I agree with this, the trigger should not be left to the discretion of each Registrar which already has some discretion on acting on reported names.
If the trigger is some form of recognized abuse which has been mitigated (i.e. action has been taken) (as in terms of the current RAA) I would think the Registrar would, if only for practical purposes, apply the same (criteria for taking) action against names found to meet the same criteria as the reported ones.
While I am a not lawyer (only a (retired) Gynecologist, but what's the difference, as the quote goes :-)-O?) I am not a great fan of acting against names without actual evidence of malfeasance. Guilt by Association...
It would probably fall under the Human Rights concern here in this group, which is a big word, but I think of it more in terms of Natural Justice as they say here in Namibia (Duty to Act Fairly). We will probably bake in some reasonable opportunity to raise objection anyway, so that the Audi Alteram Partem (hear the other side) part of NJ is observed.
el