On behalf of fTLD Registry Services (fTLD), Registry Operator (RO) of the
..BANK and .INSURANCE gTLDs, I am grateful for the work Scott Kitterman has
done for us with draft-ietf-dmarc-psd and others who have worked diligently
to advance this effort.  fTLD started discussing DMARC for gTLDs/PSDs with
an internal working group in June 2018, which led to the publication of the
first Internet-Draft (ID) in October 2018. We continue to meet regularly to
evolve the ID inclusive of comments and concerns raised by members of the
IETF DMARC Working Group.



As the RO for two of the most trusted and secure gTLDs on the Internet, we
have and continue to explore ways to enhance security for registrants using
..BANK and .INSURANCE and the consumers they serve. Prior to the launch of
our TLDs in 2015 and 2016 respectively, we specified several Security
Requirements, accessible at https://www.ftld.com/security/, that must be
implemented for domains in our zones inclusive of Email Authentication
(i.e., DMARC plus SPF and/or DKIM (though we advocate both). fTLD regularly
monitors for compliance with all requirements and takes enforcement action
when necessary.



fTLD began our exploratory work more than a year ago and believe DMARC for
PSDs will provide a variety of benefits including, but not limited to:

- Threat intelligence into sources of abuse;

- Protection for NXDOMAINs against nefarious e-mail borne activities;

- Brand protection; and

- Compliance enforcement for PSDs that have policy control for their
zone(s).



We appreciate that for PSDs under contract with ICANN there is currently a
prohibition of the activity presented in the ID. Notwithstanding this,
there are other types of PSDs (e.g., country-code Top-Level Domains
(ccTLDs), TLDs not governed by ICANN contract (e.g., .MIL, .GOV, .EDU))
that can experiment with DMARC for PSDs. When the IETF work is sufficiently
advanced, fTLD anticipates pursuing permission from ICANN to implement
DMARC at the TLD level as soon as practicable.


Sincerely,

Craig


*--*
Craig Schwartz
Managing Director
fTLD Registry Services | .BANK & .INSURANCE
Office: +1 202 589 2532
Mobile: +1 202 236 1154
Skype: craig-schwartz
www.fTLD.com
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