Thanks Alan, taking into account your note, here is another suggested update.... maybe we can get this sorted by day's end (hope springs eternal). [Note: the removal of "Compliance"  is to allow ICANN to figure out from whom they would like such an advisory to emanate from.] 


Suggested update: 


The effective date of the gTLD Registration Data Policy shall be [February 29, 2020]. All gTLD Registry Operators and ICANN-accredited registrars will be required to comply with the gTLD Registration Data Policy as of that date.

Until such date [February 29, 2020], ICANN [Compliance] directs Contracted Parties that registries and registrars are required EITHER to comply with the [policy resulting from] the recommendations contained in the Final Report OR continue to implement measures consistent with the Temporary Specification (as adopted by the ICANN Board on 17 May 2018, and expired on 25 May 2019). Registries and registrars who continue to implement measures compliant with the expired Temporary Specification will not be subject to Compliance penalty specifically related to those measures until February 29, 2020.

Failure to respond within 30 days of this notice shall be considered acceptance of the terms herein will be considered acceptance.




Kind regards,


Alan 




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On Wed, Mar 13, 2019 at 11:21 AM Alan Greenberg <alan.greenberg@mcgill.ca> wrote:
I think that the intent of this is exactly right, and keeping it lightweight is important.

The problematic part of the wording is that it implies that contracted parties can interpret the Recs on their own prior to ICANN publishing the new Consensus Policy (CP) (presumably 6 months prior to 29 Feb 2020). For the period from xx May 2019 until the CP is published, the Temp Spec is the rule (properly phrased). After the CP is published, the new CP may apply and must apply no later than 29 Feb.

Alan

At 12/03/2019 12:42 AM, Elizabeth Bacon wrote:

Hello Team,
In Sunday?s session, ICANN noted that they feel they need a temporary policy to bridge between the expiration of the Temporary Specification and the completion of the EPDP Consensus Policy.  There was some consensus in the room that the Team had anticipated this and provided that mechanism via Recommendation 28.  In addition, the idea of what a ?temporary policy? might be raised several questions and concerns.   In an effort to not recreate the wheel or implement an overly heavy solution, we proposed to Dennis that a formal notice/advisory from ICANN Compliance to Contracted Parties to operationalize the language we previously agreed for Recommendation 28 would be sufficient and appropriate. 
 
The language is below for your review. I look forward to your thoughts before I share with Dennis.
Thanks,
Beth
 
 
The effective date of the gTLD Registration Data Policy shall be [February 29, 2020]. All gTLD Registry Operators and ICANN-accredited registrars will be required to comply with the gTLD Registration Data Policy as of that date.

Until such date [February 29, 2020], ICANN Compliance directs Contracted Parties that registries and registrars are required EITHER to comply with the recommendations contained in the Final Report OR continue to implement measures consistent with the Temporary Specification (as adopted by the ICANN Board on 17 May 2018, and expired on 25 May 2019). Registries and registrars who continue to implement measures compliant with the expired Temporary Specification will not be subject to Compliance penalty specifically related to those measures until February 29, 2020.
Failure to respond within 30 days of this notice shall be considered acceptance of the terms herein will be considered acceptance.
 
Elizabeth Bacon
Senior Director, Policy and Privacy                                                                                   
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