Hello team,
I’ve reviewed our draft updated recommendations and the strawman for Rec 2. Left some minor changes in the redline doc.
I want to provide more context specifically around the suggestion for an alternative to the Losing FOA, we can call it the “TAC ACK” process. Prior to our public comment review, the WG seemed aligned on the decision to drop the Losing FOA; we must certainly address all the concerns raised in the public comments, and I think we can do that while also maintaining our goal of streamlining the transfer process by further exploring the TAC ACK option.
What the process would look like:
- RNH unlocks domain and requests TAC from the Registrar of Record (Losing Rr)
- Losing Rr sends a TAC ACK email to the RNH saying “Someone requested a TAC; if this wasn’t you, click <NACKlink>. If it was you, you can either do nothing and we’ll provide you the TAC in 5 days or you can click <ACKlink> and we’ll give you the TAC right now”
- If RNH clicks <NACKlink>, the TAC is never set at the Ry, and other things might happen (e.g. account password reset, etc)
- If RNH clicks <ACKlink>, the Losing Rr provisions the TAC at the Ry and issues it to the RNH (Rec 3 Notification of TAC Issuance)
- If no response, Losing Rr waits 5 days and then provisions the TAC at the Ry and issues it to the RNH (Rec 3 Notification of TAC Issuance)
- When the RNH receives the TAC, they provide it to the gaining Rr and the transfer is completed (Rec 4 “Notification of Transfer Completion” etc)
Why this is beneficial:
- Registrant agency: the Registrant has the option to cancel the transfer right away, following the same process as with the current Losing FOA (which has the option to NACK, and which auto-ACKs after a 5 day pending period)
- Just-in-time notifications: The TAC ACK process occurs right when the RNH is preparing for the transfer, rather than at some point later on after they’ve initiated it with the gaining Rr and moved on/stopped thinking about it
- Simplicity: Registrants consistently request fewer emails overall and fewer steps specifically in the transfer process, and have requested an ‘instant transfer’ process for years
Risks & mitigations:
- Risk: There would be no notification/’stop the transfer’ moment after the transfer is initiated with the gaining registrar; Mitigation: (a) there is a notification/stop moment at the time of TAC request, and (b) the fast-undo process we are committed to creating in the next phase of this WG would specifically address these issues and could certainly include reverting DNS if it was changed
- Risk: Level of development effort does not balance benefit; Mitigation: The level of effort will differ for different providers, and we shouldn‘t reject ideas just because they take work, especially since we’re already making changes to the transfer process as a whole. Now is exactly the time to do this!
The working group hasn’t reached consensus on eliminating the Losing FOA, but we also haven’t reached consensus on keeping it. I still believe that this “TAC ACK” proposal would address the entirely valid concerns about security and registrant agency, while also providing noticeable improvement for registrants who have repeatedly and for quite some time requested a faster transfer process. I hope we can discuss this proposal alongside the Losing FOA strawman.
Thank you,
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Sarah Wyld, CIPP/E
Policy & Privacy Manager
Pronouns: she/they
swyld@tucows.com
Dear working group members,
As discussed on yesterday’s call, staff had an action item to provide a redline revision of the Initial Report reflecting agreed updates to Recommendations 3-9 (see pages 18-24), as well as a strawman draft of the new Recommendation 2 and response to Charter Question A7. The redline is attached. The Recommendation 2 strawman is available here.
Please carefully review these documents in coordination with the groups you represent. If you feel that there are items that need to be revised, please enter them here. For each item, please include:
- Report version (the date listed in the header of the document) and applicable line numbers ( these are listed along the left margin of the document).
- Name and group you represent: If multiple WG members represent a group, input should be in coordination with these other members.
- Rationale: please provide a clear explanation for why you are proposing the revision.
- Specific proposed revision: Provide the language you would like to see added/removed/edited.
The deadline for submitting input is 30 November 2022. After the deadline, the working group will discuss the items submitted in the input document. Following review of those items, the text will be considered stable.
Please do not hesitate to reach out with any questions about the review process.
Kind regards,
Caitlin, Julie, Berry, and Emily
Emily Barabas
Policy Development Support Senior Manager
Internet Corporation for Assigned Names and Numbers (ICANN)
Phone: +31 (0)6 84507976
www.icann.org