Hello Kim,

> 
> But there needs to be compliance testing - complaints driven, 
> random selection, or some other methodology. But with no, or 
> weak, followup all the incentive is to not follow the rules 
> as the risks are so low that anything adverse will happen.

Agreed.

> 
> I would hazard a guess that there are still companies 
> systematically registering on behalf of the real entities but 
> not placing the real entities as the registrant. 

Ultimately the registrant suffers in these scenarios.  Our experience
with disputes indicates that this is one of the main problems that occur
with dispute over who is the rightful licence holder (a corporate entity
or the technical person that registered the name on their behalf).  How
many people would let a real estate agent put their name on a house
title when the house is bought?  Yet several years after registration a
domain name maybe worth more than a house to a business.

One of the issues at present is that the rules/procedures for changing
the registrant are too onerous when an error has been made.  They are
aimed at preventing the trading of domain names (which is generally
working well), but there are side effects also.

Regards,
Bruce