2. If your response requires an edit or deletion of Recommendation #3, please indicate the revised wording and rationale here.

The ICA generally supports the recommendation because of the importance of being able to address cybersquatted domain names immediately upon a new registration without having to deal with a change of registrar within the first 30 days. The ICA does however recognize that this is a restriction on the mobility of domain names and mobility is a fundamental principle and purpose of the Transfer Policy and is therefore of importance to the ICA. Moreover, although in principle we want registrants to be able to move registrars if necessary so that they receive better or lower cost services, the lowering of the current 60 day period to a 30 day period by way of a Consensus Policy, is a reasonable compromise and overall improvement in the circumstances. Nevertheless, the ICA would like to see further discussion of whether the 30-day restriction can be shortened while satisfactorily preserve safety mechanisms against illegal activities. The ICA would like to see specific evidence supporting why a 30-day restriction is appropriate, as otherwise the default should be lowered to the minimum feasible which appears to be five (5) days given the Add Grace Period.

2. If your response requires an edit or deletion of Recommendation #9, please indicate the revised wording and rationale here.

The ICA believes that this Recommendation should be deleted. There does not appear to be sufficient or any available evidence that there is such a serious security risk with unexpired TACs, that putting a short fuse of 14 days on them is appropriate or desirable, especially considering the limitations at place in how registrants run their businesses and how aftermarkets function. For example, the “Fast Transfer’ system used in some aftermarkets, relies upon the continuing ability to use a pre-stored TAC without it expiring. The ICA believes that there needs to be a better understanding of the uses of TACs beyond a simple individual transfer in the normal course - and for no established genuine reason. In the alternative, the ICA recommends that there be an opt-out of the short 14-day expiration (or opt into a shorter expiration) so that RNHs with satisfactory knowledge and consent, can continue to use longer TACs.

2. If your response requires an edit or deletion of Recommendation #11, please indicate the revised wording and rationale here.

The ICA is concerned that the notification of the TAC issuance to the RNH can be provided within 10 minutes - but this may very well be after the TAC has been used, thereby preventing effective ability to invalidate the TAC by the registrant. The ICA would like to see additional consideration of whether it is feasible to delay the effectiveness of the TAC for a period of time so as to enable a RNH to take action to invalidate an unauthorized TAC. Alternatively, a registrar should be required to ensure that a RNH has actually confirmed its authorization of the TAC

2. If your response requires an edit or deletion of Recommendation #18, please indicate the revised wording and rationale here.

While the ICA recognizes the general benefits of the 30-day restriction on inter-Registrar transfers, the ICA also recognizes that circumstances may require that the default restriction be lifted, and therefore the ICA supports the Recommendation's inclusion of a removal of the restriction under the circumstances identified in 18.1 - 18.4 of the Recommendation. The ICA would prefer however, to see a remedy for lifting this restriction that is not entirely based upon the discretion of a registrar that may exercise their discretion self-servingly or capriciously.

2. If your response requires an edit or deletion of Recommendation #19, please indicate the revised wording and rationale here.

The ICA approves of the requirement that the Losing Registrar must notify the RNH of a transfer completion, however the ICA is concerned that the up-to 24 hour window does not adequately afford registrants the ability to take meaningful action to prevent a transfer from completing. In order to address this concern, a registrant initiable transfer dispute resolution procedure is recommended.

2. If your response requires an edit or deletion of Recommendation #26, please indicate the revised wording and rationale here.

The ICA is concerned that Recommendation 26.3 removes the requirement to obtain confirmation from both the Prior and New Registrant prior to processing a Change of Registrant Data, however given the notification requirements in Recommendation 27.4, the ICA is satisfied with the Recommendation, provided however that any change of the RNH should also require notice to the prior RNH and new one.

2. If your response requires an edit or deletion of Recommendation #28, please indicate the revised wording and rationale here.

The ICA is generally apprehensive about permitting an RNH the ability to opt out of receiving Change of Registrant Data notifications, however recognizes that the requirements of Recommendation 28.1 - 28.6 provide important requirements that will still enable some boutique registrars to enable their customers to opt out. The ICA remains concerned that a bad actor may be the person surreptitiously opting out, and that in any event, a single email notification for multiple changes could be effective and still lessen the burden on the party that would have liked to avoid receiving bv multiple notifications. There appears to be no safety measures to ensure that the opt out does not immediately precede making the changes without any waiting period let alone a notification, thereby exposing unwitting registrants to unauthorized changes. The ICA therefore recommends that greater security measures be considered, such as requiring 2-F verification, and/or additional telephone or other channel verification.

2. If your response requires an edit or deletion of Recommendation #33, please indicate the revised wording and rationale here.

The ICA strongly supports the overall Recommendation in that it is crucial to provide for a registrant-initiable transfer dispute resolution mechanism. The ICA supports the request for an Issue Report or other suitable mechanism to further research and explore the pros and cons of an expanded TDRP or a new standalone dispute resolution mechanism for registrants who wish to challenge improper transfers, including compromised and stolen domain names, however the ICA also wishes to express its concern over the characterization that such an effort "could be resource intensive and will require the Council to consider the appropriate timing and priority against other policy efforts". While that may be true, in the context of ensuring fairness for registrants who currently have no effective means of dealing with unauthorized transfers, this issue is of paramount importance to registrants and deserves equitable priority to issues that primarily affect other stakeholders.