- Comments-transfer-policy-pdp-review-12oct20

RrSG Response to the Preliminary Issue Report on a Policy Development Process to Review the Transfer Policy
by secretariat＠icannregistrars.org Nov. 30, 2020

Nov. 30, 2020

Hello, On behalf of the Registrar Stakeholder Group (RrSG), I would like to submit the attached response the Preliminary Issue Report on a Policy Development Process to Review the Transfer Policy. Kind regards, Zoe Bonython RrSG Secretariat

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Tucows comment on Transfer Policy PDP Review
by Sarah Wyld Nov. 30, 2020

Nov. 30, 2020

The Tucows family of registrars thanks the ICANN staff team for preparing this Preliminary Issue Report. We support the topics already included in the Charter, and suggest that bulk transfers between registrars should be added to the list of topics which this Working Group is chartered to address. Policy which supports transferring domains in bulk at this time is limited to the BTAPPA process, which does not apply in most scenarios; as such, registrars and registrants would benefit from a more universal policy not tied to an acquisition. We note that Question A1 in the “Gaining Registrar FOA and Losing Registrar FOA” section is confusingly worded, as the second part of the question is based on a yes/no response to the first part, which is not itself a yes/no question. Also, in the “A. Expected Skills for Working Group Members” section, the third bullet and the second-to-last bullet are almost identical, and could be combined for clarity. Finally, in the interests of moving towards more effective and efficient PDPs, we are open to using the “member/alternate/observer” model for this Transfer Policy Working Group. We suggest that the membership model should be included as part of the eventual PDP review process, to ensure that we evaluate the outcome of that decision. Thank you, Sarah Wyld -- Sarah Wyld, CIPP/E Policy & Privacy Manager Tucows swyld(a)tucows.com +1.416 535 0123 Ext. 1392

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Comments from Openprovider on review of transfer policy
by Siemen Roorda Nov. 30, 2020

Nov. 30, 2020

Dear ICANN, In the attached file, you find Openprovider’s comments to the “Preliminary Issue Report on a Policy Development Process to Review the Transfer Policy.” We decided not to provide input on all questions of section 3.5 of the report. In most cases, the reason is that we either don’t have the expertise to write a useful comment, or that we are fine with the current transfer policy on that topic. Apart from answers to questions of section 3.5 of the report, we have added some generic comments and input on the current transfer policy that is not covered in the report. In case of any further questions, feel free to contact me at registry-liaison(a)openprovider.nl. Kind regards, Siemen Roorda Hosting Concepts B.V. d/b/a Openprovider IANA ID 1647

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