Hi Jonathan I’ve had a quick look at the IRTP issue, and am not convinced we should comment for a couple of reasons: this issues involved really concern registrants. That said, this can involve many small businesses and we should support the aims of IRTP including both ensuring the processes are in place to allow a relatively easy way for registrants to change registrars, while following processes designed to minimize fraud two issues in the IRTP space are still to be resolve. The first one discussed in the paper is a revised process of transfer accommodating the EPDP and impacts of GDPR - ( data that had previously been accessible by registrars now must be entered by the registrant) and the extend to which RDAP, as adopted, will facilitate access to the data concluding - this is not a huge issue for end users, and there are still some unknowns both from the EPDP and RADP Happy to discuss on the CPWG call Holly