18(b) How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

Prototypical answer:

18.2 How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

CUNA LLC believes that the proposed .CREDITUNION gTLD has the potential to offer the following benefits to Internet users and consumers:

• A trusted online information source for the credit union sector seeking to access information and services online related to credit unions;
• Provide short and memorable domain names that will ease locating credit union information online;Minimize potential incidents of phishing and malware often associated with mistypes of domain names in the .COM space;
• Incorporate enhanced intellectual property rights (IPR) protection mechanisms. As set forth in the Applicant Guidebook;
• Include a post-registration reporting mechanism to take down non bona fide registrations.

Currently CUNA Inc., its members, and other entities in the credit union sector operate many websites using a combination of second-level and top-level domain names. A representative sampling of websites for credit union members of CUNA and their corresponding domain names is listed below.

CUNA Inc. believes that a .CREDITUNION gTLD can provide an online single source identifying function for its current and future members and credit union members in the United States and globally.

18.2.1 What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?

The primary mission and purpose of the .CREDITUNION gTLD is to provide a trusted, hierarchical, and intuitive online information source for information, products, and services associated with the credit union sector. As technologies for delivering financial services evolve, CUNA LLC will continue to evaluate opportunities to distribute information, products, and services to current and future credit union sector entities. CUNA LLC believes that a .CREDITUNION gTLD has the potential to provide a virtual platform to offer interactive features to deepen and broaden its relationship with its existing and future member credit unions, member Leagues, and other entities in the sector, as well as with individual credit union member-owners.

The .CREDITUNION gTLD has the potential to play a key strategic role in CUNA Inc.’s work to advance its actions and its overall mission. CUNA Inc. is dedicated to accomplishing the following core actions in furthering its mission of supporting, protecting, unifying, and advancing the credit union movement:

• Consistently and accurately anticipating the needs of its members;
• Providing leadership, advocacy, and services that positively energize the credit union sector
• Being recognized by its members and other important audiences as the definitive source of information and perspective on issues and trends affecting the movement;
• Systematically collecting data on its members’ needs, measuring its members’ satisfaction and its success, and striving to continuously improve its effectiveness;
• Developing and maintaining an efficient and effective infrastructure that encompasses human, financial, and technological resources; and
• Being recognized as the definitive voice of credit unions before the government of the United States.

See http:⁄⁄www.cuna.org⁄cuna⁄vision_mission_goals.html


18.2.2 What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

As an industry gTLD, the primary driving factors behind creating a .CREDITUNION gTLD are providing a safe and secure online information source for the credit union sector. The success of the gTLD will not be measured by the number of domain names registered. Instead, it will be measured by the level of consumer recognition and trust that is placed in .CREDITUNION gTLD. Using this benchmark, CUNA LLC strives to build consumer recognition and trust rising to the level of that found in the .COOP and .ORG top-level domain names. As noted above, CUNA Inc. is the premier national trade association serving America’s credit unions, and is increasingly reliant upon emerging technologies to deliver its message and services to its members and the credit union sector generally. A .CREDITUNION gTLD has the potential to serve as a cornerstone of this online strategy, if the potential benefits that ICANN experts have touted become a reality.

While many users of financial institutions are subject to a never-ending barrage of spam and phishing activities due to the common use of traditional gTLD names, .the CREDITUNION extension will, become a trusted source of goods and services for individuals looking for information regarding products and services within the credit union sector.

All domain names registered within the .CREDITUNION gTLD will be required to comply with the following three policies: Registrant Eligibility (who can register within the .CREDITUNION gTLD); Name Selection Criteria (what domain names can be registered); and Authorized Usage Policy (how the domain names can be used). Each of these policies are described below in more detail and throughout the remainder of the application.

18.2.3 What goals does your proposed gTLD have in terms of user experience?

CUNA LLC believes that the .CREDITUNION gTLD will provide a single trusted source of information and education for the 180 million credit union members both domestically and internationally, as well as the tens of thousands of credit unions worldwide. In addition to providing consumers with short, memorable, and intuitive domain names to help consumers navigate the .CREDITUNION namespace, CUNA LLC envisions using the gTLD to test and develop best in class safeguards to minimize any potential phishing, pharming, or spam that have plagued customers of other financial institutions.

As identified in Section 18.1.2, CUNA LLC’s mid-term goal is, in consultation with those members with a nexus to credit union sector, to evaluate potential strategies to integrate with and⁄or migrate traffic from its existing group of domain names, which are currently registered across multiple TLDs, to a single online source under the .CREDITUNION gTLD. This will provide individuals with a single online trusted source for information, products, and services within the credit union sector. This will also provide increased confidence and predictability for credit unions and their members as the gTLD achieves greater use and sector awareness.

18.2.4 Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.

CUNA Inc. is committed to promoting a safe eco-system for the credit union sector by providing best in class safeguards that will evolve over time, continuing to incorporate additional security and other safeguards as necessary. In addition to implementing all of ICANN’s consensus policies and other Rights Protection Mechanisms (RPMs) identified in the Applicant Guidebook, CUNA LLC intends to provide the following registration policies in support of its goals:
1) REGISTRANT ELIGIBILITY POLICY. CUNA LLC will develop and publicly post on its website a charter providing a description of and the types of organizations that have a nexus with the credit union sector. Only those individuals and organizations meeting these criteria will be permitted to register a domain name in .CREDITUNION. To facilitate this timely validation, CUNA LLC is evaluating either conducting this validation internally; outsourcing it to a third party (i.e. Choicepoint as the original case of .TRAVEL); or automatically permitting registration based upon an individual’s or organization’s membership in an association. CUNA LLC is still reviewing the pros and cons of each of these options and has yet made an exact decision on the best validation process.
2) NAME SELECTION CRITERIA POLICY: CUNA LLC will initially require that third party registrants only register domain names that correspond with their business and⁄or trade name. This will minimize instances of phishing, malware, and cybersquatting in the .CREDITUNION gTLD registry.
While it is the full intention of CUNA LLC to make available for registration generic, geographic, and other domain name strings that do not correspond to a registrant’s business and⁄or trade name to potential registrants meeting the nexus requirements, CUNA LLC has not yet decided on a suitable equitable allocation process. In fact CUNA LLC may not finalize this decision until after developing and implementing its own hierarchical and intuitive framework as outlined above to gain additional market analysis.
3) ACCEPTABLE USE POLICY: CUNA LLC will set forth a list of prohibited activities in which registrants must refrain from. Failure to comply with these requirements subject the domain name registration to suspension and or cancellation. This acceptable use policy is set forth in further detail in the response to Question 30.
CUNA LLC is also proposing an enhanced Rights Protection Mechanism (RPM) that will allow trademark owners to challenge domain names initially reserved⁄allocated by the registry operator. This process will be modeled after the trademark challenge process adopted by dotAsia in connection with its Pioneering names process.
18.2.5 Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users? If so, please describe any such measures.
As the premier national trade association serving America’s credit unions, CUNA Inc. recognizes first hand that this is an evolving area of law in which there is no international standard. However, due to the fact that every domain name will be registered to an entity having a nexus with the credit union sector—the majority of which are direct members of CUNA Inc.—CUNA LLC has a vested interest in ensuring that accurate and current domain name information is readily available in connection with each .CREDITUNION domain name.

CUNA LLC will ensure that the operation of the .CREDITUNION gTLD will be consistent with CUNA Inc.’s Statement of Privacy Principles, available on its website at http:⁄⁄www.cuna.org⁄privacy.html.

In addition, CUNA LLC intends to incorporate contractual language in its Registry Registrar Agreement (RRA) modeled after language utilized by existing ICANN gTLD registry operators. Specifically, CUNA LLC shall notify Registrar of the purposes for which Personal Data submitted to Registry Operation by Registrar is collected, the intended recipients (or categories of recipients) of such Personal Data, and the mechanism for access to and correction of such Personal Data. Registry Operator shall take reasonable steps to protect Personal Data from loss, misuse, unauthorized disclosure, alteration, or destruction. Registry Operator shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars. Registry Operator may from time to time use the demographic data collected for statistical analysis, provided that this analysis will not disclose individual Personal Data and provided that such use is compatible with the notice provided to registrars regarding the purpose and procedures for such use.

18.2.6 Describe whether and in what ways outreach and communications will help to achieve your projected benefits.

As noted above, CUNA LLC’s driving factor in securing a .CREDITUNION gTLD in ICANN’s first round is primarily defensive in nature, and while CUNA LLC sees the potential for this gTLD to serve as a cornerstone for its future online strategic initiative, there are a number of unanswered questions concerning consumer recognition, security and stability, and broader industry adoption of new gTLDs within the marketplace that must be satisfactorily answered first. Once these concerns have been answered to CUNA LLC’s satisfaction, CUNA LLC is committed to making prominent use of the .CREDITUNION gTLD in printed and online material as well as across its member credit unions that serve 94.5 million members in the United States alone, and in the credit union sector generally. CUNA LLC plans, over the period of Stage One and Stage Two, to work with other prominent credit union sector entities in the United States and internationally to market the benefits of using the .CREDITUNION gTLD.

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