Generally, Much better, Nominet has clearly listened to consultation feedback and seems to have listened with respect. Incorporates a new Data Quality Policy for all Channel partners. Confidentiality clause is welcome. Good help for existing Registrars who feel unable to meet the Channel Partner Tag, ie. they won’t be blocked from WHOIS2 on the Self Managed TAG Force Majeure easier to read. No charge for Tag Classification is obviously welcome for Registrars faced with funding the migration. Long-term it looks like fees are going to be introduced. The definition of Reseller is confusing - several of my contacts within client organisations fall within this definition. Very much welcome the explanation in the Notes and Summary of Feedback that “many smaller Registrars exemplify excellent standards of customer service and data quality” - i.e. this is not just for our big Registrars. Self managed and Accredited get free registrant transfers but not Channel Partners Nominet does lots of explaining about the rights to pick up expired domains with - and how it won’t just benefit the largest Registrars - i.e. board members - that makes me worried. I just cannot work out how this is going to pan out in practice. However, the clarification that the permission to take over a Registrant’s domain name must be obtained during the 60 expiry window, not at registration, is most welcome. I agree that the restriction in 2.1.14 could cause problems during a DDOS and Nominet’s test for customer’s “explicit, unprompted request” is subjective and open to abuse. Enforcement The removal of the CEO (ie. another board member) as the adjudicator following contract termination is obviously welcome. CEDR is welcome - ACAS would not be welcome!! I have a question - Nominet has long standing professional relationship with CEDR (which there is nothing wrong with) - but could give rise to potential conflicts in exceptional circumstances and it may be worthwhile looking at other backup providers like CIArb. Data Quality Policy Clear. Fair and inline with international ICANN data quality aspirations - therefore, it’s coming for us all anyway sometime soon. Pleased that the language is about ‘working with’ registrar to improve the quality. Please provide more information about which Registrars Nominet selects to ‘validate’ and which not and when. Open to abuse. 5.1.4 - worried about publishing data quality validation process which involve a number of checks, or not, and open to abuse. I may employ a number of open means and then escalate the matter as needs, including reporting to third parties. How much detail is needed here? UK Address format - it would help to have all the fields. Is there one for House name first, ie. the first line of my address is Springfield House, therefore non-compliant. Phone number - is the prefix of the area code non-compliant? e.g. the (0) part of (0)1865 Sorry please clarify Annex Section 4 with an example. Self managed Tag I need more explanation about the Self Managed Tag being uplifted to Channel Partner obligation within the Self Managed Tag under certain circumstances - for example, when the Tag holder registers a ‘small’ number of names of third parties. ‘Small’ seems a subjective test and open to abuse/confusion. Channel Partner Tag Website and abuse complaint email reasonable (not 24/7 like ICANN thank God) Accredited Channel Partner Tag Classification Much better and more reasonable, less large organisation targeted, and doesn’t require electronically accessible accounts and annual reports. Some of the service commitment, processes for escalating complaints, etc will take some time and cost to produce, and in our case is a little absurd (we have a few customers - i.e. one of them used to be Nominet - for whom we work around the clock), but we need to (and would be proud to be) accredited at the highest level. Therefore, fair enough. The ability to opt out of certain communications being sent directly to Registrants is welcome and look forward to more details. 5.3.2. is confusing - I just don’t understand it fully. I have read the notes as well. On behalf of my customers, I may "transfer from Registrants of domain names on an Accredited Channel Partner Tag” - only from other Accredited Channel Partners? Is that correct? Sanctions - much less aggressive and more constructive, conciliatory - welcome, welcome.