In our view, the proposal has two substantial flaws. First, it is overly specific as to the process *all* contracted registrars must use to determine whether the registrant is a legal vs a natural person. Second, it includes procedures for verifying the accuracy of the data for legal persons. The procedure is unnecessary for determining whether the registrant is a legal person. If the eventual policy requires a high degree of accuracy of a legal person's name and address, that's a separate matter and should be dealt with in that part of the policy.
The attached memo suggests a simpler and more comprehensive approach.
Thanks,
Steve