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

Edit: Strike “evidence of fraud” from I.A.3.7.1 (retain proposed language: violation of the Registrar’s domain use or anti-abuse policies) Rationale: Propose moving evidence of fraud part of the recommendation to a reason that a Registrar of Record must deny a transfer. The language for violating the domain use or anti-abuse policy should remain

If your response requires an edit or deletion of Preliminary Recommendation 20, please indicate the revised wording and rationale here.

Add: I.A.3.8.6 The Registrar of Record has credible evidence of fraud Rationale: Fraud is one example of an abusive activity that registrars must prohibit in their Registration Agreement with Registrants. This language is intended to further empower registrars to deny transfers for abusive behaviour, while also ensuring that the registrar has evidence of the abusive behaviour.

If your response requires an edit or deletion of Preliminary Recommendation 21, please indicate the revised wording and rationale here.

Add: I.A.3.8.7 the Registrar has knowledge of credible evidence of the domain currently being used for malware, phishing, pharming, or command & control botnets. Rationale: This language is intended to further empower registrars to deny transfers for abusive behaviour, while also ensuring that the registrar has evidence of the abusive behaviour.