSG is also still concerned with the previously raised issue with recommendation #26.