Hi Caitlin and Team: First, I should apologize for missing the last 2 calls. I have had frequent schedule conflicts with this group, including an "off the grid" vacation last week. So please accept my apologies if these edits/comments appear to be "last minute". Next, I have noted a few changes to this draft (attached). Here are the highlights: * I think we should call Section II. "Inter-Registrant Transfer (Change of Registrant)" to keep it consistent with Section I. "Inter-Registrar Transfer". * Also, I think we should allow for non-material changes to Registrant information to include "equivalent" data, such as changing "Inc." to "Incorporated" or "Mike" to "Michael." I welcome ideas form the group on how to define this (or set some boundaries). * I'm still unclear whehter or not the Registrar has the right to refuse a Change of Registrant. What if there is some reason that the Registrar cannot legally serve or enter in to an agreement with the new Registrant? For example, in the US we cannot serve Registrants in Cuba or North Korea. Similarly, the US and several other nations have levied sanctions against individuals and organizations in Crimea. I would hate to see this policy used as a backdoor to compel Registrars to violate local law. Finally, there is the case where a Registrar has simply banned a particular Registrant from using their services. This right to refuse service should be maintained in the new policy. * Speaking of the Registration Agreement, I do not see where in the Draft Process (Sec. II(3)) where the Registrar presents this agreement to the new Registrant, and obtain their explicit acceptance. This is required buy the RAA (Sec. 3.7.7). Thanks- J. From: Caitlin Tubergen <caitlin.tubergen@icann.org<mailto:caitlin.tubergen@icann.org>> Date: Wednesday, March 11, 2015 at 13:40 To: "gnso-impl-irtpc-rt@icann.org<mailto:gnso-impl-irtpc-rt@icann.org>" <gnso-impl-irtpc-rt@icann.org<mailto:gnso-impl-irtpc-rt@icann.org>> Subject: [gnso-impl-irtpc-rt] Reminder: Comments on Change of Registrant/Transfer Policy - due Thursday 12 March Hi All, Please note that the deadline for the Implementation Review Team to provide comments on the attached draft COR policy is tomorrow, Thursday, 12 March. If you are unable to provide feedback by that time, you are welcome to submit any comments during the public comment period. Thank you. Kind regards, Caitlin From: owner-gnso-impl-irtpc-rt@icann.org<mailto:owner-gnso-impl-irtpc-rt@icann.org> [mailto:owner-gnso-impl-irtpc-rt@icann.org] On Behalf Of Caitlin Tubergen Sent: Thursday, March 05, 2015 10:19 PM To: gnso-impl-irtpc-rt@icann.org<mailto:gnso-impl-irtpc-rt@icann.org>; Theo Geurts Subject: [gnso-impl-irtpc-rt] For your review: Change of Registrant/Transfer Policy - by Thursday 12 March Hi All, Thank you to everyone who participated in the call today. For those of you who were unable to attend, please find a link to the recording here: https://icann.adobeconnect.com/p4howkg3hce/ During the call, we discussed the outstanding issue from our last call, which was the issue of third party privacy/proxy providers and the potential challenge of transmitting the change of registrant credential to the underlying registrant. The members of the IRT that were on the call with okay with the proposed solution, which you will find in footnote 1. The P/P issue was the last outstanding issue to discuss before we post the draft policy for public comment. I have attached the draft policy for your final review. You will note that this is the hybrid "Transfer Policy," which will go out for public comment. The Transfer Policy has two sections: the IRTP in section I, and the Change of Registrant in section II. The hybrid policy was recommended by the WG. As you may remember, we had already worked through recommendation 2, the time limiting of FOAs, before we began discussing the Change of Registrant function. If you have any final questions or comments on the draft policy, please submit them to me by Thursday, 12 March. Thank you! Kind regards, Caitlin