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Continued Operations Instrument (COI) Amendment Service Frequently Asked Questions (FAQ)

Please note that the English language version of all translated content and documents are the official versions and that translations in other languages are for informational purposes only.

Q1: What is the Continued Operations Instrument (COI) Amendment Service?

A1: The Continued Operations Instrument (COI) Amendment Service provides a method for registry operators to request an amendment from the ICANN organization to change the funding levels of their COI values up or down to better align with domain registrations under management (DUMs) of a generic top-level domain (gTLD). The COI funds are an important part of safeguarding the operation of gTLDs by ensuring there are sufficient financial resources to protect the continuity of critical registry functions. If the ICANN organization finds that a COI is insufficiently funded at any time after a gTLD has been delegated, the registry operator will be referred to the COI Amendment Service and have 60 days to amend their COI funding level. To request a COI amendment, submit a new case via the Naming Services portal by selecting the correct form of COI (for Letter of Credit or Escrow Agreement).

Q2: Why would registry operators amend their COI?

A2: There are two reasons why a registry operator may want to amend their COI:

  1. Registry operators can request a change to the value of their COI to align with the updated DUMs projections of a gTLD.  In December 2011, the ICANN organization published guidance to help registry operator calculate the estimated costs of gTLD operations based on projected DUMs. Since that time, the launch of new gTLDs has provided market-driven data points on which to base their projections. With the COI Amendment Service.
  2. When Domains under Management (DUMs) surpass COI coverage within six (6) months of a previous amendment, the registry operator will be required to increase their COI to ensure it is not underfunded.

Q3: What are the requirements to submit a COI Amendment request?

A3: The registry operator may request a COI Amendment if it is overfunded or insufficiently funded. This can be done any time after the registry has been in General Availability/Registration (GA) for six months as defined by the Claims Start Date.

The requirements are:

  1. Registry operators must wait at least six months from the date a COI was previously amended before amending the same COI an additional time.
  2. The COI may be in the form of a Letter of Credit (LOC) or escrow agreement issued by the registry operator's bank.
  3. Updated projections
    1. Based on the increase or decrease in the number of DUMs outlined in the request, not current DUMs.
    2. The Standard Emergency Event Fee Table attached to the Emergency Back-End Registry Operator (EBERO) Agreement [PDF, 1 MB] (Attachment D1) will be the guideline for calculating the appropriate value of a COI based on DUMs projections.
    3. In situations where one COI covers multiple gTLDs, the total funds required will be determined by analyzing the DUMs against each respective gTLD listed on the COI's allocation schedule.
    4. Requests for amendments will be evaluated against the most current submitted Monthly Transaction Report.
  4. The registry operator is responsible for all banking fees associated with the amendment, including, Advising Fees charged by Bank of America. This fee will be approximately $200 and no more than $250 per amendment.
  5. All requests must be submitted via the Naming Services portal and a new case should be created according to the correct form of COI (Letter of Credit or Escrow Agreement).

Q4: Does the ICANN organization have an advising bank?

A4: Yes, Bank of America was selected as the ICANN organization's advising bank through an extensive Request for Proposal (RFP) process. The institution is well-respected and has the expertise needed to ensure that these COIs meet all relevant financial regulations and requirements. They also maintain correspondence relationships with over 2,500 financial institutions globally. In addition, Bank of America has the infrastructure required to communicate securely with these banks and provide safekeeping services for all original documents. As Bank of America is ICANN's advising bank, all LOCs must be advised through Bank of America. Should Bank of America identify outstanding terms per their customary banking guidelines, registry operators must amend such terms as part of the COI Amendment Service process.

Q5: Why did the ICANN organization decide to outsource this function?

A5: Outsourcing this administrative function to an experienced financial institution allows the ICANN organization to manage this process more effectively and focus on its core areas of expertise. Working with one designated advising bank will also allow the ICANN organization to ensure that all LOCs are executed in a consistent manner, properly authenticated and comply with standard global regulations.

Q6: What is the process?

A6: To initiate the process, the registry primary contact must complete and submit a new COI Amendment case, either for Letter of Credit (LOC) or Escrow Agreement, through the Naming Services portal.

Once submitted, the ICANN organization will perform a completeness check of the request to confirm it meets the requirements and is approved to move forward. If the COI is in the form of a LOC, the ICANN organization will direct Bank of America, ICANN's advising bank, to review the LOC and detail any changes to the language that may be required. The registry operator may then provide those instructions to their issuing bank to execute the amendment. If the COI is in the form of an escrow agreement, the ICANN organization will request the registry operator to work with the escrow institution to amend the escrow agreement. For a complete list of the steps, please read the How to Submit a COI Amendment Request [PDF, 152 KB].

Q7: How long does the process take?

A7: After a COI amendment has been requested, the ICANN organization's service level target is to provide the registry operator with a response in eight (8) business days informing the registry operator if the request has been approved or denied. Once the ICANN organization has approved the request, completion timing will vary depending on the registry operator and the bank, but could be finished in as quickly as twenty-one (21) business days.

If the amendment request is due to a request from the ICANN organization, the process for the COI Amendment Service should be completed within sixty (60) calendar days.

Q8: Is the process the same in all regions?

A8: Yes, however, there may be delays in the timeline for some regions/countries due to differences in bank approval processes.

Q9: Is there any cost associated with the COI Amendment Service?

A9: Yes, there may be nominal banking fees associated with the service including, but not limited to, advising fees and amendment fees.

Q10: Where can I go if I have additional questions?

A10: Please visit the Continued Operations Instrument (COI) page on Additionally, questions can be sent to ICANN Global Support:

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