Thanks for circulating this, Amy, it helps to spell out the concern you and Mike raised on this morning's call. Could you clarify whether the 60-day lock provision is part of the IRTP as a consensus policy, or part of the implementation of that policy? Just to be clear, my understanding is that this WG can't do any of the things you list, since we have no remit to change IRTP-C or its implementation. We could include a recommendation that a change like #2 or #3 be considered in order to facilitate implementation of our p/p service accreditation recommendations. But I imagine it would make a big difference whether we are asking to change a consensus policy or the adopted implementation of that policy. Looking forward to your clarification on this. Steve Metalitz From: gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, November 17, 2015 1:01 PM To: gnso-ppsai-pdp-wg@icann.org Subject: [Gnso-ppsai-pdp-wg] PP transfer issue 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<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<mailto:amy.bivins@icann.org> [Description: icann-logo] One World. One Internet. Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 801 17th Street NW, Suite 400 Washington, DC 20006
