Dear PPSAI WG Members:

Here is the issue you asked staff to address by email today.  This came to our attention after reflecting on the work done Friday by the “implementation issues” sub-team.

In short, disabling a proxy or privacy service will trigger the 60-day inter-registrar transfer lock required by IRTP C (which takes effect on 1 August 2016, https://www.icann.org/resources/pages/transfer-policy-2015-09-24-en ). Although applicable generally, this issue is of particular concern following de-accreditation of a privacy or proxy service (if transfer to another registrar is required to maintain privacy).

Here are 3 things the WG could consider doing to address this:

1. Maintain the status quo and leave the 60-day IRTP C lock in place.
2. Create an exception for Privacy and Proxy Service customers, so the 60 day IRTP C (inter-registrar transfer) lock doesn't apply when/if the customer changes or removes the PP service.
3. Create an exception for PP users only if a PP service is de-accredited, so the IRTP C (inter-registrar transfer) lock can be lifted by the beneficial user if the registrar has been notified of de-accreditation.

Please let us know if you’d like to us to provide any further background. 

Thank you!

Amy E. Bivins

Registrar Policy Services Manager

Internet Corporation for Assigned Names and Numbers (ICANN)

amy.bivins@icann.org

One World. One Internet.

Direct: +1 (202) 249-7551

Fax:  +1 (202) 789-0104

801 17^th Street NW, Suite 400

Washington, DC 20006