Dear WG members, As requested during the WG call earlier today, here is the relevant language in the Final Report recommendations which contains express references to the IRTP-C. The first reference appears in the WG¹s recommendation that P/P providers publish as part of their Terms of Service certain information regarding Publication of a customer¹s contact information. Among other things, a provider must also include:

"The specific grounds upon which a customer¹s details may be Disclosed or Published or service suspended or terminated, including Publication in the event of a customer¹s initiation of a transfer of the underlying domain name . In making this recommendation, the WG noted the changes to be introduced to the Inter Registrar Transfer Policy (³IRTP²) in 2016. These changes mean that disabling proxy services would result in the underlying customer becoming the registrant of record , as Section C.1.2 of the IRTP requires a registrar to impose a 60-day inter-registrar transfer lock following a Change of Registrant."

Given the recent discussions on the mailing list and the call today, the WG may wish to consider rewording the above to say, for instance:

"The specific grounds upon which a customer¹s details may be Disclosed or Published or service suspended or terminated, including Publication in the event of a customer¹s initiation of a transfer of the underlying domain name . In making this recommendation, the WG noted the changes to be introduced to the Inter Registrar Transfer Policy (³IRTP²) in 2016 . These changes mean that , where following a Change of Registrant, disabling proxy services would result in the underlying customer becoming the registrant of record , as Section C.1.2 of the IRTP requires a registrar is required to impose a 60-day inter-registrar transfer lock following a Change of Registrant."

(NOTE: The footnote explaining what a Change of Registrant means (i.e. a non-typographical, change to either the registrant name, organization or email address) will be retained. However, specific references as to the extent of discretion in determining, how a Material Change resulting in a Change of Registrant is determined, and a general conclusion equating every disabling of P/P services to a Change of Registrant will be omitted.) The second reference is in the de-accreditation section. If the above suggested edit is acceptable to the WG, there doesn¹t seem to be a reason to change the current language, which reads:

"In addition to the three [de-accreditation] principles outlined above, the WG recommends specifically that, where a Change of Registrant (as defined under the IRTP) takes place during the process of de-accreditation of a proxy service provider, a registrar should lift the mandatory 60-day lock at the express request of the beneficial user, provided the registrar has also been notified of the de-accreditation of the proxy service provider.²

We hope this is helpful. Thanks and cheers Mary Mary Wong Senior Policy Director Internet Corporation for Assigned Names & Numbers (ICANN) Telephone: +1 603 574 4889 Email: mary.wong@icann.org