Name: George Kirikos
Date: 15 Aug 2022
Affiliation: Leap of Faith Financial Services Inc.
Original Public Comment: Initial Report on the Transfer Policy Review - Phase 1(a)
Are you providing input on behalf of another group (e.g., organization, company, government)?
If yes, please explain.
Leap of Faith Financial Services Inc.
Are there any recommendations the Working Group has not considered? If yes, please provide details below.
Are there any other comments or issues you would like to raise pertaining to the Initial Report? If yes, please enter your comments here. If applicable, please specify the section or page number in the Initial Report to which your comments refer.
Summary of Attachment
The "LEAP-comments-Transfers-Phase1a-20220814-FINAL.pdf" is our main comment submission.
The "LEAP-extensionrequest-Transfers-Phase1a-20220731.pdf" file is our earlier request for the deadline to be extended to mid-September. This was not granted (although, perhaps it will be, who knows!). We retain it to have a full historical record.
Summary of Submission
There is a lot wrong with this working group's report, too long to summarize briefly. Read the entire 60 pages to see our full analysis.
We wish to emphasize, though, that the TAC is very dangerous. It should be eliminated, by adopting our counterproposal in Section E (generate a transaction ID at the gaining registrar, to input at the losing registrar). This would be a huge improvement.
Also, the Losing FOA needs to be maintained, at least on an opt-in basis, as per our "Best of Both Worlds" proposal in section F.
Consideration should be given to inviting knowledgeable members of the ICANN community like ourselves to participate directly in the working group on behalf of domain registrants, to reduce the unbalanced participation that currently exists in the working group.
SSAC should also do a thorough review, in light of our own comments that highlighted the inconsistencies between their past advisories and the working group's recommendations. An XPRIZE-style competition would also be a way to bring in fresh ideas, and new solutions.