18(c) What operating rules will you adopt to eliminate or minimize social costs?
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18.3.1 What operating rules will you adopt to eliminate or minimize social costs (e.g., time or financial resource costs, as well as various types of consumer vulnerabilities)?
CUNA LLC’s proposed operating rules that implement the aforementioned policies, e.g. Registrant Eligibility, Name Selection Criteria, and Acceptable Use, are an important corner stone to minimize potential negative social costs. These policies and the corresponding administrative review process will limit registrations and provide registrants and the consumers that use their services a more trusted online environment. This approach should by default minimize social costs. This ecosystem provides consumers with a trusted source for reliable business content with a substantially lower risk of fraud and⁄or scams.
18.3.2 What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?
CUNA LLC believes that the proposed operation of the .CREDITUNION gTLD as set forth in this application has no known negative consequences or cost implications on consumers. To the contrary, the proposed operation of this registry likely will lead to direct and quantifiable benefits to consumers. CUNA LLC believes that by following the core CUNA Inc. values as identified on its website (http:⁄⁄www.cuna.org⁄cuna⁄vision_mission_goals.html), it will be able to provide real value to its members and consumers generally and minimize any potential negative consequences⁄costs.
18.3.3 How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first-serve basis?
CUNA LLC does not envision multiple applicants for the same domain name, as domain names will only be allocated to credit union sector members and entities having a meaningful nexus with the credit union sector. If there is a potential contention set for a domain name, CUNA LLC will look to industry established phased equitable allocation mechanisms (e.g. RFP, auction, first-come first-serve) and as identified in Question 23.
18.3.4 Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).
CUNA LLC does not envision any initial pricing advantages, introductory discounts, bulk registration discounts because these marketing⁄commercial initiatives are inconsistent with the mission and purpose of the .CREDITUNION gTLD as a trusted online source identifier. Moreover, since CUNA Inc. and credit unions are not-for-profit entities, CUNA LLC anticipates the .CREDITUNION gTLD will be offered to eligible entities at a reasonable and competitive rate.
18.3.5 Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.
CUNA LLC is committed to providing the domain name registration periods set forth in the registry agreement. However, as noted above, as an industry-based gTLD, the registration and use of the domain name is conditioned upon the registrant being an eligible entity within the credit union sector or an entity having a meaningful nexus with the credit union sector. Because of CUNA Inc.’s clear mission statement of helping credit unions, together with CUNA LLC and CUNA Inc.’s status as non-profits, CUNA LLC is not driven by profit but by providing a quality service to the credit union community.
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