Hello,

Reading the new transfers policy at:

http://www.icann.org/transfers/policy-12jul04.htm

I was wondering about the "60 day" rules in Section A.3:

"The Registrar of Record may deny a transfer request only in the
following specific instances:
....
8. A domain name is in the first 60 days of an initial registration
period.
9. A domain name is within 60 days (or a lesser period to be
determined) after being transferred (apart from being transferred back
to the original Registrar in cases where both Registrars so agree
and/or where a decision in the dispute resolution process so directs)."

The key part is "MAY DENY A TRANSFER" (as opposed to "must"). I was
under the impression that under the current rules, #8 is a "must", as
it's prevented by the registry itself. Does that remain true? Or, would
one be allowed to transfer before the 60 days now?

Also, for section #9, currently that is truly a "may", in that some
registrars (like OpenSRS) allow transfers out before 60 days have
elapsed after a transfer in, while some don't (I think GoDaddy
doesn't). Will that continue to be allowed, or will OpenSRS turn that
into a hard limit?

For fraud protection, I can understand wanting to make it a hard limit
of 60 days (I've helped folks recover stolen domains, and the ability
to move multiple times to some of the uncooperative registrars
definitely helps the thieves in covering their tracks and making
forensics more challenging), but having a less binding rule can also
help, for transfers related to legitimate sales, etc. Just wondering
what the new rules will be at OpenSRS.

Sincerely,

George Kirikos
http://www.kirikos.com/

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