Firstly, just a nit, but section 4.1 introduces a new abbreviation in the
last bullet point: "PSDo". I suspect that this should be PSO for
consistency.

More substantively, in Appendix A, the case is being advanced for "concerns
associated with Multi-organization PSDs that do not mandate DMARC usage".
I'm not sure why "multi-organization" is an appropriate qualifier, nor as
to what mandated DMARC usage has to do with any of the privacy concerns.
Neglected DMARC usage is what leads to the spillage up to the PSD level.
Even within a single organization there may be serious privacy walls which
need to be respected between different sub-portions of the org - which may
or may not be represented in a DNS hierarchy.

I've read through the breakdown in section 4.1, but I think that it is
incomplete - largely on the terms mentioned above. Also, the claim that
reports on cousin domains would be sent to the [right] PSO ignores the risk
of the PSD itself being the cousin attack point. After all if a domain
doesn't exist, one may as well start from the top :-)

I think it would be more effective to add an anti-RUF requirement to the
implementation of this spec - such that no RUF reports would be sent,
regardless of the record which is published by the PSD. Since very few
providers even support RUF at all, this does not seem to be a big ask,
although it does require some additional logic. The privacy risk is
primarily related to RUF, not RUA reports so blocking RUF could (IMO)
effectively mitigate the perceived risk of the PSD records while still
allowing the DMARC validation protection.

--Kurt
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