[registrars] Transfers etc...

["Paul M. Kane" <Paul.Kane@REACTO.com>]

Unfortunately I will only be able to be in the call for the first 20 mins
but may I make a few suggestions.....

The Registrars Constituency should write a letter to ICANN:

• asking Verisign to substantiate it's allegations and provide the raw data for evaluation.
• defering any action on this issue until it is better understood
• indicate the requirement for "notarized" communications places a significant barrier to trade in the wholesale market, many registrants are ISP/IPP and as such it may inhibit competition.
• Perhaps there should be a duty placed upon the gaining to furnish the losing registrar with an agreed letter of transfer within a specified time period.  I would suggest the Registrars Constituency should formulate and agree upon a standard transfer letter, than can be available in multiple languages (to avoid the language barriers to transfer) 
• if the failure of the losing registrar to produce the appropriate documentation within "x" days should result in the gaining registrar returning to the loosing registrar the domain name originally transferred.  In addition as the loosing registrar, acting in good faith will have incurred costs, firstly releasing the domain then recapturing it, perhaps the inappropriately gaining registrar should pay a fee to the loosing registrar in compensation.

We need to try and sort this procedure out "in-house" and once agreed within
the Registrars Constituency perhaps it may be appropriate to present the
procedure to the DNSO for review, then to ICANN for formal adoption. 
It is important we can self regulate our industry rather than have something
mandated upon us... as we want to avoid a situation of multiple bi-lateral
agreements between competing registrars.

Good luck on the call

Best

Paul