From: Graham Maltby 
Sent: Tuesday, 28 January 2003 5:52 PM
To: jo.lim@auda.org.au
Subject: Transfers (Change of Registrar) Policy

Dear Jo,

I would like to provide comment regarding shortcomings in the current 
transfer policy related to:

- Required email needed to transfer the domain.
- Early Transfer.

As I see it, there is very little safeguard given by requiring a confirmation 
of the transfer by email, that is not already provided by the domain password.

If an unauthorized party had access to the domain password, it would be a 
simple matter to change the email addresses listed, prior to asking for the 
transfer.  This effectively bypasses any value the process provides.

It also has the unwelcome side effect of preventing a legitimate transfer of 
an expired domain in a timely fashion.  If the administrative email address is 
wrong and the domain is locked pending delete, the email confirmation is one 
more complication before service can be restored.

Finally, early transfer.  I have no specific suggestion but do support the 
option put forward by Enetica Domains;

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Our preferrance is to simply increase the window where a transfer  can be done 
without loss of registration time from the current 90  days to 18 months. This 
would allow registrants the freedom to choose a new registrar anytime after the 
first 6 months, and would  be much closer to gTLD procedures. It also prevents 
the licence from ever being valid for more than 3 &1/2 years, ie repeated 
transfers won't result in a licence valid for 10 years.
----

Thank you for the oportunity to comment.

Regards,
Graham Maltby - Internet Information Group