RE: [registrars] current update on whois task force
I notice that the current draft proposes that in addition to checking that an email address is correct after a name has been placed in HOLD status (e.g via sending a confirmation email to the new contact email address) that a registrar should do further checks (such as attempting to contact the registrant using other contact points e.g post or fax or phone etc). This is a further cost on the registrar, and I do not support it (e.g manual labour cost and cost of postage etc). I think email should be the minimal check REQUIRED.
If the email address is working, then a complainant has at least one verified method of communicating with the registrant. The complainant is free to carry out their own checks of postal address etc, or alternatively the complainant could pay the registrars costs in doing further checks. It is not reasonable that a registrar should incur further costs as a result of failure of a registrant to provide correct details. Alternatively a registrant may be charged to update contact details after a name has been placed on HOLD just as they are charged for retrieving a name in the Redemption Grace Period.
So I recommend that this change to the implementation committees suggestion not be accepted. It is what I call scope creep. If it is accepted, then the WHOIS Task Force should be made aware that as a consequence registrars will need to charge either the registrant or the complainant for the additional costs. The WHOIS Task Force should consider whether the burden of costs should lie with the registrant or the complainant in their suggested procedure.
I note the implementation committee also recommended a review process for the new WHOIS recommendations and also recommended a 30 day period for a registrant to respond to a request.