AT-LARGE GATEWAY
At-Large Regional Policy Engagement Program (ARPEP)
At-Large Review Implementation Plan Development
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Inter-ˇRegistrar
Transfer
Policy
Part
B
–
Recommendation
#9
–
part
2
New
provision
on
when
and
how
domains
may
be
locked
or
unlocked
Public
comments
are
sought
(by
13
February)
to
changes
to
the
Inter-ˇ
Registrar
Transfer
Policy
(IRTP)
proposed
by
the
ICANN
staff,
at
the
request
of
the
GNSO.
Recommendation:
That
ALAC
supports
the
changes
proposed
by
ICANN
staff,
as
set
out
in
their
Proposal
of
22
November
2011
Background:
Because
this
policy
supports
the
process
whereby
registrants
can
transfer
their
domain
name
from
one
accredited
registrar
to
another,
this
is
of
concern
to
ALAC
–
representing
users
–
and
we
should
support
changes
that
clarify/enhance
user
rights.
The
specific
changes
proposed
are
about
‘domain
locks’
that
can
be
imposed
by
registrars
to
prevent
registry
changes
to
the
domain
name
that
the
registrant
does
not
intend
or
authorize.
‘Domain
locks’
are
mentioned
in
the
paper
SSAC
044:
A
Registrants
Guide
to
Protecting
Domain
Name
Registration
as
one
way
that
registrants’
rights
to
their
domain
name
can
be
protected.
However,
the
IRTP
recognizes
and
supports
the
right
of
a
duly
authorized
registrant
to
transfer
from
one
registrar
to
another.
(NB:
one
issue
in
the
proposed
policy
is
the
suggested
use
of
WHOIS
data
as
one
means
to
verify
the
authenticity
of
the
request
for
transfer
–
which
may
be
of
concern
given
the
significant
inaccuracy
of
WHOIS
data)
A
summary
of
what
is
proposed
by
the
ICANN
staff
is:
• Registrar
may
only
impose
a
lock
that
would
prohibit
transfer
of
the
domain
name
if
it
includes
in
its
registration
agreement
the
terms
and
conditions
for
imposing
such
lock
and
obtains
express
consent
from
the
Registered
Name
Holder:
and
• Registrar
must
remove
the
“Registrar
Lock”
status
within
five
(5)
calendar
days
of
the
Registered
Name
Holder’s
initial
request,
if
the
Registrar
does
not
provide
facilities
for
the
Registered
Name
Holder
to
remove
the
“Registrar
Lock”
status
Proposed
changes
The
specific
changes
proposed
are
as
follows:
The
new
clause
in
Part
3,
Clause
6-°©‐7
(Reasons
for
Denial)
is:
Express
objection
to
the
transfer
by
the
authorized
Transfer
Contact.
Objection
could
take
the
form
of
specific
request
(either
by
paper
or
electronic
means)
by
the
authorized
Transfer
Contact
to
deny
a
particular
transfer
request,
or
a
general
objection
to
all
transfer
requests
received
by
the
Registrar,
either
temporarily
or
indefinitely.
In
all
cases,
the
objection
must
be
provided
with
the
express
and
informed
consent
of
the
authorized
Transfer
Contact
on
an
opt-ˇin
basis
and
upon
request
by
the
authorized
Transfer
Contact,
the
Registrar
must
remove
the
lock
or
provide
a
reasonably
accessible
method
for
the
authorized
Transfer
Contact
to
remove
the
lock
within
five
(5)
calendar
days.
As
a
consequence
of
the
proposed
change
above
(more
fully
spelling
out
requirements
on
registrars),
under
the
list
of
when
a
requested
change
of
registrar
may
not
be
denied,
the
following
change
was
made:
• Domain
name
in““Registrar
Lock””status,
(the
following
is
now
deleted:
unless
the
Registered
Name
Holder
is
provided
with
the
reasonable
opportunity
and
ability
to
unlock
the
domain
name
prior
to
the
Transfer
Request.)
The
other
ICANN
proposed
change
is
to
section
5:
“Registrar
Lock”
Status
and
EPP
-°©‐
based
Registry
Requirements
for
Registrars.
Subject
to
ICANN
specifications
or
policies
and
any
applicable
laws
or
regulations,
Registrars
must
follow
the
requirements
set
forth
below….
Registrar
may
set
a
domain
name
in
“Registrar
Lock”
status
(or
with
the
EPP
status
code
“client
Transfer
Prohibited”)
upon
registration
or
subsequent
request
by
the
Registered
Name
Holder
provided
that
the
Registrar
includes
in
its
registration
agreement
and
obtains
express
consent
from
the
Registered
Name
Holder
the
terms
and
conditions
upon
which
it
locks
and
prohibits
transfer
of
the
domain
name.
Further,
the
Registrar
must
remove
the
“Registrar
Lock”
status
within
five
(5)
calendar
days
of
the
Registered
Name
Holder’s
initial
request,
if
the
Registrar
does
not
provide
facilities
for
the
Registered
Name
Holder
to
remove
the
“Registrar
Lock”
status.