text:
How to Transfer Stocks & Assets from Robinhood to TD Ameritrade
This article compiles a series of steps to guide you in order to successfully transfer stocks and assets from Robinhood to TD Ameritrade.
Robinhood is a great broker, in fact, for many, it is the best broker meanwhile, for some, it instead a limited broker. Many will prefer TD Ameritrade over Robinhood. However, the choice on a broker generally depends on your experience and trading level.
There are compelling reasons for someone to transfer to TD Ameritrade, a more well-known competitor. But, if you do so, does it mean you'll have to sell all of your assets first, then transfer the money?
TD Ameritrade is a full-service broker that has been in operation for decades. They provide a variety of account options, including retirement accounts. Robinhood, on the other hand, does not currently provide retirement accounts.
Can you transfer stocks from Robinhood to TD Ameritrade? Yes, you can use an ACAT transfer to transfer stocks from Robinhood to TD Ameritrade. However, Robinhood will charge you $75 as a transfer fee. TD Ameritrade, on the other hand, will not charge you anything for inbound transfers.
The process of transferring stocks and assets from Robinhood to another broker remain the same as you will have to pay $75 as transfer fee. This is the case with the transfer from Robinhood to Webull or Fidelity.
Robinhood is by far the most-known commission free broker but it isn't the only one out there. Fidelity is another commission-free stock trading platform and offers more trading features than Robinhood. Transferring your stocks from Robinhood to Fidelity can be a great idea. However, keep in mind that if you are a newbie to trading, it will be preferrable you continue with Robinhood as Fidelity and TD Ameritrade are for expert and advanced traders.
That said, if you want distinguished trading features, you are at the right place. In this article, I will show you how to transfer your stocks and assets from Robinhood to TD Ameritrade.
CHECK ALSO: How to Transfer Buying Power From Robinhood to Bank Account [Complete Process]
What is TD Ameritrade and How Does it Works?
TD Ameritrade is an electronic trading platform that allows customers to trade financial assets such as common stocks, preferred stocks, futures contracts, exchange-traded funds, currencies, options, cryptocurrency, mutual funds, fixed income investments, margin lending, and cash management.
Why Should I Transfer Stocks from Robinhood to TD Ameritrade?
Trading with Robinhood offers many benefits. However, it obvious in many cases that TD Ameritrade is the greater choice for almost everyone.
Let's take a look at how they compare in several areas, and then you can determine whether you should switch from Robinhood to TD Ameritrade.
Great Mobile and Trading Experience
When it comes to experience on mobile applications TD Ameritrade surely has a upper hand.
Robinhood is ideal for people who prefer a basic trading interface. It's especially beneficial if you're a complete novice.
TD Ameritrade, on the other hand, offers two separate apps: "regular" and "thinkorswim". The first is for regular traders, while the second is for those who are more experienced and prefer a little more information.
CHECK ALSO: Best Virtual Prepaid Cards for International Shoppers
Easy to Use Desktop/Web App
Although Robinhood has a user-friendly interface, I believe that this is a disadvantage. Many customization choices are unavailable, and orders cannot be staged.
TD Ameritrade, on the other hand, allows you to tailor practically every aspect of your order, from the order type to the quantity and size. Plus, if you're a non-professional, you get Level II quotations for free, which is a hard deal to pass up.
When it comes to the securities that each broker has to offer, it all depends on what you're looking for. There is no apparent winner in this contest.
For example, Robinhood offers a wide range of cryptocurrencies, whereas TD Ameritrade exclusively offers Bitcoin futures trading.
TD Ameritrade, on the other hand, provides access to a wide range of instruments, including bonds, futures/commodities, future options, Forex, and equities on overseas exchanges, whereas Robinhood does not.
CHECK ALSO: List of Banks That Don't Use ChexSystems
When comparing the two brokers based on research tools, TD Ameritrade emerges as the clear winner.
TD Ameritrade has a screener, an idea generator, a calculator, and professional research reports, which Robinhood lacks.
Robinhood provides straightforward content for novice investors and traders, but you'll have a hard time discovering what you're looking for. This is due to the fact that all of their articles are arranged chronologically and there is no search function. They offer a podcast with important suggestions in addition to their articles, but that is the extent of their educational content.
To help you educate yourself, TD Ameritrade has a large library of articles, glossaries, webinars, and videos. As a result, having everything you require in one location is really convenient.
CHECK ALSO: How to Add Money to Robinhood Without Bank Account [Complete Process]
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How to Transfer Stocks & Assets from Robinhood to TD Ameritrade Step by Step
Because of this, you may want to transfer your stocks from Robinhood to TD Ameritrade. Other might have a different reason of wanting to do so.
Whatever your reason may be, if you want to transfer your stocks and assets from Robinhood to TD Ameritrade, there are 3 simple steps you need to follow which are:
Gather information from Robinhood
Open a TD Ameritrade account
Completing the Transfer from Robinhood to TD Ameritrade
1. Gather Information from Robinhood
You'll need to gather certain information from Robinhood in order to transfer stocks out of the platform. Your Robinhood account number is the most crucial information you need to complete this transfer. You can find the account number on your Robinhood statement, and TD Ameritrade will most likely request a copy of it.
Here's how to find your Robinhood account number to Transfer Stocks to TD Ameritrade:
Click on the "Account" icon in the bottom right corner of your screen
Tap on "Investing"
Your account number will be displayed at the top of your screen
To continue with your transfer, you may need to refer to a DTC number. The DTC number for Robinhood is 6769.
Robinhood will charge you $75 when you transfer stocks or cash from Robinhood to an outside brokerage like TD Ameritrade. This fee applies whether you are doing a partial or full transfer.
This fee will be deducted from your Robinhood account's available cash balance before the transfer process begins.
CHECK ALSO: How to Transfer Money From Robinhood to Bank Account [Complete Process]
2. Open a TD Ameritrade Account
You will obviously need a TD Ameritrade account to receive your stocks and assets from Robinhood. To open a TD Ameritrade account, all you need to do is to go to TD Ameritrade Website, click on "Open new account" and follow the steps providing all information to open your account. There is no initial deposit required from you to open the account.
3. Initiating and Completing the Transfer from Robinhood to TD Ameritrade
Once you've opened the account, you can transfer stocks, options, ETFs, and other assets from another brokerage to your TD Ameritrade account.
You cannot, however, transfer cryptocurrencies out of Robinhood. If you have any, you should convert them to cash first. This money will be deposited into your new TD Ameritrade account. Keep in mind that this may result in a capital gain, which you will be responsible for paying taxes on.
Here's how you initiate the transfer from Robinhood to TD Ameritrade
Login to your TD Ameritrade account via their mobile app
Go to "My Account" and from there, select "Account Transfer"
Follow and complete all the prompts necessary for the transfer.
Make sure the name on your Robinhood account matches the name(s) on your receiving TD Ameritrade account for the transfer to be successful.
Once you've initiated the transfer, give it up to 7 working days to complete
CHECK ALSO: Why is My Withdrawable Cash $0 on Robinhood?
How Long Does it Takes to Transfer Stocks from Robinhood to TD Ameritrade?
After you open a TD Ameritrade account and initiate the transfer, you should expect to wait a week for it to be completed.
It may take up to 2 weeks in some cases, but telling how long such a transfer will take is kind of difficult.
Because there may be a variety of factors that influence the time it takes for the transfer to be processed, it's a good idea to contact Robinhood and inquire.
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Final Thoughts on How to Transfer Stocks and Assets from Robinhood to TD Ameritrade
While Robinhood provides access to cryptocurrency and has a user-friendly mobile app, switching to TD Ameritrade has several other advantages.
So it all boils down to what you value the most. TD Ameritrade is a no-brainer if you need a lot of training material, prefer a more complex trading platform, and want to trade a wide range of assets.
The most crucial thing to remember is that you will have to pay $75 to Robinhood to complete the transfer. Of course, after the transfer is complete, you can always ask TD Ameritrade if they would cover this amount.
Moving from Robinhood to TD Ameritrade isn't always a good option, but it appears to be for some, in most cases. Although Robinhood's trading app is more user-friendly, there are many more advantages when using TD Ameritrade. However, as I mentioned earlier, the final choice remains yours.
#Finance #Money Transfers #Robinhood


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Q: Compare object properties in 2 lists I found, in some other questions, information on how to compare two lists of objects and get the difference in the sense that objects in lists are different.
I am not sure if the same/similar thing is possible in the case that I have the same objects in two lists, but with possibly different property values of particular objects in two lists.
Is there a shortcut to check for that case?

A: I think what you want is described on this page:
Example (copied from the above linked MSDN site to keep the answer on StackOverflow):
// This class defines your objects with your properties.
public class ProductA
{
    public string Name { get; set; }
    public int Code { get; set; }
}

// This class is used for custom comparison.
public class ProductComparer : IEqualityComparer<ProductA>
{

    public bool Equals(ProductA x, ProductA y)
    {
        //Check whether the objects are the same object.
        if (Object.ReferenceEquals(x, y)) return true;

        //Check whether the products' properties are equal.
        return x != null && y != null && x.Code.Equals(y.Code) && x.Name.Equals(y.Name);
    }

    public int GetHashCode(ProductA obj)
    {
        int hashProductName = obj.Name == null ? 0 : obj.Name.GetHashCode();
        int hashProductCode = obj.Code.GetHashCode();
        return hashProductName ^ hashProductCode;
    }
}

Here is how you could use that now:
ProductA[] fruits1 = { new ProductA { Name = "apple", Code = 9 },
                   new ProductA { Name = "orange", Code = 4 },
                    new ProductA { Name = "lemon", Code = 12 } };

ProductA[] fruits2 = { new ProductA { Name = "apple", Code = 9 } };

// Get all the elements from the first array except for the elements from the second array.
IEnumerable<ProductA> except = fruits1.Except(fruits2);

redpajama_set_name: RedPajamaStackExchange


Set Pirate Ship - TOP 10 Results for Price Compare - Set Pirate Ship Information for April 26, 2019.
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Good choice for your child.
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Set Pirate Ship - Video Review.


This RC Boat can turn right & left, go forward & reverse, and its design simulates the true style. With sealed compartment for battery and double propeller and switch to test the propeller, which will give your kids fun.
Function Turn Right & Left, Go forward & Reverse.


Home » Testimonials » Natalee W.
One day when I was out for a training run back in 2012, I felt a sudden deep pain in my hip joint. I went to a chiropractor who diagnosed me with a hip flexor strain and sent me on my way. After many months, my hip never felt better and I was unable to run, walk, sit, and basically do anything without pain. It became chronic and I had to cease all triathlon training except swimming, during which I still experienced mild pain. I thought I could never run again.
After one year of no answers and another flare-up, I went to TCO's Orthopedic Urgent Care Clinic and was lucky to see one of Dr. Larson's partners who quickly diagnosed my labral tears and FAI. After my initial appointment with Dr. Larson, I knew surgery was my only option to get back to racing triathlons again. My left hip was done in November 2013 and right hip done August 2014. My PT Emily Beyer, a gifted soul and skilled therapist made a tremendous impact on me and my recovery.
In June 2015 I finally was able to compete in my first race since the onset of my injuries, and finished 19th out of 96 women and 1st place in my age group! And NO HIP PAIN! Today I am running and biking just as fast as I was before my injuries, having just started training a few months ago.
I am filled with the utmost gratitude for Dr. Larson and all his staff, and will forever be grateful. What Dr. Larson does really changes lives, and now I can continue chasing my dream of being a competitive triathlete. Thank you!!!!


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Dior is presenting an epic style for DIORCLUB3 sunglasses, the collection was inspired by Niki De Saint Phalle's art work. Super model Sasha Pivovarova is the star of DIORCLUB3′ Spring Summer 2018 advertising campaign. Sasha is also showing her amazing painting together for the shoot. The sunglasses are different, lit and absolutely cool.


text:
Longest River in India 2022: Top 10 Longest & Largest River in India with important facts
December 7, 2022 June 18, 2022 by srikantomandal
India is well-known as the land of rivers as numerous rivers are flowing across the country. It plays a huge role in the economic development of the country. Rivers are the major irrigation sources of India.
The rivers in India have been divided into two, namely Himalayan Rivers (rivers that originate from the Himalayas) and Peninsular Rivers (rivers that originate in the Peninsula). Himalayan Rivers are perennial while Peninsular Rivers are rain-fed. Here, in this article, we will talk about the top 10 longest rivers in India.
Top 10 Longest Rivers in India
Source and Source location of the longest rivers
Major Tributaries of the Top 10 longest rivers in India.
Major Facts about the Longest river in India
1. Ganges River (2525 Km)
2. Godavari River (1464 Km)
3. Krishna River (1400 Km)
4. Yamuna River (1376 Km)
5. Narmada River (1312 Km)
6. Indus River (1114 Km)
7. Brahmaputra River (2900 Km)
7. Mahanadi River (890 Km)
8. Kaveri River (800 Km)
10. Tapti River
Frequently Asked Questions (FAQ) on the longest river in India
Q 1. Which is the longest river in India?
Q 2. How many major transboundary rivers are there in India?
Q3. Which is the second-longest river in India?
Q4. Which is the longest river in South India?
Q5. Which is the largest river in India by volume?
Q6. Which is the longest river in peninsular India?
Here is the list of the top 10 longest rivers in India in terms of length.
Total Length (km)
1. Ganga 2525
2. Godavari 14654
3. Krishna 1400
4. Yamuna 1376
5. Narmada 1312
6. Indus 3180 (1114 in India)
7. Brahmaputra 2900 (916 in India)
8. Mahanadi 890
9. Kaveri 800
10. Tapti 724
1. Ganga Gangotri Glacier Uttarakhand
2. Godavari Triambakeshwar Maharashtra
3. Krishna Mahabaleshwar Maharashtra
4. Yamuna Yamunotri glacier Uttarakhand
5. Narmada Amarkantak Plateau Madhya Pradesh
6. Indus Mansarovar Lake Tibet (China)
7. Brahmaputra Angsi Glacier Tibet (China)
8. Mahanadi Dandakaranya Chhattisgarh
9. Kaveri Brahmagiri Hill Karnataka
10. Tapti Betul district (Satpura Range) Madhya Pradesh
The tributaries of the major rivers are highly important for almost all competitive exams. Often the tributary of a particular river is asked in competitive exams like SSC and Railway exams.
Tributaries (left Bank)
Tributaries (Right Bank)
1. Ganga Koshi
Burhi Gandak
Ghaghara
Mahananda
Ramganga Yamuna
Falgu
Punpun
2. Godavari Banganga
Purna
Pranahita
Indravati
Sabari Pravara
Sindphana
Manjira
Manair
Kinnerasani
3. Krishna Bhima
Dindi
Munneru Niranjna
Koyna
Panchganga
Dudhaganga
Ghataprabha
Malaprabha
Tungabhadra
4. Yamuna
Hindon
Hanuman Ganga
Sasur Khaderi Tons
Chambal
Betwa
5. Narmada Tawa
Kharmer
Temur
Shakkar Uri
Hathni
Orsang
Hiran
6. Indus Zanskar
Soan
Sutlej Shyok
Gomal
7. Brahmaputra Lhasa Nyang
Parlung Zangbo
Dhansiri Kameng
Beki
Raidak
Jaldhaka
Teesta
Subansiri
8. Mahanadi Seonath
Hasdeo Ong
Jonk
Telen
9. Kaveri Harangi
Hemavati
Shimsha
Arkavathy Lakshmana Tirtha
Kabini
10. Tapti Girna …….
• Total length of the river Ganga is 2525 km.
• It is the most sacred river in India to Hindu beliefs.
• It is a transboundary river of Asia that flows through India and Bangladesh.
• The Ganges is India's largest and longest river, followed by Godavari (1465 Kms).
• The river Ganga originated from the Gangotri Glacier, located in Uttarakhand, and starts at the confluence of the Bhagirathi and Alaknanda rivers in Devprayag.
•The river flows through Uttarakhand, Uttar Pradesh, Bihar, and West Bengal.
• In West Bengal at dhulian Murshidabad, It entered Bangladesh and finally converged in the Bay of Bengal.
• In Bangladesh, the river Ganga is known as the Padma river.
• Major left bank tributaries of Ganga are Koshi, Burhi Gandak, Garra, Gomti, Ghaghara, Gandak, Mahananda and Ramganga.
• Major right bank tributaries of Ganga are Yamuna, Sone, Ajay, Tamsa (also called Tons), Karamnasa, Falgu, Kiul, Punpun, Chandan, Damodar, and Rupnarayan.
• Some of the prime cities on the banks of Ganga are Patna, Bhagalpur, Munger, Jamalpur, Hajipur, Kanpur, Varanasi, Haridwar, and Rishikesh.
Also, see the List of the Indian cities on the river banks
• Total length of Godavari River is 1464 km.
• In terms of length covered within India, the Godavari is the second longest river in India.
• Godavari river is also known as Dakshin Ganga or South Ganges.
• The river originated from the Triambakeshwar, Nasik in Maharashtra and traverses via Chhattisgarh, Telangana, and Andhra Pradesh, after which it finally meets with the Bay of Bengal.
• The major left bank tributaries of the river include the Purna, Pranhita, Indravati, and Sabari Rivers.
• Some of the prime cities on the banks of Godavari are Nashik, Nanded, and Rajahmundry.
• The total length of the Krishna river is 1400 km.
• The river Krishna is the third-longest river in India in terms of length.
• It works as one of the prominent sources of Maharashtra, Karnataka, Telangana, and the state of Andhra Pradesh.
• After originating from Mahabaleshwar the river enters the Bay of Bengal after flowing through Maharashtra, Karnataka, Telangana, and Andhra Pradesh.
• Some of the major tributaries of the Krishna river are Bhima, Panchganga, udhaganga, Ghataprabha, and Tungabhadra.
• Major cities on the bank of river Krishna are Sangli and Vijayawada.
• The Total length of the river Yamuna is 1376 km.
• The Yamuna, also called Jamuna, originated from the Yamunotri glacier at the Banderpoonch peak in the Uttarkashi district of Uttarakhand.
• The Yamuna is the longest right bank tributary of the River Ganga.
• Hindon, Hanuman Ganga, and Sasur Khaderi are the major left bank tributaries of Yamuna.
• Major right bank tributaries of Yamuna are Tons, Giri, Baghain, Chambal, Betwa, Sindh, and Ken.
• River Tons is the longest tributary of the Yamuna river.
• The central states through which the river flows are Uttarakhand, Himachal Pradesh, Delhi, Haryana, and Uttar Pradesh.
• The Total length of the Narmada river is 1312 km.
• The Narmada River originated from the Amarkantak Plateau in Anuppur district Madhya Pradesh.
• The river is also known as Rewa and previously known as Nerbudda.
• Due to its massive contribution to the state of Madhya Pradesh and Gujarat, It is known as the "Life Line of Madhya Pradesh and Gujarat"
Also, see Nicknames of Indian Rivers
• In contrast with all the rivers of the country that flow in the east direction, it flows westward.
• It is also considered one of the holy water bodies. To Hindus, the Narmada is one of the seven heavenly waterways of India; the other six are Ganges, Yamuna, Godavari, Saraswati, Sindhu, and Kaveri.
Longest River in India 2022
• The total length of the Sindh River is 3180 km. It covers 1,114 kilometers in India.
• The river originated from the Mansarovar Lake, and after crossing Ladakh, Gilgit, and Baltistan, it entered Pakistan.
• One of the oldest civilizations, the Indus Valley civilization, flourished on the banks of the Indus River and its tributaries.
• Major left-bank tributaries of the Indus river include Zanskar, Suru, Soan, Jhelum, Chenab, Ravi, Beas, Sutlej, and Panjnad.
• Major Right bank tributaries of the Indus river include Shyok, Hunza, Gilgit, Swat, Kunar, Kabul, Kurram, Gomal, and Zhob River.
• Leh and Skardu are the major cities located on the bank of the river Indus.
• The total length of the Brahmaputra River is 2900 km.
• Its total length within India is only 916 kilometers.
• It is the sole river in India whose gender is considered male.
• Source of the river is Angsi Glacier near Mansarovar Lake, Tibet, China.
• After the Indus river, It is the second river that originates from the Mansarovar ranges.
• In Tibet (autonomous region of China), it is called the Yarlung Tsangpo River. The river enters India via Arunachal Pradesh, then traverses through Assam, and finally enters Bangladesh.
• During the rainstorm season (June–October), floods are exceptionally usual.
• The Kaziranga National Park is located on the banks of the Brahmaputra river.
• World's largest river Island "Majuli or Majoli," is located on the river Brahmaputra, Assam. In 2016 it became the first island to be made a district in India. Majuli Island is spread over an area of 880 square kilometers.
• The total length of the Mahanadi river is 890 km.
• The Mahanadi River originates in the Raipur district of Chhattisgarh.
• The river flows through the states of Chhattisgarh and Odisha and finally falls into the Bay of Bengal.
• The Mahanadi river was known as 'the sorrow of Odisha'.
• Its major left bank tributaries are Seonath, Mand, Ib, and Hasdeo.
• Its major right-bank tributaries are Ong, parry, Jonk, and Telen.
• World's longest earthen dam, Hirakud dam built across the river.
• The total length of the Kaveri river is 800 km.
• Kaveri River, also spelled Cauvery, is a sacred river of southern India.
• It rises in Brahmagiri Hill of the Western Ghats in Karnataka and flows through the states of Karnataka and Tamil Nadu, and finally fas into the Bay of Bengal.
• In Tamil Nadu, the river breaks into many distributaries forming a vast delta called the "garden of southern India."
• Some of the major irrigation projects on the Kaveri river are Parambikulam Aliyar, Amaravathy Medium, Arkavathi Medium, and Badanavalu Medium.
• The total Length of the river Tapti or Tapi is 724 km.
• Tapti River is one of the only three rivers in Peninsular India that runs from east to west.
• The river is named after the goddess Tapati, the daughter of Surya, the Sun-god, and Chhaya.
• It rises in the Betul district (Satpura Range), Madhya Pradesh, and drains off into the Gulf of Khambhat (Arabian Sea).
• The river flows through the states of Maharashtra, Gujarat, and Madhya Pradesh.
Ans. The Ganges River is the longest river in India. The total length of the river is 2525KM.
Ans. In India, there are three major transboundary rivers: the Ganges, the Brahmaputra, and the Indus.
Ans. Godavari River, the total length of the Godavari River is 1465 km.
Ans. The Godavari is the longest river in South India. The total length of the Godavari River is 1465 km.
Ans. The Brahmaputra is the volume-wise largest river in India. The total length of the Brahmaputra River is 2900 km. Its total length within India is only 916 kilometers.
Ans. The Godavari is the longest river in South India with a length of 1465 km.
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Categories Indian Geography Tags Ganga, Longest river, Top 10 longest river
[PDF] Number of Players in Sports and Games
Important Mountain Passes in India UPSC notes

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text:
Blogs de l'ICANN
Lisez les blogs de l'ICANN pour vous tenir au courant des dernières activités d'élaboration de politiques, des événements régionaux et bien plus encore.
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Case 13-00098
In a matter of a Complaint by Garth Bruen and others
Report dated 28 October 2013
This investigation began initially as a complaint from Garth Bruen, but has been expanded by a collective approach from at least 173 other complainants, coordinated by Garth Bruen. The complaints are essentially an attack on the way in which the Compliance Department of ICANN operates, and seek a full investigation into the performance of Compliance. I should add that one complainant objected to the word "attack" and asked that this be removed, because he did not want to use such a term. He is of course anonymous, but I record that at least he did feel this was a constructive criticism. The complainants allege that Compliance is not being run properly and that this has resulted in registrars not be held to the terms of the Registrars Accreditation Agreement, which they then allege causes or permits spam and phishing and rogue domain holders to operate freely.
At the heart of the issue is a complaint formulated by Mr. Bruen which was shared with a number of groups resulting in a large number of filings of complaints on the same issues. These have come from a number of places, and I cite some of the wording from various sites and from the complaints. The extracts illustrate the difficulty in resolving matters which are factual, from rhetorical statements of position.
Linkedin complaints
"1. The records for the domains were forged
2. We used the official process for reporting them
3. The registrar did not enforce
4. The domain remained online
5. ICANN did not enforce the contract
5. ICANN refused to explain why
6. Employees who asked about it were fired
7. The public trust is broken"
"What do we want out of this? Not just an investigation, we want results and improvement. To be clear, we want a public accounting of what happened to your complaints and why certain employees were fired or retaliated against. However, on a grander scale we want a system which actually addresses the problems plaguing the Internet. Despite claims that "ICANN does not have any power to prevent unsolicited email" they actually have the power to cut down on significant amounts abuse by properly enforcing the contract and collecting statistics on abusive – things which they have refused to do so far."
A typical extract says
"The domains cited were registered with false WHOIS which violates the registrant agreement and used in abuse directed at me. While proper complaints were filed and the domains remained in violation ICANN did not issue enforcement actions against the cited registrars"
And more-
"I am requesting a full and open investigation of the handling of the listed complaints by ICANN staff to be conducted by an impartial outside party. This review should also include a review of the way ICANN handled staff involved in the investigation of the complaints as I have heard reports of intimidation and unfair treatment. As a continuous recipient of Internet abuse I would like to see a compliance system put in place which is truly transparent and accountable. Part of this should be 1) a simple, user-friendly process which accepts abuse reports from the Internet user at-large without the expectation that those users will understand the complexities of ICANN policy, 2) an ongoing analysis of abuses of the Domain Name System and their impact regardless of direct contractual authority of ICANN in those abuses, 3) a quarterly review of compliance activities to be conducted by non-contracted members of the Internet community, and 4) a proactive plan to reduce abuses of the Domain Name System through effective use of ICANN policy."
And more recently from a blog at CircleID by Garth Bruen at http://www.circleid.com/posts/20130924_icann_and_your_internet_abuse/
"KnujOn has published a report which demonstrates that ICANN Compliance appears to completely collapse between September 2012 and December 2012. Following December 2012, ICANN seems to stop responding to or processing any complaints. It is around this time certain compliance employees start disappearing. This was not limited to the Sydney office as some would have us believe, all while we have been given assurances the compliance team was being ramped up not down. The accepted budget has 20 Compliance staffers listed but in reality there are only 14 employees with another ubiquitous staff member vanished from the roster. Six phantom employees is a lot."
"The focus of my complaint is not that spam is being sent subsequent to legitimate information being provided in WHOIS details, but instead that where false information has been provided, there are many examples of where nothing has been done about it when highlighted in complaints. It is simply not good enough for compliance to start flapping a broken wing at us by declaring they cannot control spam. We are not asking them to. We are simply asking them to carry out the work they have been hired to do. Most of us accept that registrars have no control over spam; that is a no-brainer. The complaint from my perspective has always been about a failure by those responsible for compliance to execute their duties effectively when complaints of non-compliance are made. It is also about what I perceive to be the arbitrary, ineffective, and arrogant manner in which they have handled some documented complaints of non-compliance.
I find it puzzling that ICANN execs appear to feel that they have a right to decide what parts of their jobs they do and do not execute. It further appears to me that, like many administrators who either cannot or will not solve the problems they should be solving, ICANN execs have begun to invent new problems they assert demand their attention more, as they appear to think this justifies them not carrying out the matters being raised in this complaint. Whenever executives start telling us that we need to "move on" and look to the "new challenges" facing an industry, I am always suspicious about what is not being done that should be done."
As well as the material given to me by the complainants, to enable me to get a balance of the position, I have also been provided with material from Compliance, and of course read material accessible on the ICANN website. See this site for example at http://www.icann.org/en/resources/compliance. It is important to note some substantial changes which have been introduced over the relevant period of this complaint and I quote as follows.
"ICANN Contractual Complaince Audit Program
On Monday, 26 November 2012, ICANN launched the Contractual Compliance Audit Program. This program will run on a three-year cycle during which each registry and registrar agreement will be randomly selected for audit. Contractual Compliance, working with KPMG as the contracted vendor, issued 323 Requests for Information (RFI) via email and fax to 317 Registrars and 6 TLDs. This is a major effort for ICANN and for contractual compliance as we seek to validate the contractual obligations per the RAA and Registry Agreement. More information can be found at https://www.icann.org/en/resources/compliance/audits. Contractual Compliance has released the first phase of the new consolidated complaint management system. The phased rollout improves both the user experience and the compliance operations by:
– Moving complaint submission from Internic.net to ICANN.ORG under Compliance
– Adding site navigation based on complaint types and FAQs
– Improving email correspondence to the complaint reporter and the Registrar/Registry
– Adding a follow-up Continuous Improvement Pulse Survey for the reporter and contracted parties
– Whois Inaccuracy is the first complaint type to migrate to the new application
– 1st step in consolidating the three complaint tools and different email complaints into one source"
There have also been very substantial changes in the way in which the website describes the compliance function, and new compliance complaint entry pages.
I am unsure whether the complainants have read the relevant pages on the Compliance pages of the ICANN site. The Compliance Operating plan for example, at http://www.icann.org/en/resources/compliance/operating-plan has a number of bullet points which are relevant in the questions raised by the complainants. The first which says "work constructively with registrars and registries to foster a culture of compliance", has a philosophy of working with people to ensure compliance goals are met. While the plan does prioritise informal resolution if possible, it does state that non-compliance will be pursued aggressively. It is also relevant in this context to look at the audit program, which is on this page http://www.icann.org/en/resources/compliance/audits and which describes how Compliance are using a three-year audit cycle, with a goal of enabling ICANN to first identify and frame and then properly manage and help remediate deficiencies.
In these specific areas which have attracted most of the attention from Compliance critics, the pages contain detailed information about WHOIS complaints and enable users to lodge a ticket using a number of different complaint forms for various problems.
This is a matter where I clearly have jurisdiction because it falls under the issue of delay or unfairness within ICANN.
However I should also mention a specific concern about the late lodging of the complaint. I acknowledge that the initial complaint from Garth Bruen came in to my office in March 2013. But the specific matters he complains about occurred in 2012. The subsequent complaints, which are in reality the same issues, have come in over a period of time from early August to mid September 2013. It is not a strict pre-requisite or procedural requirement but the Ombudsman Framework adopted in 2009 does state that normally complaints will not be accepted for matters older than 60 days. The reason for such a time limit is the speed with which matters typically progress at ICANN.
In the balance, if there are over 173 people who have gone to the trouble of making a complaint, even if the issues are based on events from 2012, it would be wrong not to carefully consider what they have submitted.
To undertake this investigation I have read a considerable amount of material sourced from Compliance, all of which is available to the public, on this section of the ICANN website at http://www.icann.org/en/resources/compliance/reports and at http://www.icann.org/en/resources/compliance/operating-plan. In particular I have read the presentations from Compliance presented from ICANN 42 at Dakar to ICANN 47 at Durban. I have also read the attachments which have been provided by the individual complainants, and their emails. A number of the complainants went to some trouble to explain that their own experience was unique and I acknowledge that their interaction with spamming and phishing does of course differ. In the course of this investigation I have had the opportunity to discuss this matter with a number of members of the Compliance team, and also with some registrars so that I could get a perspective of the relationship between registrars and Compliance. The individual complainants are of course only one part of the picture. The relationship between registrars and Compliance is also significant and important in discussing the allegations which have been made. During my discussions with the registrars I was told that complaints had been made about domains which they administered, but which had no validity at all. I have seen such a complaint provided by one of the registrars by Knujon, which makes it clear that the information is not only inaccurate but out of date.
It is a theme of the complaints in fact, that the information is largely out of date. Virtually all of it goes back to 2012.
It is critical in understanding this complaint to outline the role of the Registrars Accreditation Agreement in the various editions. This agreement is at the very core of the function ICANN was created to administer. ICANN established market competition for generic domain name registrations, and did so by adopting policy and then developing specific contracts with the registrars which have been refined to the most recent 2013 edition, which is gradually extending to all registrars. Such contracts have been developed through a vigorous policy development process and considerable debate and negotiation between ICANN and the registrars. Registrars must maintain a registration agreement which must include certain terms in Section 3.7.7 of the RAA and related consensus policies (such as the UDRP). It is important to understand the role of Compliance in the administration of the contracts. This is expressed on the ICANN website as "The overall goal of the Contractual Compliance Program is to ensure that ICANN's contracted parties fulfill the requirements set forth in their agreements with ICANN." For the purpose of this complaint it is therefore critical to understand where the obligations as alleged by the complainants are set out in the agreement. Because the complaints are historical, it is not necessary to consider the new 2013 version. However the Compliance Program is set out in full at this site http://www.icann.org/en/resources/compliance/registrar
A common theme through the complaints and from the original complaint relates to the WHOIS obligation, and the role of Compliance in ensuring that accredited registrars comply with their obligations. The complainants say that the failure to rigorously enforce the obligations has permitted spam and phishing, and made it difficult to enforce removal of such sites because the WHOIS information is not up-to-date. Garth Bruen goes to some pains to explain the commercial services which his company provides which are designed to cope with spam, phishing and other dubious sites.
Spam and website content have always been outside of the scope and authority of ICANN. After all, every ICANN staff member is issued with appropriate software to deal with spam and phishing and blocking inappropriate emails. If it were possible to control such problems, then obviously ICANN is as interested as any other Internet user in reducing the time wasted. ICANN cannot do anything about website content or spam, as it is outside of the RAA. However I was also told by Compliance that Internet users often make Whois inaccuracy complaints about spam domains without any evidence. There is a section of the RAA that states that registrars must abide by applicable laws, but ICANN practice is to interpret this to mean a final judgment from a court of competent jurisdiction rather than allegations. Because laws vary by country, so does "what is illegal".
So the real issue in this complaint is whether any alleged failure on the part of Compliance to enforce the terms of the Registrars Accreditation Agreement has contributed to the complainants getting unwanted spam and phishing and other unwanted email. None of the complaints on this issue refer to any attempt to use the ticketing system which has an elaborate multi-language set of options for lodging complaints about WHOIS accuracy. In addition, I have seen discussions, emails and memoranda which refer to the way in which bulk complaints are handled. Compliance has explained to me that the system for dealing with bulk complaints has been revamped and improved, and comments have been sought. There certainly has been some discussion, but I have not seen any criticism of the improved systems, which in my view appears to coincide with the very substantial improvements introduced in 2012/2013.
I have had discussions with various registrars, from small to large. They were very willing to discuss their relationship with Compliance, and several were frank about the fact that they have quite an active relationship. The larger registrars in particular must deal with substantial numbers of compliance issues, and typically have a team of people who deal with Compliance, as well as law enforcement and other aspects. A common theme of the discussions is that compliance has matured over the last few years, the process is getting better and communication has improved. They mentioned that there are often quite vigorous discussions and debates, not just about specific issues but also about policy. One registrar commented that compliance is a very specific process, and Compliance must comply with policy. If there are complaints about policy as to Compliance, then this is a matter for a PDP process because otherwise they are outside the remit of Compliance.
Another comment was that it is in the registrars' best interests to have compliance working efficiently, because the registrar business model relies upon the compliance complaint program.
I also mention one registrar in particular which has been openly criticised, being Bizcn.com. As part of the monitoring by Compliance, scorecards of requests are kept. Compliance informed me that Bizcn.com is a registrar that is prompt & cooperative with Compliance inquiries, including Whois inaccuracy complaints. I was shown the scorecard, of all complaints since January 2013, which shows that all were resolved before a 3rd notice was needed.
The age of the complaints means that the transition from the previous Registrars Accreditation Agreement to the new 2013 version has largely overtaken the issues raised by the complainants. The principal complainant and the supporters in the group have not discussed the effect of these changes at all. There is no doubt that spam and phishing are an ongoing problem. However my investigations and discussions with compliance and with the registrars make it plain that there is an active and ongoing program to ensure that the old and new Registrars Accreditation Agreements are adhered to.
However it is important to note the new Whois requirements in the 2013 RAA, the new agreement says that for the Whois Accuracy Program Specification, registrar must within 15 days:
Validate the information identified in section 1 (e.g. Email, phone, postal address) Verify the email address or phone number (by calling or sending SMS) If verification fails, the registrar can verify manually or suspend the domain. This is mandatory, and must also occur when the information is changed
It is worth noting that in the Whois Accuracy Specification that for willful provision of inaccurate Whois information, the registrar must suspend or terminate a domain for failure to update or respond to inquiries within 15 days.
Registration Data Directory Service (Whois) Specification: registrars must include an abuse email and telephone number in the Whois output Whois Accuracy Spec and Whois Spec are effective 1 January 2014 for registrars that are on the 2013 RAA.
Part of the problem with the complaint is that it does not correctly identify the test which applied for the older version. The complainant has asserted that the registrant must provide verifiable information. In fact the agreement provides for reliable information, which is substantially different. The RAA says at 3.7.7.1
"The Registered Name Holder shall provide to Registrar accurate and reliable contact details and promptly correct and update them during the term of the Registered Name registration, including: the full name, postal address, e-mail address, voice telephone number, and fax number if available of the Registered Name Holder; name of authorized person for contact purposes in the case of an Registered Name Holder that is an organization, association, or corporation; and the data elements listed in Subsections 3.3.1.2, 3.3.1.7 and 3.3.1.8."
This is not the same as verifiable.
The complainants also assert that the registrar must enforce registrant violations. But again the test is in fact that the registrar must take reasonable steps to investigate and correct incorrect information. This is significant because there is a substantial change brought in under the new agreement, where there is a 15 day takedown period. So the problem is that the complainants have overstated the duties of the registrar, the registrant and the role of compliance in this matrix. But in any event the new agreement effectively resolves many of these issues. The older agreement in fact refers to this in RAA 3.7.8 providing that:
"Registrar shall, upon notification by any person of an inaccuracy in the contact information associated with a Registered Name sponsored by Registrar, take reasonable steps to investigate that claimed inaccuracy. In the event Registrar learns of inaccurate contact information associated with a Registered Name it sponsors, it shall take reasonable steps to correct that inaccuracy."
It is important to remember that these policies were developed by ICANN Consensus Policy, with extensive negotiation between the affected parties. One of the features of a consensus policy is that it may not satisfy every party, but in this case, the complainants had not correctly identified the test which applies. They may prefer to have a more difficult standard, and the 2013 agreement certainly reflects the policy development of stricter standards. But at the relevant time is of this complaint, the earlier agreement was in force and applied to the obligations of the registrar and registrant.
I was requested to look at a number of specific issues, including a list of "bad registrars" which was given to compliance at the Prague meeting. There were five registrars identified, but I am told that these registrars have all been most cooperative with compliance. One of them did have some issues which have been resolved with the assistance of compliance. There was full cooperation I am told.
This was done because someone commented "everyone knows who the bad registrars are," but it was not clear to Compliance staff who the persons present were identifying. Some of the reasons why registrars were classified as "bad" were outside of the scope of the RAA (e.g. Spam, malware, cybersquatting havens). One registrar identified on the "bad registrar" list was under Compliance review prior to the Prague meeting. The registrar was found to be compliant with the RAA, but later independently made changes to its terms and conditions regarding "pharma" domains.
The complainant's issue is that Compliance is not doing its job. This requires however a leap in their argument from the role of Compliance within ICANN, through to the ability to deal with the spam and phishing issue, which is mentioned by many of the complainants. This regrettably is a fundamental misunderstanding of the role of Compliance within ICANN.
A number of other aspects to the complaints also need to be answered. Many of the complainants referred to the number of staff at Compliance being inadequate, although it seems on my investigation that this was based on staff numbers in a draft budget. Draft budgets are not always what results once the final decisions are made. In the case of compliance this was the case, although it is also worth noting that compliance teams are being established at Istanbul and Singapore to extend global coverage. There has also been a criticism that staff members were fired for raising issues of inadequate compliance action, but on my investigation I have found that the staff members who actually did the work are still at ICANN. I am confident from my investigation that this allegation is unsubstantiated.
As a result of this investigation, I consider that there is no substance to the complaints.
Chris LaHatte
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