Versions Compared

Key

  • This line was added.
  • This line was removed.
  • Formatting was changed.

...

It is the understanding of the ALAC that the belief within the PEDNR WG was that all provisions of the RAA that applied to registrars must be enforced by registrars on resellers (for those who use them). Since that has now proven to be false (reference to Greenberg post) it is imperative that either sections 4.1.2 and 4.2.3 of the proposed ERRP not be omitted, or the ERRP wording otherwise be adjusted to ensure that it covers websites operated by resellers.

The ALAC understands that registrars might be reluctant to include terms that have not been fully vetted during the PDP process, but the two paragraphs in question are identical in impact to the existing 3.12.5 and should have no unforeseen consequences not already in the current RAA.

Without these two paragraphs, there is no obligation for a registrar to ensure that a reseller displays this information and a significant percentage of registrants, those who deal with resellers, may be deprived of this information.  The access to this information that the PDP was attempting to ensure is no longer guaranteed, and the registrar, by subcontracting services to a reseller, has effectively been relieved from fulfilling these RAA obligations. This calls into question the value of the immense time and energy that the community puts into developing PDP Consensus Policy Recommendations and indeed the effectiveness of the entire RAA.