Hi team, I know this is a topic we’ve already discussed but it came up again for us at Tucows recently and I want to share some more thoughts for the group’s consideration before we come back to it in a meeting I think we should keep ‘violation of the registration agreement’ in the reasons why the losing registrar MAY deny a transfer. If we want the DNS space to have the trust and respectability of the Internet community, we must take a ‘responsible registrar’ approach to certain types of domain. Issues outlined in the DNS Abuse Framework <https://dnsabuseframework.org/>, for example, may extend beyond standard DNS Abuse in some cases, but absolutely causes terrible harm to the world that disallowing domain transfer is appropriate. For example, a domain suspended for promoting terrorism, shouldn’t simply be allowed to be transferred to a less-aware registrar and continue promoting terrorism. The extremely minor speed bump of having to find a new domain and a new registrar is the literal least we can do. I’m concerned that by removing this option from registrars we lose an important measure to prevent abuse and other online harms. When we discussed this topic in a recent meeting, I had thought that the registrar would address the harm by revoking ownership of the domain name (e.g. by updating the RNH contact info to their own), but upon further discussion both internally and with some other Rr’s I have come to understand that is not common practice nor should it be the expected path. As such, there needs to be some method for the Rr to deny the transfer in this type of situation while the original RNH remains listed on the registration record. I know there’s a concern that some registrars might have unreasonable terms, but don't we generally expect that the Rr will set reasonable terms and the RNH will understand those terms prior to accepting them? If we start assuming that the RNH did not understand the terms they accepted, that seems like a dangerous path to go down. Going back to the terrorism example, a registrar that hasn’t signed on to the DNS Abuse Framework isn’t required to suspend a domain for terrorism (unless told to by appropriate LEA, but that’s a different case). But one that has shouldn’t be forced to allow terrorists to continue at another Registrar, they should be able to follow their published policy of suspending the service and denying transfer away. I understand this isn’t simple and there are valid concerns about Registrars setting impossible or inappropriate Terms in order to retain customers by preventing transfer out. I hope that as a team we can find some way to balance all these issues and include violation of the registration agreement in our updated reasons why the Registrar MAY deny the transfer. Thank you, *Rich Brown* Compliance Officer Tucows, Inc