and would not raise red flags with the registrar
That's the real determing factor here, they are visibly limiting to 10 tries every 10 minutes, but if there's another limit such as 100 failed tries per password (per 2 hours) absolute max or whatever, that can make a huge difference.
If you want to hope for unicorns and rainbows, you might even think they use the higher failure limit as a flag to start investigation into where the abuse is coming from and doing what they can to stop it at its source - you'd want to encourage the abusers to keep trying in order for that kind of scheme to work.
I just had an idea for a system which lets you try 10 times in 10 minutes, lets you bypass that limit by tossing your cookies or whatever, but - after 100 failed tries on this 2 hour password, even if you guess correctly it doesn't let you in anyway, just acts like you put in another wrong guess, but... for attackers that continue to try it initiates a backtrace...