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[registrars] registrar transfers

To Registrars -

Register.com has been closely reviewing the registrar transfer issue and is
ready to update its policy with regard to transfers.

As you know, Register.com makes it a practice to verify its customers'
transfer authorization prior to permitting the transfer of their domain names
to another registrar.  Not only is this practice permissible under the ICANN
agreements, but it has been in place since 1999 in order to protect registrants
against potential unauthorized transfers and hijackings.  Consumer protection ultimately builds the reputation of the
domain name industry, supports ICANN's charge to protect the stability
and security of the domain name system, and furthers the registrar
community's interest in protecting domain name consumers.

Register.com continues to stand behind its consumer protection policy.  At
the same time, register.com has always been committed to working closely with
ICANN-accredited registrars, and other ICANN constituencies, to resolve
registrar transfer issues.  In that spirit, we have listened closely to the views of the constituency,
our customers, ICANN, and other stake holders, and have considered options for
balancing the consumer protection policies with registrar business concerns.
As a result of close review of industry practices, register.com has
determined that it would change its policy to one of default ACK. 
The new practice that register.com intends to implement would be as follows:

a) Register.com will continue to verify with its customers that they
authorized the transfer requests.
b) If a customer verifies a request, register.com will ACK the request.
c) If a customer objects or questions the request, register.com will NACK
the request.
d) If a customer does not respond, register.com will ACK the request if the
requesting registrar has "transfer in" practices that reliably obtain
express authorization from the registrant.
e) If the requesting registrar has unreliable practices of obtaining express
authorization from the registrant, and the customer does not respond,
register.com will NACK the request unless and until register.com receives
assurances that the requesting registrar reforms its "transfer in"
practices.  Register.com reserves the right to check such practices and ensure
that appropriate authorization, as required by the ICANN agreements, has been obtained.

We believe that this new policy would provide register.com and the registrar
constituency with the flexibility and balance that we have all been seeking
in resolving this issue. 
We recommend that the constituency schedule a conference call to discuss this solution.

Elana Broitman
Director, Policy and Public Affairs
575 Eighth Avenue
New York, NY 10018
(212) 798-9100

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