.bank 2000 proposals

Domain Name Registration Proposal For A New Second Level Domain Name: ".bank"

Telephone (04) 472-8838, Facsimile (04) 473-1698

P0 Box 3043, Wellington 6015, New Zealand. Level 12, Grand Arcade Tower, 16 Willis Street

Overview

"Branding" and reputation are critical elements in business, in both the "real" and the "virtual" worlds. This is most particularly relevant for banks.

Banks' core roles rest heavily on maintaining the confidence and trust of their customers in the integrity of their systems and processes, in their ability to maintain client confidentiality, and in their business efficiency and effectiveness.

Most countries recognise the critical role that banks play in the economy and the financial system by applying to them a degree of supervision and regulation that applies to few other sectors, and by strictly controlling the institutions that claim to be, and operate as, banks.

This is also the case in New Zealand - only financial institutions that have been registered and are supervised by the Reserve Bank may call themselves "banks".

New Zealand banks believe that there is a need to allow identity to be established and conveyed more clearly and effectively in the on line world with regard to banking services. Banks propose that this be done by creating a new second level domain name in the New Zealand name space: ".bank" .

Qualifying Criteria

Main Principles for Registration of Second Level Domain Names

1. The Internet Society of New Zealand ISOCNZ, which administers the New Zealand Internet name space, has defined the criteria for second level domain names as being that:

• There is a clear common interest shared by the entities that would reside within the domain i.e. there exists a community of interest.
• Communities of interest do not overlap, so far as is practicable.
• The domain name clearly indicates or describes the nature of the community of interest.
• The community of interest is certain of continued existence.

These requirements are addressed in the following sections.

Principle One: Community of Interest

In New Zealand, one of the effects of the Reserve Bank of New Zealand Act 1989 is that generally only organisations which have been registered as registered banks by the Reserve Bank may describe themselves as "banks". These institutions are subject to the Reserve Bank's prudential supervision regime, and must meet various international banking standards, for instance on capital adequacy.

This does not prevent other organisations, such as funds managers, insurance companies and building societies, from providing banking services, but it does mean that they cannot use the term "bank" as part of their name, or otherwise describe themselves as banks.

There is therefore a "community of interest" within New Zealand, clearly defined by legislation, and consisting of organisations that have been registered as banks by the Reserve Bank of New Zealand. These organisations provide a broadly similar range of banking services, and adhere to common technical, operational and business rules and standards. There are at present 18 registered banks in New Zealand. (See appendix 1 for a list.)

Principle Two: Potential for Overlaps

Since banks are also commercial entities, there is potential for an overlap between the proposed ".bank" second level domain and the ".co" domain name. In fact all banks which provide Internet banking services in the New Zealand name space currently use ".co" as their second level identifier.

In practical terms, the potential for this to create problems or confusion should be minimal. Many organizations have several brands, which they use in both the real and the on line world. In the latter case, this can also involve different Internet addresses across both level two (community) and level one (country) name spaces.

In principle, some potential for overlap already exists within the .nz name space. For example the entities within the .mil.nz name space are also members of the .govt.nz community, but there is presumably value in enabling them to present an on line identity distinct from other government entities.

Similarly, the creation or proposed creation of new second level domain names in other countries (for instance ".store") perhaps indicates that while more fine grained domain name structures could create some overlaps in communities of interest, there are compensating advantages to this approach, in being able to more efficiently convey information as to the nature of the entities concerned.

Principle Three: Degree of Descriptiveness

Banks believe that the proposed ".bank" name fully meets ISOCNZ's requirements in terms of being clearly indicative of the nature of the community of interest.

Principle Four: Degree of Permanency

Banks have been in existence as discrete entities for a considerable length of time.

As technology advances, and societies and economies evolve, new organisational structures, channels and systems will emerge. However, so long as economies require funds management, lending and payments, there will be organisations which provide banking services, and which wish to be known as "banks".

Moderation of the .bank Domain Name

Delegation

ISOCNZ provides that the authority to moderate membership of some second level domains can be delegated to a representative of that community.

Banks propose that the authority to moderate membership of the .bank domain name should be delegated to the New Zealand Bankers' Association, as their industry representative. The NZBA would develop and administer rules and processes in consultation with ISOCNZ, as is currently required.

Although membership of the NZBA is not compulsory, the banks that are members account for almost all of the banking services (account management, transactional banking and lending) provided to New Zealand consumers, business and government entities.

In addition, all banks operate under the technical and business rules and standards that the NZBA administers on behalf of the industry. These include transaction and file formats, and rules and procedures for paper based and electronic payments. The NZBA also provides various registry services, including for instance maintaining the register of valid bank branch numbers.

Administration of the .bank domain name would therefore be a natural extension of the NZBA's existing registration responsibilities into the virtual world.

Access Rules

As noted above, legislative provisions mean that membership of the .bank domain name space would be restricted to organisations that have been registered as banks by the Reserve Bank of New Zealand.

Unlike some other countries, New Zealand does not have a limit on the number of banks. Any organisation (whether or not it currently offers banking or financial services) that wishes to enter the market and can meet the Reserve Bank's requirements can be registered as a bank.

Any such organisation would then be able to use the term "bank" in its name and, under the framework proposed above, would then have access to the .bank domain name space. This initiative therefore cannot be seen as creating a group that would be open only to existing service providers.

Any change in public policy or in legislation which redefined the nature of banks or which resulted in new rules regarding the use of the term "bank" would be included in the access rules that would be developed in conjunction with ISOCNZ and applied to this name space.

Conclusion

1. Banks believe that there is a strong case to be made for a .bank second level domain name space, that it meets the key requirements set out by ISOCNZ, and that the administrative responsibilities can and should be delegated to the New Zealand Bankers' Association, as the industry's representative.

2. Appendix

New Zealand Registered Banks

Registered banks in New Zealand, as at end August 2000, are as follows.

• ABN AMRO Bank
• AMP Bank Ltd (*)
• ANZ Banking Group (New Zealand) Ltd (*)
• ASB Bank Ltd (*)
• Bank of New Zealand (*)
• Bank of Tokyo-Mitsubishi (Australia)
• BNP Paribas
• BNZ Finance
• Citibank NA (*)
• Commonwealth Bank of Australia
• Deutsche Bank
• Kookmin Bank
• Rabobank New Zealand Limited
• Rabobank Nederland
• The Hongkong and Shanghai Banking Corporation (*)
• The National Bank of New Zealand Ltd(*)
• TSB Bank Ltd (*)
• Westpac Banking Corporation (*)

(*) Member of the New Zealand Bankers' Association