I haven't been actively participating in this WG, but have been monitoring. I understand that the issue of whether the FOA is still really needed has come up. I do have some thoughts on this. It *might* be true that the FOA is an archaic thing of the past, but we do not have any evidence of it at the moment. There have been a lot of changes with respect to inter-registrar transfers recently, and more to come. But we do not yet fully understand how these are working or will work. At the moment, transfers are still the number one complaint that Contractual Compliance receives after Whois accuracy. For the period of February-June 2014, there were 2427 transfer complaints received, totally over 13% of all registrar-related complaints logged, and almost 10 times the number of the next-highest non-Whois related complaints. Accordingly, it may well be that case that once all of the dust settles, the FOA may be seen as of minimal value. But that time is not now. The WG on Policy and Implementation is actively discussing how issues such as this one could be addressed after a PDP has completed if needed. I would suggest the IRTP-D WG flag this issue as one to be reviewed in a couple of years, and that a recommendation then be issued to consider the removal of the requirement if the evidence supports it at that time. Alan