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The public comment announcement is available at

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: Inter-Registrar Transfer Policy Part B Working Group Proposed Final

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Report 

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ALAC Statement on the Inter-Registrar Transfer Policy Part B Working Group Proposed Final Report - REVISED DRAFT

The ALAC supports all of the recommendations in the Inter-Registrar Transfer Policy Part B Working Group Proposed Final Report.

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An automated response is not considered acceptable as it eliminates the intent of establishing communications between the registrars.

- Should there be any consequences when a response is not received within the required timeframe?

The Emergency Action Channel would have no meaning if there were not consequences to no response.  Consequences should include a provision for the registry unilaterally reversing the transfer and possibly fines.

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The Emergency Action Channel may be useful for a number of registrar issues. Those are likely outside the scope of this PDP, but other uses should not be precluded.

 Recommendation 2.

The ALAC supports the concept of increased and improved registrant education. Although it is not clear that the ALAC should be designated as the prime channel for such activities, it may be considered one of the possible channels, factoring in the limited ICANN budget at its disposal for such activities and the limited control over volunteer time that it exercises.

The ALAC supports the concept of increased and improved registrant education. The ALAC, through its RALOs and ALSs can interact with users worldwide in ways that are both geographically close and culturally sensitive. Although it is not clear that the ALAC should be designated as the prime channel for such activities, The ALAC and At-Large may be considered one of the possible channels, factoring in the limited ICANN budget at its disposal for such activities and the limited control over volunteer time that it exercises.