.creditunion Pre-Register Domain - .creditunion Domain Information

18.1 Mission and Purpose of .Creditunion
The intention of CUNA Performance Resources, LLC (ʺCUNA LLCʺ) in filing this application is to provide a trusted, hierarchical, and intuitive namespace for entities that have a meaningful nexus with the credit union sector. Such entities include but are not limited to, credit unions, credit union trade associations and leagues, credit union service organizations, regulatory bodies, and entities offering products and services aimed primarily at credit unions.

18.1.1 CUNA Performance Resources, LLC

CUNA LLC was formed in Wisconsin, USA, on January 15, 2004 and its sole member is the Credit Union National Association, Inc. ("CUNA Inc."). CUNA Inc. is the premier national trade association serving Americaʹs credit unions. This not-for-profit trade group is governed by volunteer directors who are elected by their credit union peers. CUNA Inc. represents the interests of, and provides a wide variety of products and services to, approximately 90 percent of America's 7,300 state and federally chartered credit unions.

Credit unions in the United States have been a part of the financial services industry for more than one hundred years and currently hold almost one trillion dollars in assets. Credit unions are not-for-profit financial service cooperatives serving more than 90 million members in the United States alone. Globally, there are more than 50,000 credit unions in 100 countries, serving over 180 million people.


18.1.2 Potential Business Models

CUNA LLC is still analyzing potential use case options for the type of domain names that will be permitted to be registered and by whom. Specifically, CUNA LLC is relying upon CUNA Inc. and other members of the credit union sector to help develop a framework that will ensure that the credit union community is provided information and services in a safe and trusted environment. The current best thinking involves a two-stage roll-out.

Stage One (3 months - 12 months)

The primary use of the .CREDITUNION gTLD will initially be primarily defensive in nature, with CUNA LLC registering a small number of second level domain names to CUNA Inc. and select members of the credit union sector. This initial use will provide select IT and security personnel within the credit union sector the ability to run a number of tests to ensure seamless and secure access to various websites, and interoperability with various software and web-based applications. This will take at least several months, and up to one year.

Stage Two (Following Conclusion of Stage One)

Once appropriate security and stability issues have been satisfactorily addressed, CUNA LLC will implement the appropriate Sunrise and Trademark Clearing House Rights Protection Mechanisms and expand the allocation of domain names within the broader credit union sector as identified above. This phased roll-out will likely take place as soon as CUNA LLC makes a business decision that it is the appropriate time to expand the registration universe and use of the new domain name, but any final decision is subject to change depending upon a range of external factors. During this same period of time CUNA LLC, in consultation with the credit union sector, will evaluate potential strategies to integrate with and/or migrate traffic away from the current patchwork network of second level domains registered in various TLDs, to the new .CREDITUNION gTLD.

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.

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.

22 CUNA LLC Has Properly Researched This Topic


CUNA LLC is keenly aware of the sensitivity of national governments in connection with protecting country and territory identifiers in the Domain Name System (DNS). In preparation for answering this question, CUNA LLC's subject matter experts reviewed the following relevant background material regarding the protection of geographic names in the DNS:

-ICANN Board Resolution 01-92 regarding the methodology developed for the reservation and release of country names in the .INFO top-level domain, see http://www.icann.org/en/minutes/minutes-10sep01.htm;
-ICANN's Proposed Action Plan on .INFO Country Names, see http://www.icann.org/en/meetings/montevideo/action-plan-country-names-09oct01.htm;
-"Report of the Second WIPO Internet Domain Name Process: The Recognition and Rights and the Use of Names in the Internet Domain Name System," Section 6, Geographical Identifiers, see http://www.wipo.int/amc/en/processes/process2/report/html/report.html;
-ICANN's Governmental Advisory Committee (GAC) Principles Regarding New gTLDs, see https://gacweb.icann.org/download/attachments/1540128/gTLD_principles_0.pdf?version=1&modificationDate=1312358178000;
-ICANN's Generic Names Supporting Organization Reserved Names Working Group - Final Report, see http://gnso.icann.org/issues/new-gtlds/final-report-rn-wg-23may07.htm.

22.1 Initial Reservation of Country and Territory Names

CUNA LLC is committed to initially reserving the country and territory names contained in the internationally recognized lists described in Article 5 of Specification 5 attached to the New gTLD Applicant Guidebook at the second level and at all other levels in the .CREDITUNION gTLD, within which CUNA LLC will provide for registrations. Specifically, CUNA LLC will reserve:

1. The short form (in English) of all country and territory names contained on the ISO 3166-1 list, as updated from time to time, including the European Union, which is exceptionally reserved on the ISO 3166-1 list, and its scope extended in August 1999 to any application needing to represent the name European Union, see http://www.iso.org/iso/support/country_codes/iso_3166_code_lists/iso-3166-1_decoding_table.htm#EU;

2. The United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardization of Geographical Names, Part III Names of Countries of the World; and

3. The list of United Nations member states in six official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names.

22.2 Fair & Non-Misleading Use of Geographical Identifiers

Currently, CUNA LLC and other members with a nexus to the credit union sector operate websites using a combination of geographic identifiers in their registered domain names. CUNA LLC believes that a .CREDITUNION gTLD can provide an online, single-source identifying function for its current and future members, customers, and peers in the credit union sector around the world. This is in contrast to the present approach members with a nexus to the credit union sector have used as it expands into different markets around the world, which consists of registering the domain names that are available, rather than those that may be the most intuitive.

Given this geographic approach to finding content about credit unions, CUNA LLC intends to explore the option of providing a hierarchical and intuitive framework for the .CREDITUNION namespace by using geographical identifiers as second-level domain names. CUNA LLC believes the use of geographical identifiers to the left of the TLD and as part of the domain name itself has a direct and material impact on search engine algorithms and their corresponding query results. In addition, such naming conventions are intuitive and practiced by direct navigation Internet users (those who type their intended destination into address bars as opposed to search engines). CUNA LLC would like to determine if this type of hierarchical and intuitive use of second-level domain names within a gTLD provides increased consumer functionality, as premised by ICANN.


22.3 The Legal Protection of Geographical Identifiers

The World Intellectual Property Organization (WIPO) authored an authoritative resource on the current state of the law in connection with the protection of geographical identifiers, its 2001 "Report of the Second WIPO Internet Domain Name Process: The Recognition of Rights and the Use of Names in the Internet Domain Name System" ("WIPO Report"). Section six of the WIPO Report was devoted exclusively to the protection of Geographical Identifiers.

From its analysis of the well established framework against the misuse of geographical identifiers at the international, regional, and national levels, WIPO identified the following two elements for the protection of geographical identifiers: (i) a prohibition of false descriptions of the geographical source of goods; and (ii) a more extensive set of rules prohibiting the misuse of one class of geographical source indicators, known as geographical indications (See WIPO Report Paragraphs 206 and 210). Neither false descriptions of the geographical source of goods, nor misuse of geographical indications, is present in CUNA LLC's current or proposed use of geographical identifiers.

Notwithstanding WIPO's observation that the protection of geographical identifiers is "a difficult area on which views are not only divided, but also ardently held" (Paragraph 237), national governments within the ICANN Governmental Advisory Committee (GAC) and other international fora have continued to advocate for increased safeguards to protect against the misuse of geographical identifiers within the DNS.

CUNA LLC and other members with a nexus to the credit union sector generally seek to avoid business practices that could potentially mislead consumers. CUNA LLC does believe, however, that it is important to be able to use geographical identifiers in a fair and non-misleading manner, if such use can benefit Internet users and consumers as proposed in CUNA LLC's business model.

22.4 Fair & Non-Misleading Use of Geographical Identifiers

In undertaking a thorough research of this subject matter prior to filing this application, CUNA LLC was able to uncover the following representative sampling of fair and non-misleading use of geographical identifiers used in the existing gTLD domain name space:

Fair Use of National Geographical Identifiers

AUSTRALIA.COOP - Is operated by Co-operatives Australia, the national body for State Co-operative Federations, and provides a valuable resource about cooperatives within Australia.

UK.COOP - Is operated by Co-operatives UK, the national trade body that campaigns for cooperation and works to promote, develop, and unite cooperative enterprises within the United Kingdom.

NZ.COOP - Is operated by the New Zealand Cooperatives Association, which brings together the country's cooperative mutual businesses in a not-for-profit incorporated society.

MALDIVIAN.AERO - Is the dominant domestic air carrier in Maldives, and provides a range of commercial and leisure air transport services.

Fair Use of Regional/Local Geographic Identifiers

TEXAS.JOBS - Is operated through a joint effort between DE, the Texas Workforce Commission, and the National Labor Exchange to connect job seekers with approximately 96,000 job openings. An additional domain name operated by this joint effort was

BOISE.COOP - Is operated by Boise Co-op, a member-owned cooperative founded in 1973 by a few dozen individuals who shared a mutual interest in buying healthful and organic food at reasonable prices.

BROOKLYN.COOP - Is operated by Brooklyn Cooperative Federal Credit Union, which began as a modest storefront business in 2001, but is now New York City's fastest growing credit union and a model for community development credit unions nationwide.

HYDERABAD.AERO - Is operated by the Hyderabad International Airport and provides a range of interactive services and information for both business and leisure travelers.

SACRAMENTO.AERO - Is a portal website operated by Sacramento County to provide links to each of the airports serving the Sacramento area: Sacramento International Airport (SMF), Mather Airport (MHR), Executive Airport (SAC), and Franklin Field (F72).

22.5 Protection of Regional and Local Geographic Names for Non-Misleading Use

CUNA LLC has stated its intention to consider using non-reserved geographic identifiers as part of a hierarchical and intuitive framework in a fair and non-misleading manner to help consumers navigate the .CREDITUNION namespace. CUNA LLC is committed to operating the .CREDITUNION gTLD in a manner that minimizes potential consumer confusion, and will actively work with others in the ICANN community regarding any future policy development in this area.

22.6 Potential Future Release of Initially Reserved Names

CUNA LLC looks forward to collaborating with other new gTLD registry operators (especially .BRAND gTLDs) in potentially working with ICANN's GAC to explore processes that could permit the release of initially reserved country names (including ISO-3166 two-characters). Specifically, CUNA LLC is interested in exploring other Registry Service Evaluation Processes (RSEP) that have been filed by existing gTLD registry operators in releasing previously reserved domain names.

22.7 Dispute Resolution

CUNA LLC does not envision any potential disputes from governments or public authorities in connection with the registration and use of geographic names within the .CREDITUNION gTLD based upon its proposed use set forth in the response to Question 18 of this application. However, CUNA LLC is willing to working with governments, public authorities, or IGOs that may have a concern regarding the registration of names with national or geographic significance at the second level within the .CREDITUNION gTLD.

22.8 Creation and Updating the Policies

CUNA LLC is also committed to continually reviewing and updating these lists to prevent the misleading use of geographical identifiers. Consistent with this commitment, CUNA LLC or its designated representatives intend to participate in any ongoing ICANN policy discussion regarding the protection of geographic names within the DNS. Should the need arise in the future for the creation or updating of the policies regarding this class of domain names, CUNA LLC will act in a responsible manner.