Thank you for sharing this with the team, Luc,

You write that, "In practice, there are only three main scenarios of redaction and proxy registrations, and only one of them should be subject to this policy."   You then go on to summarize about #2. Proxy Registrations concluding that, "The accreditation system is not needed here."

You write:

      "2. Proxy registration

          "Domains are registered on behalf of others. This may happen for a variety of reasons: the underlying registrant isn’t tech savvy, the registrant licenses the right to use the domain name to one or several licensees, or a lawyer holds a domain name on behalf of their client.

          "In all those cases, the registrar does not know who the underlying registrant is and thus cannot disclose this information, even if presented with an actionable request.

          "The accreditation system is not needed here."

Speaking in my individual capacity, it seems to me that an outcome such as you propose misses the point of PPS Accreditation.  My understanding is that a principal objective of Privacy and Proxy Services Accreditation is to create contractual obligations between Privacy and Proxy Service Providers and ICANN, given that up to now none exist (with the exception of ICANN-contracted parties including Registrars). 

If my understanding is correct, and the speaker from Facebook was truthful when she reported being stymied in their ongoing efforts to disclose registrant data for infringing domain users, then I cannot readily see justification for concluding pf "Proxy registration" that "The accreditation system is not needed here."  To the contrary, my take-away from the excellent session organized by Dennis Chang and his team is that the accreditation system is very much needed to compel data disclosure.  

Of course, I may be off-base and/or incorrect, and hope that in such case you will please educate me further.

Respectfully,

John McCabe