Description of TLD Policies

• Uniform Dispute Resolution Policy

Your response should comprehensively describe policies on all topics to be followed in connection with the proposed TLD. The following items (E2‑E10) are examples only and should not limit your description.

E2. TLD String. Please identify the TLD string(s) you are proposing. For format requirements for TLD strings, see the answer to FAQ #5.

We propose a restricted TLD to be used by entities from the financial sector. The first preference therefore is:

.FIN

We recognize that this string is part of ISO-3166-1 alpha-3, which, according to the FAQ does not exclude its usage for this purpose. If, however, there are concerns about use of this 3-letter string, an alternative string could be:

. FINANCE

or a shortened version of this string if the community prefers it.

In the rest of these documents, we will refer to .FIN in the text, with the understanding that it could be changed.

E3. Naming conventions. Describe the naming conventions and structure within the TLD. E.g., will registrants have names registered at the second level (directly under the TLD, as in registered‑name.com), or will the TLD be organized with sub‑domains so that registered domain names are created at a lower level (as in registered‑name.travel.com)?

Basically, most registrations will be for 2^nd level domains, for example, AXA.FIN, ALLIANZ.FIN, MARSH.FIN…

During the first six months of operation, we propose that applications will be accepted, but registrations will not take effect until the end of the period (See response to Question E.12) Also, during this initial period, the SO will survey the financial community regarding the possible reservation of certain special terms that are words in common usage (for example, LOAN.FIN or, INFO.FIN). Some terms may be proposed for total exclusion, or for use as generic 2d level domains. If the Board of the Sponsoring Organization (SO) determines that a term should be reserved as a 2d level domain, then user registrations would be allowed in the 3^rd level.

In addition, all strings in the ISO-3166-1 alpha-2 list will be excluded from use as 2d level domains, subject to review by the Board of the SO.

E4. Registrars. Describe in detail the policies for selection of, and competition among, registrars. Will domain‑name holders deal through registrars, directly with the registry operator, or some combination of the two? What are the respective roles, functions, and responsibilities for the registry operator and registrars? If registrars are to be employed, how and by whom will they be selected or accredited? If the number of registrars will be restricted, what number of registrars will be selected? Have the qualifying registrars already been selected? On what basis will selections among those seeking to be registrars be made, and who will make them? If registrars are to be used, what mechanisms will be used to ensure that TLD policies are implemented?

There will be a procedure for entities which applies to become a registrar for these TLD. The SO Board will have to set up the final rules, among the proposed rules will be:

· Application (documents to be defined and posted on the registry Web) to be send by registered letter to registry

· Must be accredited by ICANN

· Application fee is EUR 5,000 (includes first annual fee)

· Annual renewal fee EUR 2,000

· Specific wordings for agreement with registrant will be forced (regarding hot line for instance)

· Special agreement between registry and registrar to be signed

· Pricing will be up to the registrar

· Prepayment or evidence that payment will occur (long relationship) is needed

· Technical test before going life

· Disputes about the accreditation shall be resolved by SO

Registrants will normally deal with the registry only through registrars. Agreements for registration, invoicing and payment for registrants will be with the registrar. In the case of disputes between registrant and registrar, transfer of a domain name registration to another registrar and change of registrant of an existing domain, the registrant will deal with the registry and procedures will be established for these transactions.

The registry will send a certificate of the registration of the domain to each registrant by registered letter and email.

E5. Intellectual Property Provisions. Describe the policies for protection of intellectual property. Your response should address at least the following questions, as appropriate to the TLD:

E5.1. What measures will be taken to discourage registration of domain names that infringe intellectual property rights?

We propose a 30-day waiting period for the activation of all registrations. During this period, the Registry will randomly review the qualifications of the applicant, and its proposal for the domain name registration will be posted on the Internet, so that registration applications can be monitored by interested parties.

E5.2. If you are proposing pre‑screening for potentially infringing registrations, how will the pre‑screening be performed?

The pre-screening procedure will be the Registry’s review of an applicant’s qualifications to be registered in this restricted domain.

E5.3. What registration practices will be employed to minimize abusive registrations?

The Registry’s pre-screening procedure will be directed to assuring that only financial entities in certain SIC codes (standard international codes) and only those entities that are fully in compliance with applicable legal and regulatory requirements will be allowed to register in the domain. In addition, the SO Board will make an initial determination of eligibility in the case of protests, or will refer questions regarding intellectual property disputes to be determined according to the Uniform Dispute Resolution Policy (UDRP). Decisions of the Board will be appeal able to UNCITRAL.

E5.4. What measures do you propose to comply with applicable trademark and anti‑cyber squatting legislation?

The registrars, the registry and the SO will adopt the UDRP for resolution of trademark disputes. The registry will also comply with all decisions by competent legal authorities having jurisdiction over the parties to controversies relating to registrations.

E5.5. Are you proposing any special protections (other than during the start‑up period) for famous trademarks?

We do not propose any special protection beyond the procedures outline above.

E5.6. How will complete, up‑to‑date, reliable, and conveniently provided WHOIS data be maintained, updated, and accessed concerning registrations in the TLD?

The registry will run the authoritative WHOIS-server, which will be updated at 15 minutes intervals. Data will be shown in machine- and human- readable formats. A Web-interface for the WHOIS-server will be available.

See also D13.2.1 where among others are listed:

“…

4. WHOIS for public allowing everybody to query for information

5. Bulk – WHOIS for special purposes with restricted policy for the usage

…”.

E6. Dispute Resolution. Describe the policies for domain name and other dispute resolution. If you are proposing variations to the policies followed in .com, .net, and .org, consider the following questions:

We propose to adhere to the policies followed in .com, .net and .org, including the UDRP. In addition, the UNCITRAL will be available for the resolution of disputes that are outside the scope of the UDRP.

E6.1. To what extent are you proposing to implement the Uniform Dispute Resolution Policy?

The UDRP will be the standard policy.

E6.2. Please describe any additional, alternative, or supplemental dispute resolution procedures you are proposing.

No additional, alternative or supplemental dispute resolution procedure is proposed.

E7. Data Privacy, Escrow, and WHOIS. Describe the proposed policies on data privacy, escrow and WHOIS service.

Data Privacy: The registry’s WHOIS, as described above, will be available through a web site. The information posted (also described above) will be publicly available information relating only to financial institutions and contact persons designated by the institutions. European privacy law will apply.

Escrow: A weekly escrow-backup-disc will be send to an escrow (see D15.2.7). Additionally there will be daily backups for recovery purposes at 2 different locations. External and recognized escrow service company is to be selected.

E8. Billing and Collection. Describe variations in or additions to the policies for billing and collection.

No registration will become effective until payment is made by the registrar to the registry.

Advanced payment will be requested from registrars.

Payments by the registrars to the registry may be made by bank-transfer or credit card.

E9. Services and Pricing. What registration services do you propose to establish charges for and, for each such service, how much do you propose to charge?

The registrars will be charged according to the following table:

Service	Price in EUR per year
1.) one year registration	100
2.) Yearly renewal	90
3.) Weekly Bulk-WHOIS	10,000
4.) Special protection of data	200
5.) WHOIS	0
6.) Name service	0
7.) Special Web-Service for search	0
8.) Help desk for registrars	0
9.) Certificates	0

See also D13.2.1. for additional details. It should be noted that the above prices to registrars are for the first operation year in scenario “50M”.

E10. Other. Please describe any policies concerning topics not covered by the above questions.

Registrations will be effective for one-year periods. An application for renewal will be handled in the same manner as an initial application.

II. REGISTRATION POLICIES DURING THE START‑UP PERIOD (Required for all TLDs)

E11. In this section, you should thoroughly describe all policies (including implementation details) that you propose to follow during the start‑up phase of registrations in the TLD, to the extent they differ from the General TLD Policies covered in items E1‑E9. The following questions highlight some of the areas that should be considered for start‑up policies:

E12. How do you propose to address the potential rush for registration at the initial opening of the TLD? How many requested registrations do you project will be received by the registry operator within the first day, week, month, and quarter? What period do you believe should be considered the TLD's "start‑up period," during which special procedures should apply?

As explained in E3, during the first 6 months of operation, a decision will be made on the selection of "reserved" 2^nd level domains, and no registrations will take place during that time. Applications will be accepted from registrars during the initial six-month period, and will be published, with the understanding that the registration will not become effective until the expiration of the period.

There will be a substantial number of applications (assumption is 20 % of the registrations of year 1 of scenario “50M”, i.e. 10,000) received by registrars and transmitted to the registry during the start-up period and that duplicate requests will be received. A round-robin-process will be used to resolve duplicate requests, as follows:

During the initial period, there will be successive 3-day time segments during each of which the applications for registration will be queued by the registry, with one queue for each registrar. After day 3 of each segment, the queue will be closed and processed. We assume that processing can be completed in 3 days, and that new set of queues can begin. The processing will function as follows:

· Randomly re-sort each individual queue, (making it useless to sell a rank position in a registrar’s queue). We propose that pre-registrations of same names by same holders will be deleted before sorting, however technical realization is still under development.

· Sorting the queues (i.e. defining which queue is no 1, no. 2 etc).

· In each round process only one request from each queue and then, (regardless of the success of the application) proceed to the next queue and repeat the process until all queues are empty

This process can be repeated during the initial period to process newly built queues, thereby reducing any backlog of initial applications and allowing the normal processing to commence at the end of the initial period.

E13. Do you propose to place limits on the number of registrations per registrant? Per registrar? If so, how will these limits be implemented?

No. In a restricted domain, such as .FIN, we do not see a need for such a policy, especially in light of the procedures to assure compliance with the qualification standards for the domain.

E14. Will pricing mechanisms be used to dampen a rush for registration at the initial opening of the TLD? If so, please describe these mechanisms in detail.

No. We have established prices which we believe are adequate for support of the registry and SO and we do not see a need for making price a means of preferential treatment.

This will allow equal market access to any registrants.

E15. Will you offer any "sunrise period" in which certain potential registrants are offered the opportunity to register before registration is open to the general public? If so, to whom will this opportunity be offered (those with famous marks, registered trademarks, second‑level domains in other TLDs, pre‑registrations of some sort, etc.)? How will you implement this?

No. We do not propose a ”sunrise period” either for 2d or higher level domains. We believe that the procedure for establishing reserved 2d level domains and the dispute resolution procedures will adequately address trademark issues that may arise.

III. REGISTRATION RESTRICTIONS (Required for restricted TLDs only)

E16. As noted in the New TLD Application Process Overview, a restricted TLD is one with enforced restrictions on (1) who may apply for a registration within the domain, (2) what uses may be made of those registrations, or (3) both. In this section, please describe in detail the restrictions you propose to apply to the TLD. Your description should define the criteria to be employed, the manner in which you propose they be enforced, and the consequences of violation of the restrictions. Examples of matters that should be addressed are:

E17. Describe in detail the criteria for registration in the TLD. Provide a full explanation of the reasoning behind the specific policies chosen.

At present nor the SO nor the registry are in a position to describe accurately what will be the criteria which will have to be met by the potential registrants to register a .FIN domain name. However, in great number of countries, there are well-established institutions granting various licenses to companies or individuals operating in the broad financial field. The SO will heavily rely on their work and professionalism to set up and maintain a list of agencies and regulatory authorities,… which accreditation to exercise a financial activity will cause a potential registrant to be allowed to register a fin names.

In other countries and in other cases (for instance for financial editor), the SO will rely on country licensing where applicable, and as a general rule, apply all fairness to application review. The aim will be constantly to serve best the Internet world and the financial community at large.

The involved SIC codes that we consider as those of natural members of the .FIN community are listed in appendix E17.

E18. Describe the application process for potential registrants in the TLD.

The detailed process of registrant application will be defined by the registry and approved by the SO.

The following process is proposed: registrant will have to provide a proof of affiliation or certification by a national regulators related to the financial industry (a detailed list will be published by the SO) or a proof of membership of the SO itself. For companies that meet the criteria for being a member of the .FIN community but who cannot provide a valid certificate a direct membership application process will be established.

The registrars will have to check manually the completeness of materials provided by the registrants and send a digital copy of it to the registry.

A list of new .FIN domain names will be publicly available during one month, if no dispute occurred during this period, the registrant will be granted by the sponsoring organization the right to use its .FIN domain name for one year.

E19. Describe the enforcement procedures and mechanisms for ensuring registrants meet the registration requirements.

The security of the system rely on:

The ability of the registry to check the completeness of the credentials provided by the registrants
The quality of the reporting/auditing procedures

The sponsoring organization will conduct annual audit of all .FIN registrars. The auditing teams will be selected among internationally recognized auditors. Failure to meet the quality procedures could end to the withdrawal of the .FIN registrar license.

There will be an annual refund to registrars depending on the quality of their registration in order to provide a financial incentive to register members of the financial community properly.

E20. Describe any appeal process from denial of registration.

Appeals from decisions by the SO regarding denial of registration will be referred to [insert name of arbitration organization] and the SO will abide by its judgments.

E21. Describe any procedure that permits third parties to seek cancellation of a TLD registration for failure to comply with restrictions.

A procedure will be established for referral of cancellation petitions to a committee appointed by the Board of the SO. Committee decisions will be ratified or rejected by the Board of the SO, and an aggrieved party will then the opportunity to make a further appeal to be determined by UNCITRAL.

IV. CONTEXT OF THE TLD WITHIN THE DNS (Required for all TLDs)

E22. This section is intended to allow you to describe the benefits of the TLD and the reasons why it would benefit the global Internet community or some segment of that community. Issues you might consider addressing include:

E23. What will distinguish the TLD from existing or other proposed TLDs? How will this distinction be beneficial?

Internet users will have the assurance that domain name holders in the .FIN domain are qualified organizations under the laws of their jurisdictions. This will contribute to prevent fraudulent entities from representing themselves as legitimate businesses in the financial field. The domain .FIN will itself offer an intuitive guide to the location of financial institutions. Searches for the web sites of financial institutions will be aided by a specialized web-based-search-tool which will be made available. Registrants in the domain will be able to categorize themselves as follows:

· Geographic area of activities

· Corporate structure, including status as parent or subsidiary, or individual professional

· Membership in professional organizations

· Type of financial offerings and services

· Language(s) spoken

· Individual statements and comments

· Graphic images and symbols

· Links to other web sites

The web-based search-tool will be available in 7 languages, including the 6 official UN languages

· English

· French

· Russian

· Spanish

· Arabic

· Chinese

· German (not UN official language)

This publicly available information will enable consumers of financial services to make informed choices among competing providers and will undoubtedly be of great advantage to the public.

E24. What community and/or market will be served or targeted by this TLD? To what extent is that community or market already served by the DNS?

The community served by the .FIN TLD will be the Internet community at large because financial services are necessary to anyone. The .FIN will target the existing financial industry that is still poorly represented by the .com sites. Being a restricted TLD the .FIN will allow the finance industry to be better served and provide a better service to its customers. We estimate the overall size of the market to be around 1,000,000 financial institutions. (See D13.2.3)

E25. Please describe in detail how your proposal would enable the DNS to meet presently unmet needs.

Given the explosive growth of the Internet, more and more end-users are confronted with an almost incredible mass of available information which is increasingly difficult to use. Many users find themselves lost in the existing generic top level domains because of lack of meaningful categorization of web sites. Purportedly automatic solutions (as offered by web search engines) do not really help the user and in some cases increase the confusion. For example, techniques like “keying” may mislead a user who enters a term and is then led to a web site maintained by a competitor of the entity originally sought out by the user. The misuse of meta-tags also contributes to user confusion. The proposed .FIN domain will filter applicants for registration so that the user can be sure that registrants are in the financial services field. In addition it will provide a user-friendly profile of registrants which can be used to find relevant addresses (Cf. the response to Question E.23.).

E26. How would the introduction of the TLD enhance the utility of the DNS for Internet users? For the community served by the TLD?

The .FIN TLD will allow a better categorization which is an essential need for the future of the DNS. Moreover, the large fields encompassed by the finance industry will allow this TLD to handle new electronic payment system name directory such as ATM networks or credit-card gateways.

The third level domain name such as bank.FIN or insurance.FIN will also allow specialized intermediaries to be well categorized on the Internet.

E27. How would the proposed TLD enhance competition in domain‑name registration services, including competition with existing TLD registries?

Registrants from thee financial sector will be offered an alternative to the undifferentiated generic TLDs already in use. It is possible, especially at the initial stages, that some registrants with existing registrations in generic or country code domains may retain these until the .FIN domain is well established, but we believe that eventually it will become the logical choice in preference to the existing top level domains for financial entities.

V. VALUE OF PROPOSAL AS A PROOF OF CONCEPT (Required for all TLDs)

E28. Recent experience in the introduction of new TLDs is limited in some respects. The current program of establishing new TLDs is intended to allow evaluation of possible additions and enhancements to the DNS and possible methods of implementing them. Stated differently, the current program is intended to serve as a "proof of concept" for ways in which the DNS might evolve in the longer term. This section of the application is designed to gather information regarding what specific concept(s) could be evaluated if the proposed TLD is introduced, how you propose the evaluation should be done, and what information would be learned that might be instructive in the long‑term management of the DNS. Well‑considered and articulated responses to this section will be positively viewed in the selection process. Matters you should discuss in this section include:

E29. What concepts are likely to be proved/disproved by evaluation of the introduction of this TLD in the manner you propose?

Concept 1: Financial institutions need a top level domain that is differentiated from .com, .net and .org.

Concept 2: Users will prefer multiple generic domains as a better means of making intuitive searches for a relevant web site

Concept 3: There will be less instances of trademark disputes when registrants in the financial field can have a domain separate from business entities generally

. FIN will enable the evaluation of these concepts.

We believe that global competition among financial institutions is increasing and ultimately this will be of enormous benefit to users of the Internet. There are presently no comprehensive world organizations that bring together all the actors in several overlapping activities such as commercial banks, investment banks, assets management institutions, insurance companies, brokers, and distributors of financial products The institution of .FIN TLD would be of substantial assistance in fostering global competition in this area.

We also believe that the Internet has a “leveling” effect among the global competitors in the financial services field. Newcomers to the field will have the capability to achieve as much visibility through a web site as long established entities.

The success of the .FIN TLD should prove that the Internet is a powerful agent for competition on the global scale, in which old and new economy players will meet and compete for customers. be .

E30. How do you propose that the results of the introduction should be evaluated? By what criteria should the success or lack of success of the TLD be evaluated?

We believe that the test of success of the introduction of the .FIN domain will be a combination of the number of registrants and the number of users. These figures are capable of being determined and compared to the number of registrants and users of the existing domains.

E31. In what way would the results of the evaluation assist in the long‑range management of the DNS?

The experience resulting from the introduction of the .FIN TLD will be useful for analysis of the entire concept of expanding the field of generic top level domains. The results will be particularly valuable for analysis of the concept that the Internet needs new domains which refer to fundamental categories of business organizations. It should not be overlooked that this concept of categorization can be applied to nearly all types of human needs that are met by the Internet.

E32. Are there any reasons other than evaluation of the introduction process that this particular TLD should be included in the initial introduction?

The .FIN domain offers a unique opportunity for a very large and globally diverse group of entities to come together on a level playing field and serve users in an entirely new way. The institutions of the financial sector have the monetary and technical resources and the motivation to make this domain succeed. Many of the financial institutions that will use .FIN are well known, experienced and prosperous in their respective sectors. Success in the .FIN TLD will give other industries the "drive" and confidence to implement DNS in their thinking and plans.

Also, the fact that there does not exist a worldwide association representing the needs and interests of the financial services sector is a powerful argument for using a new domain to serve these needs and interests. The domain could become a model for successor categorized domains and show how to build consensus within a defined population with similar objectives.

By signing this application through its representative, the Applicant attests that the information contained in this Description of TLD Policies, and all referenced supporting documents, are true and accurate to the best of Applicant's knowledge.

_______________________________

Signature

_______________________________

Name (please print)

ETIENNE FRANZI

_______________________________

Title

PRESIDENT

_______________________________

Name of Applicant Entity

Association Monégasque des Banques

_______________________________

Date

28/09/2000

Updated August 15, 2000