18(b) How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?
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18(b)i. WHAT IS THE GOAL OF YOUR PROPOSED GTLD IN TERMS OF AREAS OF SPECIALTY, SERVICE LEVELS OR REPUTATION?
The key goals of the proposed new .bbt gTLD are in line with ICANN’s Affirmation of Commitments: to promote consumer trust, competition and consumer choice. In an ever changing internet business environment, BB&T seeks to foster its online reputation and enhance its long term growth efforts by taking advantage of the opportunities provided by the tools and technology available in such an environment. Further, with the proposed .bbt gTLD, BB&T seeks to provide an authoritative internet space through which BB&T is able to communicate with its customers directly and effectively. The ability to create domain names on demand related to specific marketing, specialty service and product development supports these goals. Strengthened security measures, service levels and more effective functionality will provide a trusted and positive user experience.
18(b)ii. WHAT DO YOU ANTICIPATE YOUR PROPOSED GTLD WILL ADD TO THE CURRENT SPACE, IN TERMS OF COMPETITION, DIFFERENTIATION, OR INNOVATION?
It is anticipated that the proposed .bbt gTLD will make positive contributions to the wider internet community by providing:
DIFFERENTIATION (INCREASED TRUST):
The .bbt gTLD will simplify how internet users interact with BB&T by providing a distinctive domain space. Internet users will be able to directly navigate to the .bbt gTLD site, saving time and resources searching for an official site. BB&T seeks to use the .bbt domain space as a communication platform to interact with its users and to promote its sales and marketing programmes. BB&T plans to provide its users an enhanced and seamless integrated experience using the proposed .bbt gTLD along with its existing online domains, social media sites, standard marketing tools and communications methods. The .bbt gTLD will provide BB&T with the opportunity to offer targeted sales and personalised offers to its existing and prospective clients. The current domain name system has shown that it is vulnerable to malicious abuses due to registration of domain names which seek to exploit consumer confusion. BB&T can address some of these vulnerabilities by maintaining complete control over the domain names registered under the .bbt domain space to provide a more secure integrated communications experience to its users. Together with consumer trust, internet users will be able to rely on the authoritativeness of the domain names under the .bbt domain space, which will enhance interaction between internet users and BB&T.
The differentiation of the .bbt gTLD as a trusted site for BB&T will drive existing and new TLD registry operators to make improvements in mechanisms to improve consumer trust of their TLDs. The .bbt domain names will foster innovation and provide BB&T with new ways of doing business online. Internet users will be encouraged to interact with domain names under the .bbt domain space. As a result, .bbt will have a flow on effect to enable increased competition. Therefore, the benefits of the proposed .bbt gTLD will be distributed not only to its direct customers, but to the internet community at large by improving service and competition in the market place.
With the expansion of the internet community to all corners of the world, the existing TLD structure presents limitations, not only in the availability of domain names for registrants, but also to businesses establishing a coherent global online brand presence to meet their evolving business needs. It is often difficult to register a domain name in existing domain space due to unavailability of the desired name. Even when the desired domain name is available, it may come with a high price tag associated with a purchase of such desired name from a third party. With the .bbt gTLD, BB&T has the ability to create second or third level domain names which are relevant to its customer base, services and products specific to its financial services. BB&T will be able to combine its use of the domain space with innovative personalised user focused marketing and services to address the currently unmet needs in the existing domain name system, thereby providing greater consumer choice to its current and prospect clients.
The proposed .bbt gTLD will provide a positive user experience, which meets the changing and growing needs of the global internet community. BB&T will maintain control in the registration and use of domain names and will ensure that the new gTLD will only be used for purposes authorised by BB&T. Therefore, the .bbt gTLD will:
- provide an easy and intuitive reference and access point for internet users;
- provide BB&T opportunities to offer targeted sales and personalised services to its current and prospective clients;
- enhance BB&T’s communications platform for its internet users;
- represent BB&T’s online authenticity thus promoting user confidence;
- direct internet users to relevant information in a timely manner by creating domain names on demand thereby establishing a seamless integrated online experience for BB&T’s users;
- enhance security and minimise security risks by implementing necessary technical and policy measures;
- strengthen BB&T’s online brand reputation as a bank and promote user confidence amongst its users by mitigating cybercrime risks and eliminating user confusion; and
- prevent potential abuses in the registration process reducing overall costs to businesses and users.
The .bbt gTLD should address the concerns that the current domain name system is open to potential malicious abuse and user confusion in the registration processes. Although the current system allows an eligible party to lodge a claim through existing Uniform Domain Name Dispute Resolution Policy (UDRP) or other dispute resolution processes, the .bbt gTLD will reduce potential abuses in the registration processes and overall costs to internet users. The registration and use of domain names within the .bbt gTLD will be restricted to BB&T only for its internal business use. Therefore, user confidence in the domain name system will be strengthened, which will ultimately contribute towards promoting ICANN’s core values in benefiting the public interest.
18(b)iv. PROVIDE A COMPLETE DESCRIPTION OF THE APPLICANTʹS INTENDED REGISTRATION POLICIES IN SUPPORT OF THE GOALS LISTED ABOVE
The proposed registration policy is attached in response to Question 28.
Only BB&T will be eligible to register domain names in .bbt at this stage. The domain name registration processes will address the requirements mandated by ICANN, including rights abuse prevention measures.
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.
As part of a heavily regulated industry, BB&T is committed to protection of privacy and confidential information in accordance with its objective of increasing consumer trust and providing a safe and legitimate internet space for internet users. Privacy and confidential information will be protected in accordance with all applicable laws and regulations relating to internet security, privacy and user’s confidential information, including the Electronic Communications Privacy Act 1986 (US) and Controlling the assault of non-solicited pornography and marketing (Can-Spam) Act (2003) (US). BB&T also complies with all relevant Federal and State requirements and standards for the financial industry in the US including Regulation P of Section 216 of the Code of Federal Regulations in US and regulations from the Securities and Exchange Commission, Office of Foreign Assets Control, Financial Industry Regulatory Authority, Office of the Comptroller of the Currency, Consumer Financial Protection Bureau, Federal Financial Institutions Examinations Council and the Federal Reserve System in the US.
Privacy is of fundamental concern to BB&T’s customers as the interaction between BB&T and its internet users may involve monetary transactions. As such BB&T has a strong interest in ensuring a high level of privacy protection for its customers. BB&T has also implemented its own privacy policies and controls to demonstrate its commitment to the protection of user privacy and confidential information.
BB&T currently operates 3 privacy policies, which are all available on its website, to ensure that its users are informed of the types of information that it collects and how such information is used:
Online Information Practices: BB&T only collects personally identifiable information over its website if a user has provided such information via its online contact forms, online applications, or online banking.
(i) BB&T Corporation Consumer Privacy: As a financial institution in the US, federal law allows BB&T to share personally identifiable information to the extent that a user limits such sharing. BB&T only shares such information where it is required to run its everyday business.
(ii) BB&T Complete Client Protection: provides information on the advanced technologies used by BB&T to safeguard personal and financial information of its users relevant to BB&T’s various services.
BB&T will deploy Domain Name System Security Extensions (DNSSEC) which is intended to benefit both BB&T and its users interacting with BB&T. DNSSEC provides additional security by validating information in the transmission, therefore it is intended to benefit those who publish information in the domain name system (DNS) and the users who retrieve information from the new .bbt gTLD. BB&T already implements measures to protect privacy or confidential information of its users against misuse, loss, alteration and unauthorised access. Such measures include:
- use of Secure Sockets Layer (SSL) data encryption;
- use of various encryption methodologies;
- use of user identifiers (UID);
- use of passwords; and
- employment of multifactor and out of band authentication methods.
BB&T will continue to apply all security measures currently implemented and will comply with all other policies and practices required by ICANN in the Registry Agreement and any relevant Consensus Policy for protecting the privacy and confidential information of registrants and users in the new .bbt domain space.
18(b)vi. DESCRIBE WHETHER AND IN WHAT WAYS OUTREACH AND COMMUNICATIONS WILL HELP TO ACHIEVE YOUR PROJECTED BENEFITS.
The proposed new gTLD will be publicised by a media plan to promote recognition of the new gTLD within the internet community to be a trusted site and as a sign of authenticity.
BB&T plans to implement the .bbt gTLD in its marketing promotions and via a multi-channel communications campaign directed towards its existing clients to alert them of the new .bbt domain space.
During the initial stage of the operation of the proposed new gTLD, it is anticipated that internet users may be re-directed to current websites. However, over time, it is foreseen that communication to the internet community of the existence of the proposed new gTLD and encouragement to utilise the trusted site will contribute towards minimising malicious abuses and protecting internet users.
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