[nc-imp] Implementation Issues
We believe the final 29 recommendations made by the TF represent very little change in the current process, with the exception of the Standard Form of Authorization. This will be largest issue for those tasked with its implementation as well as for the registrars.
There are two other recommendations where we felt comment was warranted. All other recommendations we believe can be implemented with no, or very little impact on our current operations.
5. The Registrant must be informed of and have access to, the published documentation of the specific transfer process of their current Registrar. The Task Force notes that it would also be useful for Registrants to have access to the transfer process documentation of Registrars that the Registrant is considering switching to.
The last sentence is not clear. Is the intent that links to the transfer documentation of all registrars would in some way be available? If so, this would best be done through a central location at the registries, or perhaps ICANN, since both have contractual relationships and could enforce compliance.
25. Instances when the Losing Registrar may not deny a transfer include, but are not limited to;
d. Domain name registration period time constraints other than during the first 60 days of initial registration.
This conflicts with security measures that have been working for us. For example, we try to offer a simple, yet secure, mechanism for registrants to transfer ownership of their domain names. As a part of that security, the new registrant must agree not to transfer the domain away for 60 days. In addition, registrants transferring domains to us must also agree that they will not transfer the domain again for 60 days, another security measure.
These are reasonable steps that have little impact on portability, yet add much security for the registrant, and lessens the likelihood of dispute resolution procedures. We believe allowing these two "optional" time constraints will improve security and lessen the likelihood of dispute resolution.
Go Daddy Software, Inc.