Note that the following question that I am recommending the EPDP pose to ICANN Org has a direct implication on whether we issue Recommendation CM.2. Alan To: EPDP <gnso-epdp-team@icann.org> From: Alan Greenberg <alan.greenberg@mcgill.ca> Subject: Question for ICANN Org regarding Registrant Contact Information As requested, here is the draft question to the ICANN org regarding the implications of deleting the RDS Administrative fields. Alan =============== The EPDP is contemplating deleting the RDS elements associated with the Administrative and Billing Contact name and contact information (the Billing fields are not currently published and so there will be no impact). If this were to be done, the Registrant contact information would be the only remaining contact fields for the entity responsible for the registration. Under the 2009 RAA, Registrant email and telephone contacts were optional and so may not have been collected. 21013 RAA, under Data Retention Specification 1.1 says: 1.1. Registrar shall collect the following information from registrants at the time of registration of a domain name (a ?Registration?) and shall maintain that information for the duration of Registrar?s sponsorship of the Registration and for a period of two additional years thereafter: 1.1.1. First and last name or full legal name of registrant; 1.1.2. First and last name or, in the event registrant is a legal person, the title of the registrant?s administrative contact, technical contact, and billing contact; 1.1.3. Postal address of registrant, administrative contact, technical contact, and billing contact; 1.1.4. Email address of registrant, administrative contact, technical contact, and billing contact; 1.1.5. Telephone contact for registrant, administrative contact, technical contact, and billing contact; ..... Since the 2013 RAA was first available in mid-2013, and RAAs must be renewed every five year, as of mid-2018, there should be no registrars operating under the 2009 RAA. The EPDP is requesting that ICANN Org confirm that all registrars are now operating under the 2013 RAA. The EPDP is requesting that ICANN Org provide its interpretation of the requirement under the RAA Data retention Specification 1.1 whether registrars, as part of their adoption of the 2013 RAA, are required to ensure that Registrant contact email and telephone fields are completed, or whether the phrase "shall maintain that information" (which was validly allowed to be blank at registration time) allows them to preserve any empty Registrant contact fields. If the former, is Contractual Compliance taking any action to ensure that registrars fulfill this obligation?