If no, please explain

1. Administrative and Regulatory Contact Information There are several areas of the Guidebook that set out requirements for what Registrars include in their Registration Agreements; these are generally appropriate. The RrSG is concerned with one requirement: "Registry Operator will include a provision in its Registry-Registrar Agreements that requires registrars to include in their Registration Agreements a provision requiring registrants to provide administrative contact information, which must be kept up-to-date, for the notification of complaints or reports of registration abuse, as well as the contact details of the relevant regulatory, or industry self-regulatory, bodies in their main place of business." The registrar will have the Registered Name Holder’s contact information, so a further administrative point of contact for notification of complaints or reports of abuse would be redundant and contrary to ICANN Policy. In addition, contact details of a “regulatory, or industry self-regulatory body” is overly burdensome for registrants that are not businesses as well as those that are businesses. It is not clear from this provision what such a body would even be nor how a registry or registrar would verify that it is correct. In the event that the registrant is an attorney, perhaps they would provide their local bar information; is this reasonable for a registrant’s personal domain? Is it intended to only be for the domain name used by the attorney for business purposes? If so, for what purpose will the registrar, registry, or ICANN use this information? What happens if the contact information for the regulatory body changes? Will the domain be cancelled if the registrant does not maintain this information? It is not clear what problem the clause is trying to solve but it is clear that it provides no solution. 2. Code of Conduct Exemptions The RrSG is concerned about expansion of Code of Conduct Exemptions and the effects of these exemptions on non-discriminatory access to the TLD; we support the guardrails already included (evaluation criteria; requirement of non-generic usage; public comment period for input) and would support consideration of further obligations to prevent a wide range of strings—even those with public interest implications—from being operated in a closed or exclusive manner. Although there are circumstances where it is appropriate that the TLD be used exclusively by the Registry Operator or its Affiliates, these circumstances should remain limited and be thoroughly considered before the exception is granted. In terms of a registry making a good faith effort to find registrars, one option may be for them to work with the RrSG before moving on to the Exemption request. 3. (There was no appropriate box for this comment): We note that the Glossary definition of “registrar” includes a reference to WHOIS; this should be replaced with RDDS.