[registrars] VeriSign Registrar Comments on Status of Registrar Transfer Issue

["Beckwith, Bruce" <bbeckwith@verisign.com>]

Dear Registrar Constituency Colleagues, 

We at the VeriSign Registrar are encouraged by the meaningful discussion
within the Registrar Constituency regarding the issue of intra-registrar
transfers.  It is apparent that there is a better understanding now of all
of the issues, both large and small, that we as registrars face when trying
to address our customer requests for a transfer.

The proposed agreement, which encompassed a very large effort by Elana and
Ross, took significant strides towards having a Constituency-wide document.
As seen in registrars@dnso.org <mailto:registrars@dnso.org>  postings by
Elana Broitman (9/20, 9/25), Larry Erlich (9/23), Bhavin Turakhia (9/23,
9/26), David Wascher (9/24, 9/25), among others, there are major outstanding
issues that need to be addressed before we could say that the Registrar
Constituency has completely addressed this question.  In addition, as we
have stated in the past, this document should also address the thorny issues
of setting clear definitions for many aspects of registrar transfers.  For
example, we need to clearly define apparent authority, as well as how a
third party could validate transfers.  There is also not sufficient
discussion in the document on the registrar/registrant contract, and
how/whether an ISP/reseller can act as an agent on behalf of the registrant,
since they are not a party to the registrar/registrant contract (a facet of
the apparent authority definition that is needed).

Finally, it is very important that we understand that non-registrars need to
participate in the policy-formation process for the result to have
credibility.  Most importantly, we need to consult with registrants (i.e.,
consumers), who are the very important other half of this equation.

The VeriSign Registrar will vote to disapprove the current version of the
document, not because we object to its content, but because we, like many
others, see it as incomplete.  Approving a well-meaning but partially
completed framework, as if it were complete, does not help us move the ball
forward.  We believe that the Internet Community, consumers, and Registrars
themselves, would be best served by having a complete transfer document
agreed-upon, rather than a first-attempt, with major gaps in it.  As we, the
Registrar Constituency, have shown with our track record on the
registry/registrar service level agreement (we put the first document
together and never updated it as we promised we would), we hope that the
Constituency will enhance the transfer document with these additional points
and include other interests in the dialogue to have a complete document that
we can all agree on.  We would appreciate the opportunity to have input to
the revisions with this next iteration of the transfer position document.

Best regards, 

Bruce Beckwith 
VeriSign Registrar