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

Prototypical answer:

The .insurance gTLD will serve as a trusted destination on the Internet for insurers, insurance services providers, consumers and Internet users. The .insurance gTLD will seek to reach insurance professionals, their employees and partners while modeling a template of trust for online commercial interactions. The pre-registration and screening conducted by FRS will serve the industry by allowing it to congregate under one umbrella gTLD. This presents consumers with clear choices in an environment that will encourage .insurance registrants to be innovative and provide maximum value to consumers in their online experience, while providing significant competition to existing gTLDs.

Additionally, the proposed .insurance gTLD will offer the following benefits:
- Provide a trusted online marketplace for consumers seeking to access insurance products and services;
- Provide FRS and its community members with memorable Internet addresses and improve navigation to products, services, advertising campaigns, public interest content, public awareness initiatives, etc.;
- Protect the namespace for the benefit of institutions, consumers and the overall insurance community;
- Provide a variety of high value-added services through its backend registry services provider; and
- Create an opportunity to design innovative online products and services for the insurance industry and its consumers.

18(b)(i) What is the goal of your proposed gTLD in terms of areas of specialty, service levels, of reputation?

FRS was founded by organizations that hold a leadership role in the U.S. insurance industry. FRS’ Board and Advisory Board will be composed of insurers and insurance associations and therefore it is uniquely situated to understand the needs and goals of registrants in the insurance industry. FRS’ goal is that there will be no confusion for Internet users when they encounter a .insurance website. Every .insurance registrant will be a legitimate member of the insurance community, committed to a trustworthy commercial transaction experience for its clients and consumers. Registrants will work with FRS and adhere to the strictest terms of service and security standards, generated specifically by the global financial services community for this undertaking.

18(b)(ii) What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

FRS’ primary driving factor is to provide a vetted and therefore, more secure online environment for businesses and consumers to interact with the insurance community. The success of the gTLD will not be measured by the number of registrants, but rather by the level of institutional and consumer recognition and trust placed in the .insurance gTLD. Using this benchmark, FRS will strive to build recognition and trust that rises to a level meeting or exceeding that found in the .edu and .gov gTLDs.

As noted above, FRS is committed to serving the insurance community as it increasingly relies upon emerging technologies to securely deliver information between institutions and about insurance products and services to its consumers. The .insurance gTLD has the potential to serve as the cornerstone of this type of online strategy for the industry. FRS seeks to become a trusted source for inter-institution exchanges and transactions and a platform for more secure, consumer-facing insurance activities, including the purchase of insurance products and services.

In addition to the education and outreach initiative discussed above, FRS is keen to continue its work with ICANN and the broader Internet community in promoting security controls within gTLDs that require enhanced security measures, such as financial gTLDs. Its most recent effort in this area was the creation of security requirements formally proposed to the ICANN Board in December 2011 by the joint ABA and BITS (the technology policy division of the Roundtable) Security Standards Working Group. Following its submission to ICANN, the requirements have since been referenced in question 30 of the Applicant Guidebook. FRS will contractually incorporate these requirements into both its Registry-Registrar Agreement (RRA) and the end Registrant Registration Agreement to ensure that it has the legal means to enforce these obligations.

The creation of the .insurance gTLD will provide the insurance community with opportunities to explore and create new products and services that support the community in addressing the Internet based issues and concerns referenced above. It will also provide the insurance community with a space to innovate, improve current insurance services, and address the increasing consumer demand for faster and more convenient transactions.

FRS plans for its operation of the .insurance gTLD to provide significant benefits to the larger Internet community in the following ways:

1. Trust
The .insurance gTLD will allow the Internet user, before he or she even clicks on a search engine result, to know that the site belongs to a trusted member of the insurance community.

Among the results that would arise in a typical search of existing gTLDs are fraudulent businesses that intend to put Internet users, especially consumers and their personally identifiable information, including, but not limited to, financial data, at serious risk. Often, these rogue online operators register domains that look similar to legitimate domains to intentionally mislead users, resulting in increased costs to the industry and consumers. FRS’ ultimate goal on behalf of the industry is that the .insurance gTLD will reduce the efficacy of such attacks, as users on a bona fide .insurance site would know that their information was safe with a vetted insurance provider.

2. Ease of search
As the amount of information available online continues to grow, it will become increasingly more difficult for consumers to choose which websites to visit for their desired insurance services and products. However, consumers will know that Internet search results listing websites ending in .insurance belong to legitimate members of the insurance community. Will a typical Internet search produce legitimate insurance providers via the Internet? Yes. But, will the individual performing the search have the tools at hand to determine which of the results are trustworthy and legitimate? Not necessarily, but with .insurance they will.

3. Vetting and Oversight
The reason Internet users will be able to trust a .insurance domain is because FRS will aggressively govern both the issuance and continued use of a second-level .insurance domain. More information on the vetting and oversight can be found in 18(b)(iv) below.

18(b)(iii) What goals does your proposed gTLD have in terms of user experience?

FRS will ensure that the .insurance gTLD will create an enhanced user experience both for registrants and Internet users. FRS’ goal is to operate the .insurance gTLD in a manner that instills trust and confidence in the domain names and websites associated with the gTLD. For users this means a small, specialized, highly controlled environment, free from much of the abusive behaviors found in existing gTLDs.

1. Registrants
The number of .insurance registrants will be relatively small. As such, registrants will receive higher levels of customer service than can reasonably be expected in existing gTLDs. Once granted a .insurance domain, registrants will benefit through the domain nameʹs positive brand identity and consumer trust. Likewise, .insurance’s reputation will benefit from the upstanding efforts of second-level domain operators seeking to maintain their registration status.

2. Internet users
As stated above in 18(b)(ii), the restricted and manageable size of the .insurance community will provide both a trusted and secure online experience. The controls managing the community will foster competition among registrants to compete on a user-experience basis for Internet users.

18(b)(iv) Provide a complete description of the applicantʹs intended registration policies in support of the goals listed above.

To ensure a trusted environment, FRS will restrict registrations to a select group and will limit the types of activities that may take place within the gTLD with a series of policies meant to prevent and address negative behavior. These policies include:

Registrations within the community may initially be made by the following for-profit and not-for-profit businesses, individuals or organizations:
- Licensed insurance companies regulated by a government entity
- Licensed insurance agents and brokers regulated by a government entity
- Associations whose members include licensed insurance companies, agents or brokers (if approved by the FRS Board)
- Organizations that are controlled by insurance companies (if approved by the FRS Board)
- Entities whose operations are dedicated to serving insurance companies (if approved by the FRS Board)
- Specialized organizations (e.g., research or risk coordination) (if approved by the FRS Board)

In working on behalf of the insurance industry, FRS understands its responsibilities to the industry. Because of the proposed insurance-service activities that will occur within the .insurance namespace, it is essential that registrations only be permitted by verified members of the insurance community. In addition to validating the eligibility of the registrant, the domain name to be registered must comply with appropriate name selection and use requirements.

To ensure strict compliance with these policies, FRS will develop and implement a Registrant Eligibility Evaluation Process. This process will require .insurance accredited registrars to collect registrant information that will be used by FRS, or its designated third party service provider, to validate that the registrant is a member of the insurance community. These requirements will be incorporated into FRS’ Registry-Registrar Agreement (RRA).

As part of the registration process, potential registrants must provide its registrar with the following information:
- Full legal name
- Business address
- Professional title of representative of the administrative contact of the potential applicant
- Business name
- Point of contact within the business who can verify their representation of the business
- Phone
- Email
- Another proof of identity, necessary to establish that the registrant is an eligible member of the appropriate .insurance gTLD community
- For insurance companies, the state regulatory authority issuing its charter
- For agents and brokers, the state licensing agency
- For organizations that are majority controlled by insurance companies (if approved by the FRS Board), list of and proof of its owner(s)
- For entities whose operations are principally dedicated to serving insurance companies (if approved by the FRS Board), corporate operating agreement or like document(s) as determined necessary to validate alignment with the goals of the community
- For specialized organizations (e.g., research or risk coordination) (if approved by the FRS Board), a copy of the corporate operating agreement if for-profit or the mission statement if non-profit (or like document(s) as determined necessary to validate alignment with the goals of the community)

Applicants who meet the eligibility requirements and have been validated as legitimate members of the community will then be able to register their domains in .insurance.

Domain names that pass the vetting process will enter a 5-day Add Grace Period (AGP), or Pending Create, before becoming valid. Applicants whose domain name fails the vetting process will be notified with reasons for denial and procedures for appeal. Any applicant who is rejected for either a non-eligibility criteria or use of domain evaluation can appeal the validator’s decision to FRS.

FRS will audit approved registrants and their strings to ensure compliance with all applicable eligibility and use requirements.

Domains initially registered in the .insurance gTLD must correspond to a trademark, trade name or other service mark owned by the registrant. Initially, all other registrations (e.g., geographic, generic, etc.) will not be allowed. FRS will reserve a set of generic domain names prior to launch. These reserved domain names will either be used by FRS in its capacity as Registry Operator for the management, operation and purpose of the gTLD, or they will be equitably allocated to members of the community. The subset of domain names reserved for FRS’ use is necessary to create a trusted, hierarchical, and intuitive framework for the .insurance namespace to facilitate the ease by which consumers can navigate the gTLD.

Although these reserved words will be commonly used words and phrases and⁄or geographic terms, FRS will provide an enhanced Rights Protection Mechanism that will provide trademark owners with an avenue to challenge the reservation and potential use of these domain names. This challenge process will be modeled after the highly successful dotAsia Pioneering Program.

18(b)(v) 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.

The .insurance gTLD will be governed by strict guidelines and policies regarding issues of privacy and the protection of confidential registrant information. The policies will be transparent and rigorous. Each level of the gTLD (registry, registrar and registry services provider) will have privacy and security policies in place to protect against unauthorized access to confidential information.

Privacy and security will be key elements of the .insurance Acceptable Use Policy (AUP), which will govern how a registrant may use its registered name. Draft AUP language specifically addresses privacy by noting that a registrant may not use a .insurance domain for any activity that ʺviolates the privacy or publicity rights of another member of the .insurance gTLD community or any other person or entity, or breaches any duty of confidentiality that you owe to another member of the .insurance gTLD community or any other person or entity.ʺ

Members of the .insurance gTLD community operate under the highest standards of privacy and protection of personally identifiable information and financial data. Such protection is an essential component of the insurance industry and a legal necessity for any Internet enterprise. State insurance regulators and the National Association of Insurance Commissioners support strong laws and regulations that protect the privacy of individual consumer information. Every state has adopted comprehensive privacy laws to protect the extensive personal information collected by insurers to underwrite and administer insurance policies. Insurance regulators also support efforts to mandate fair treatment and notification to consumers when their private information is improperly disclosed to third parties, especially where such unauthorized disclosures may result in identity theft. It is in the best interest of an insurance provider or affiliate to continue to provide maximum privacy protections for consumers, and this will continue to be their responsibility in operating a .insurance gTLD. FRS will implement the latest online technology (e.g., DNSSEC and multi-factor authentication) and services to help ensure the .insurance domain is synonymous with trust. These steps will align with actions instituted by .insurance registrants, working in lockstep with FRS. This is a manifestation of the larger goal of .insurance, that of a trusted source of safe online transactions, as stipulated in 18(a).

The protection of privacy and confidential data is of paramount importance, especially in an industry as highly regulated as insurance services. Not only will the registry have its own set of measures, but each individual institution or registrant will be required to remain compliant with existing laws and regulations in place regarding privacy and the protection of customer data. FRS will accomplish this, in part, through the inclusion of contractual language in its RRA that is modeled after similar language in Registry Agreements of existing ICANN gTLD registry operators. Specifically, some of this language will include the following:
- Registry Operator shall notify the 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.

The draft AUP informs registrants that FRS maintains ʺcomplete enforcement rights over registrant’s use of their .insurance domain name. If registrant violates this AUP, registrant will be subject to a rapid domain name compliance action, be in material breach of the Agreement, and along with all other rights and remedies under this Agreement with respect to such a breach, FRS reserves the right to revoke, suspend, terminate, cancel or otherwise modify registrant’s rights to the domain name.ʺ

On a regular basis, FRS will audit domain names, or require an attestation by second-level domain holders, registered in the .insurance gTLD space to ensure compliance with all eligibility and use criteria. If a violation is discovered, an investigation will begin immediately to rectify the violation. If an applicant chooses to appeal, FRS will review the appeal to determine if there is any material change to the action or activity. FRS will retain the right to assign the dispute to an ombudsman if necessary.

A more detailed discussion of FRS’ privacy policies, specifically steps to avoid unauthorized access to sensitive information, can be found in responses to question 30.

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

Outreach and communications with the insurance services community will be critical to the success of this project and has already begun over the past four years by FRS’ founding members. FRS’ founding members have discussed possible impacts to the industry with domestic insurance associations as well as ICANN’s Governmental Advisory Committee (GAC). Current conversations with and among insurance companies and members of the industry include ways to reach the insurance community and build an infrastructure that includes all members of the insurance services community. Ultimately, a communications strategy and plan will be implemented by FRS and its Board to guide its efforts. Advisory groups and committees will also be consulted to ensure continued alignment.

FRS and its Board will utilize all existing channels of communication to increase the awareness of the value and merit of the .insurance gTLD. Finally, the gTLD will be promoted by registrants themselves. Insurance providers will have an incentive to direct consumers to the .insurance sites they operate, and thus will promote their second-level domains containing .insurance throughout existing media channels.

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