From info at arin.net  Thu Sep  1 15:39:46 2016
From: info at arin.net (ARIN)
Date: Thu, 1 Sep 2016 15:39:46 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
Message-ID: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>

During its recent meeting held on 23 August 2016, the ARIN Board of
Trustees considered a change to the fee schedule as it pertains to both
Number Resource Policy Manual (NRPM) section 8.3 and 8.4 transfers
(https://www.arin.net/policy/nrpm.html#eight3).

Currently about 25% of ARIN transfer request processing results in an
unsuccessful outcome, i.e. in 1 out of 4 requests, the transfer is
either abandoned or not approved. When transfer requests are
unsuccessful, ARIN incurs essentially the same processing costs as it
does for successful transfers.

To appropriately recover these costs, ARIN proposes collecting the
present $500 Resource Transfer fee at the beginning of the transfer
process as a non-refundable transfer processing fee. This fee would be
only be applicable to source organizations which do not have a
Registration Services Agreement (RSA) or Legacy Registration Services
Agreement (LRSA) when an 8.3 or 8.4 transfer request is submitted. This
fee change would replace the $500 Resource Transfer fee
(https://www.arin.net/fees/fee_schedule.html) that is currently
collected at the end of the transfer process for approved requests.

We are seeking community feedback on this modification to ARIN?s Fee
schedule.

This consultation will remain open for (30) days, after which a summary
will be provided to the Board of Trustees for their consideration.

Discussion on arin-consult at arin.net will close on 30 September 2016.

If you have any questions, please contact us at info at arin.net.

Regards,

John Curran
President and CEO
American Registry for Internet Numbers (ARIN)





From has at google.com  Tue Sep  6 11:40:04 2016
From: has at google.com (Heather Schiller)
Date: Tue, 6 Sep 2016 11:40:04 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
Message-ID: <CAEabp57uciSBy1WkjwXJvnto-BymKCn1hL4FK0djBth7jhQR7Q@mail.gmail.com>

Request for clarification, if the source has an RSA/LRSA is the fee waived
entirely?  (that's how I read the paragraph)

"This fee would be
only be applicable to source organizations which do not have a
Registration Services Agreement (RSA) or Legacy Registration Services
Agreement (LRSA) when an 8.3 or 8.4 transfer request is submitted. This
fee change would replace the $500 Resource Transfer fee
(https://www.arin.net/fees/fee_schedule.html) that is currently
collected at the end of the transfer process for approved requests."

On Thu, Sep 1, 2016 at 3:39 PM, ARIN <info at arin.net> wrote:

> During its recent meeting held on 23 August 2016, the ARIN Board of
> Trustees considered a change to the fee schedule as it pertains to both
> Number Resource Policy Manual (NRPM) section 8.3 and 8.4 transfers
> (https://www.arin.net/policy/nrpm.html#eight3).
>
> Currently about 25% of ARIN transfer request processing results in an
> unsuccessful outcome, i.e. in 1 out of 4 requests, the transfer is
> either abandoned or not approved. When transfer requests are
> unsuccessful, ARIN incurs essentially the same processing costs as it
> does for successful transfers.
>
> To appropriately recover these costs, ARIN proposes collecting the
> present $500 Resource Transfer fee at the beginning of the transfer
> process as a non-refundable transfer processing fee. This fee would be
> only be applicable to source organizations which do not have a
> Registration Services Agreement (RSA) or Legacy Registration Services
> Agreement (LRSA) when an 8.3 or 8.4 transfer request is submitted. This
> fee change would replace the $500 Resource Transfer fee
> (https://www.arin.net/fees/fee_schedule.html) that is currently
> collected at the end of the transfer process for approved requests.
>
> We are seeking community feedback on this modification to ARIN?s Fee
> schedule.
>
> This consultation will remain open for (30) days, after which a summary
> will be provided to the Board of Trustees for their consideration.
>
> Discussion on arin-consult at arin.net will close on 30 September 2016.
>
> If you have any questions, please contact us at info at arin.net.
>
> Regards,
>
> John Curran
> President and CEO
> American Registry for Internet Numbers (ARIN)
>
>
>
> _______________________________________________
> ARIN-Consult
> You are receiving this message because you are subscribed to the ARIN
> Consult Mailing
> List (ARIN-consult at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-consult Please contact the
> ARIN Member Services
> Help Desk at info at arin.net if you experience any issues.
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160906/e429b218/attachment.html>

From jcurran at arin.net  Tue Sep  6 12:07:02 2016
From: jcurran at arin.net (John Curran)
Date: Tue, 6 Sep 2016 16:07:02 +0000
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <CAEabp57uciSBy1WkjwXJvnto-BymKCn1hL4FK0djBth7jhQR7Q@mail.gmail.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<CAEabp57uciSBy1WkjwXJvnto-BymKCn1hL4FK0djBth7jhQR7Q@mail.gmail.com>
Message-ID: <014816B5-F49F-448D-A9B5-A769BDBE4FD1@corp.arin.net>

Heather -

Excellent question - the consultation language could have been clearer (and probably
was before I ?improved it?? via my editing?)

Waiving the resource transfer fee would certainly be the case for parties who have
a registration services plan (i.e. all ISPs and any end-users who opted for such), as
in general we waive their registry transaction fees.

For end-users and legacy resource holders paying per-resource maintenance fees, it
would be most equitable to charge a resource transfer fee, since the costs associated
with transfer processing are disproportionate to day-to-day registry services covered
by the annual maintenance.

(However, this is a consultation, so it is really the community being asked what it feels
is most appropriate - i.e. what are your thoughts on this?)

I hope this helps clarify things - thanks for asking!
/John

John Curran
President and CEO
ARIN

On Sep 6, 2016, at 11:40 AM, Heather Schiller <has at google.com<mailto:has at google.com>> wrote:

Request for clarification, if the source has an RSA/LRSA is the fee waived entirely?  (that's how I read the paragraph)

"This fee would be
only be applicable to source organizations which do not have a
Registration Services Agreement (RSA) or Legacy Registration Services
Agreement (LRSA) when an 8.3 or 8.4 transfer request is submitted. This
fee change would replace the $500 Resource Transfer fee
(https://www.arin.net/fees/fee_schedule.html) that is currently
collected at the end of the transfer process for approved requests."

On Thu, Sep 1, 2016 at 3:39 PM, ARIN <info at arin.net<mailto:info at arin.net>> wrote:
During its recent meeting held on 23 August 2016, the ARIN Board of
Trustees considered a change to the fee schedule as it pertains to both
Number Resource Policy Manual (NRPM) section 8.3 and 8.4 transfers
(https://www.arin.net/policy/nrpm.html#eight3).

Currently about 25% of ARIN transfer request processing results in an
unsuccessful outcome, i.e. in 1 out of 4 requests, the transfer is
either abandoned or not approved. When transfer requests are
unsuccessful, ARIN incurs essentially the same processing costs as it
does for successful transfers.

To appropriately recover these costs, ARIN proposes collecting the
present $500 Resource Transfer fee at the beginning of the transfer
process as a non-refundable transfer processing fee. This fee would be
only be applicable to source organizations which do not have a
Registration Services Agreement (RSA) or Legacy Registration Services
Agreement (LRSA) when an 8.3 or 8.4 transfer request is submitted. This
fee change would replace the $500 Resource Transfer fee
(https://www.arin.net/fees/fee_schedule.html) that is currently
collected at the end of the transfer process for approved requests.

We are seeking community feedback on this modification to ARIN?s Fee
schedule.

This consultation will remain open for (30) days, after which a summary
will be provided to the Board of Trustees for their consideration.

Discussion on arin-consult at arin.net<mailto:arin-consult at arin.net> will close on 30 September 2016.

If you have any questions, please contact us at info at arin.net<mailto:info at arin.net>.

Regards,

John Curran
President and CEO
American Registry for Internet Numbers (ARIN)



_______________________________________________
ARIN-Consult
You are receiving this message because you are subscribed to the ARIN Consult Mailing
List (ARIN-consult at arin.net<mailto:ARIN-consult at arin.net>).
Unsubscribe or manage your mailing list subscription at:
http://lists.arin.net/mailman/listinfo/arin-consult Please contact the ARIN Member Services
Help Desk at info at arin.net<mailto:info at arin.net> if you experience any issues.

_______________________________________________
ARIN-Consult
You are receiving this message because you are subscribed to the ARIN Consult Mailing
List (ARIN-consult at arin.net<mailto:ARIN-consult at arin.net>).
Unsubscribe or manage your mailing list subscription at:
http://lists.arin.net/mailman/listinfo/arin-consult Please contact the ARIN Member Services
Help Desk at info at arin.net<mailto:info at arin.net> if you experience any issues.

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160906/c34d5238/attachment.html>

From jschiller at google.com  Tue Sep  6 15:27:18 2016
From: jschiller at google.com (Jason Schiller)
Date: Tue, 6 Sep 2016 15:27:18 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
Message-ID: <CAC4yj2Wo86LSV-GZotj0mi30Jjnqj4UCLowtstGtLDGjCY50PQ@mail.gmail.com>

Can you clarify who is required to pay the fee, the source or the recipient?

>From the wording it sounds like if the source does not have an RSA then the
source
must pay the fee when the transfer is initiated.

Currently it is the recipient that pays the transfer fee.  Will that still
be true and if so
can you clarify that language?

__Jason

On Thu, Sep 1, 2016 at 3:39 PM, ARIN <info at arin.net> wrote:

> During its recent meeting held on 23 August 2016, the ARIN Board of
> Trustees considered a change to the fee schedule as it pertains to both
> Number Resource Policy Manual (NRPM) section 8.3 and 8.4 transfers
> (https://www.arin.net/policy/nrpm.html#eight3).
>
> Currently about 25% of ARIN transfer request processing results in an
> unsuccessful outcome, i.e. in 1 out of 4 requests, the transfer is
> either abandoned or not approved. When transfer requests are
> unsuccessful, ARIN incurs essentially the same processing costs as it
> does for successful transfers.
>
> To appropriately recover these costs, ARIN proposes collecting the
> present $500 Resource Transfer fee at the beginning of the transfer
> process as a non-refundable transfer processing fee. This fee would be
> only be applicable to source organizations which do not have a
> Registration Services Agreement (RSA) or Legacy Registration Services
> Agreement (LRSA) when an 8.3 or 8.4 transfer request is submitted. This
> fee change would replace the $500 Resource Transfer fee
> (https://www.arin.net/fees/fee_schedule.html) that is currently
> collected at the end of the transfer process for approved requests.
>
> We are seeking community feedback on this modification to ARIN?s Fee
> schedule.
>
> This consultation will remain open for (30) days, after which a summary
> will be provided to the Board of Trustees for their consideration.
>
> Discussion on arin-consult at arin.net will close on 30 September 2016.
>
> If you have any questions, please contact us at info at arin.net.
>
> Regards,
>
> John Curran
> President and CEO
> American Registry for Internet Numbers (ARIN)
>
>
>
> _______________________________________________
> ARIN-Consult
> You are receiving this message because you are subscribed to the ARIN
> Consult Mailing
> List (ARIN-consult at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-consult Please contact the
> ARIN Member Services
> Help Desk at info at arin.net if you experience any issues.




-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160906/b7585a4e/attachment.html>

From jcurran at arin.net  Tue Sep  6 15:37:58 2016
From: jcurran at arin.net (John Curran)
Date: Tue, 6 Sep 2016 19:37:58 +0000
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <CAC4yj2Wo86LSV-GZotj0mi30Jjnqj4UCLowtstGtLDGjCY50PQ@mail.gmail.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<CAC4yj2Wo86LSV-GZotj0mi30Jjnqj4UCLowtstGtLDGjCY50PQ@mail.gmail.com>
Message-ID: <FB955A9B-0150-4733-B167-59CC2C8944D8@corp.arin.net>

On Sep 6, 2016, at 3:27 PM, Jason Schiller <jschiller at google.com> wrote:
> 
> Can you clarify who is required to pay the fee, the source or the recipient?
> 
> From the wording it sounds like if the source does not have an RSA then the source
> must pay the fee when the transfer is initiated.  
> 
> Currently it is the recipient that pays the transfer fee.  Will that still be true and if so
> can you clarify that language?

We are proposing that the resource transfer fee be paid by the source up front , i.e. 
prior to processing of the request (we have no objection to another organization, e.g. 
the recipient, paying that fee of the source?s behalf, but that may not make sense 
given its non-refundable nature.)

It is proposed that the source organization, if the resources are not under a registration 
services plan would pay the fee when the transfer is initiated.   As noted, this would be
a change in practice which would provide for appropriate cost-recovery even when 
requests are abandoned or otherwise are not completed.

Thanks,
/John

John Curran
President and CEO
ARIN



From daveid at panix.com  Tue Sep  6 16:03:09 2016
From: daveid at panix.com (David R Huberman)
Date: Tue, 6 Sep 2016 16:03:09 -0400 (EDT)
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
Message-ID: <Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>

John,

Thank you for putting this out for community consultation. I think this 
is a fairly big shift in both thinking and fees, and it is good that the 
Board is asking for input.

To provide that input, however, I would like to see more data to have a 
better understanding of the proposed changes.

Baseline data we already know:

- Audited finncials from last year report $31.8M in reserve.

- FY16 budget is $21.7M

- FY16 revenue is projected at $18.8M (a ~$2.9M deficit)

- The audited financials for FY15 show $276,500 in revenue under "Network
transfers"

Questions that come to mind, to try and be informed:

- assuming this was in place Jan 1, what would the projected revenue be 
for transfers in FY17?

- what assumptions were made to get to this projection?

Thank you,
David




From mike at iptrading.com  Tue Sep  6 16:36:29 2016
From: mike at iptrading.com (Mike Burns)
Date: Tue, 6 Sep 2016 16:36:29 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <CAC4yj2Wo86LSV-GZotj0mi30Jjnqj4UCLowtstGtLDGjCY50PQ@mail.gmail.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<CAC4yj2Wo86LSV-GZotj0mi30Jjnqj4UCLowtstGtLDGjCY50PQ@mail.gmail.com>
Message-ID: <011101d2087e$5935df50$0ba19df0$@iptrading.com>

Jason wrote:

 

Currently it is the recipient that pays the transfer fee.  Will that still be true and if so

can you clarify that language?

 

 

Hi Jason,

 

Currently the recipient pays except for 8.4 transfers.

ARIN requests the transfer fee from SELLER before the transfer is sent to the recipient registry in those cases.

For inbound 8.4 transfers, the ARIN recipient pays the ARIN fee.

 

For a /24 sold from ARIN to APNIC or vice versa, the transfer fees total $500 from ARIN and $161 from APNIC, or $661. In this case transfer fees represent a whopping $2.60 per address, or almost a quarter of the cost of the addresses themselves. Considering that the number of small transfers is greater than large transfers, and in light of current ARIN reserve$, I suggest reducing the transfer fee for small blocks, or indexing the fee to the transfer size in a way that maintains overall current transfer revenue numbers. 

 

John says 1 in 4 transfers fail. I guess a substantial number are largish blocks that fail as a result of nefarious activity involved in claiming old blocks and selling them. The incentives for this behavior are less for small block sales. Can we get a breakdown of failure rates by transfer size?

 

Ripe charges no transfer fee. APNIC charges a fee tied to the transfer size. LACNIC charges $200 upfront, and $1300 before the transfer completes.  As part of the consideration about making the $500 upfront and non-refundable, are we able to discuss the transfer fee generally?

 

 

Regards,

Mike

 

 

 

From: arin-consult-bounces at arin.net [mailto:arin-consult-bounces at arin.net] On Behalf Of Jason Schiller
Sent: Tuesday, September 06, 2016 3:27 PM
To: ARIN <info at arin.net>
Cc: arin-consult at arin.net
Subject: Re: [ARIN-consult] Consultation on Transfer Fees Now Open

 

Can you clarify who is required to pay the fee, the source or the recipient?

 

>From the wording it sounds like if the source does not have an RSA then the source

must pay the fee when the transfer is initiated.  

 

Currently it is the recipient that pays the transfer fee.  Will that still be true and if so

can you clarify that language?

 

__Jason

 

On Thu, Sep 1, 2016 at 3:39 PM, ARIN <info at arin.net <mailto:info at arin.net> > wrote:

During its recent meeting held on 23 August 2016, the ARIN Board of
Trustees considered a change to the fee schedule as it pertains to both
Number Resource Policy Manual (NRPM) section 8.3 and 8.4 transfers
(https://www.arin.net/policy/nrpm.html#eight3).

Currently about 25% of ARIN transfer request processing results in an
unsuccessful outcome, i.e. in 1 out of 4 requests, the transfer is
either abandoned or not approved. When transfer requests are
unsuccessful, ARIN incurs essentially the same processing costs as it
does for successful transfers.

To appropriately recover these costs, ARIN proposes collecting the
present $500 Resource Transfer fee at the beginning of the transfer
process as a non-refundable transfer processing fee. This fee would be
only be applicable to source organizations which do not have a
Registration Services Agreement (RSA) or Legacy Registration Services
Agreement (LRSA) when an 8.3 or 8.4 transfer request is submitted. This
fee change would replace the $500 Resource Transfer fee
(https://www.arin.net/fees/fee_schedule.html) that is currently
collected at the end of the transfer process for approved requests.

We are seeking community feedback on this modification to ARIN?s Fee
schedule.

This consultation will remain open for (30) days, after which a summary
will be provided to the Board of Trustees for their consideration.

Discussion on arin-consult at arin.net <mailto:arin-consult at arin.net>  will close on 30 September 2016.

If you have any questions, please contact us at info at arin.net <mailto:info at arin.net> .

Regards,

John Curran
President and CEO
American Registry for Internet Numbers (ARIN)



_______________________________________________
ARIN-Consult
You are receiving this message because you are subscribed to the ARIN Consult Mailing
List (ARIN-consult at arin.net <mailto:ARIN-consult at arin.net> ).
Unsubscribe or manage your mailing list subscription at:
http://lists.arin.net/mailman/listinfo/arin-consult Please contact the ARIN Member Services
Help Desk at info at arin.net <mailto:info at arin.net>  if you experience any issues.





 

-- 

_______________________________________________________

Jason Schiller|NetOps|jschiller at google.com <mailto:jschiller at google.com> |571-266-0006

 

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160906/552d1598/attachment.html>

From scottleibrand at gmail.com  Tue Sep  6 16:44:17 2016
From: scottleibrand at gmail.com (Scott Leibrand)
Date: Tue, 6 Sep 2016 22:44:17 +0200
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <011101d2087e$5935df50$0ba19df0$@iptrading.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<CAC4yj2Wo86LSV-GZotj0mi30Jjnqj4UCLowtstGtLDGjCY50PQ@mail.gmail.com>
	<011101d2087e$5935df50$0ba19df0$@iptrading.com>
Message-ID: <CAGkMwz55bBvPs5wru8bG1k_j=S3sRRyCoBK4Pb+sP1N1qVmEhw@mail.gmail.com>

It might be worthwhile to consider the transfer fee on the seller to be a
fee for seller "prequalification", not tied to a particular recipient or
transfer transaction, but rather to the block(s) being transferred.  If a
transfer transaction falls through, the same work ARIN has already
performed to validate the chain of custody and the seller's authority to
transfer the space would be applicable to a subsequent transfer of the same
space.  (Obviously if such validation fails, such as in the case of
attempted fraud, the fee would still be non-refundable.)

-Scott

On Tue, Sep 6, 2016 at 10:36 PM, Mike Burns <mike at iptrading.com> wrote:

> Jason wrote:
>
>
>
> Currently it is the recipient that pays the transfer fee.  Will that still
> be true and if so
>
> can you clarify that language?
>
>
>
>
>
> Hi Jason,
>
>
>
> Currently the recipient pays except for 8.4 transfers.
>
> ARIN requests the transfer fee from SELLER before the transfer is sent to
> the recipient registry in those cases.
>
> For inbound 8.4 transfers, the ARIN recipient pays the ARIN fee.
>
>
>
> For a /24 sold from ARIN to APNIC or vice versa, the transfer fees total
> $500 from ARIN and $161 from APNIC, or $661. In this case transfer fees
> represent a whopping $2.60 per address, or almost a quarter of the cost of
> the addresses themselves. Considering that the number of small transfers is
> greater than large transfers, and in light of current ARIN reserve$, I
> suggest reducing the transfer fee for small blocks, or indexing the fee to
> the transfer size in a way that maintains overall current transfer revenue
> numbers.
>
>
>
> John says 1 in 4 transfers fail. I guess a substantial number are largish
> blocks that fail as a result of nefarious activity involved in claiming old
> blocks and selling them. The incentives for this behavior are less for
> small block sales. Can we get a breakdown of failure rates by transfer size?
>
>
>
> Ripe charges no transfer fee. APNIC charges a fee tied to the transfer
> size. LACNIC charges $200 upfront, and $1300 before the transfer
> completes.  As part of the consideration about making the $500 upfront and
> non-refundable, are we able to discuss the transfer fee generally?
>
>
>
>
>
> Regards,
>
> Mike
>
>
>
>
>
>
>
> *From:* arin-consult-bounces at arin.net [mailto:arin-consult-bounces@
> arin.net] *On Behalf Of *Jason Schiller
> *Sent:* Tuesday, September 06, 2016 3:27 PM
> *To:* ARIN <info at arin.net>
> *Cc:* arin-consult at arin.net
> *Subject:* Re: [ARIN-consult] Consultation on Transfer Fees Now Open
>
>
>
> Can you clarify who is required to pay the fee, the source or the
> recipient?
>
>
>
> From the wording it sounds like if the source does not have an RSA then
> the source
>
> must pay the fee when the transfer is initiated.
>
>
>
> Currently it is the recipient that pays the transfer fee.  Will that still
> be true and if so
>
> can you clarify that language?
>
>
>
> __Jason
>
>
>
> On Thu, Sep 1, 2016 at 3:39 PM, ARIN <info at arin.net> wrote:
>
> During its recent meeting held on 23 August 2016, the ARIN Board of
> Trustees considered a change to the fee schedule as it pertains to both
> Number Resource Policy Manual (NRPM) section 8.3 and 8.4 transfers
> (https://www.arin.net/policy/nrpm.html#eight3).
>
> Currently about 25% of ARIN transfer request processing results in an
> unsuccessful outcome, i.e. in 1 out of 4 requests, the transfer is
> either abandoned or not approved. When transfer requests are
> unsuccessful, ARIN incurs essentially the same processing costs as it
> does for successful transfers.
>
> To appropriately recover these costs, ARIN proposes collecting the
> present $500 Resource Transfer fee at the beginning of the transfer
> process as a non-refundable transfer processing fee. This fee would be
> only be applicable to source organizations which do not have a
> Registration Services Agreement (RSA) or Legacy Registration Services
> Agreement (LRSA) when an 8.3 or 8.4 transfer request is submitted. This
> fee change would replace the $500 Resource Transfer fee
> (https://www.arin.net/fees/fee_schedule.html) that is currently
> collected at the end of the transfer process for approved requests.
>
> We are seeking community feedback on this modification to ARIN?s Fee
> schedule.
>
> This consultation will remain open for (30) days, after which a summary
> will be provided to the Board of Trustees for their consideration.
>
> Discussion on arin-consult at arin.net will close on 30 September 2016.
>
> If you have any questions, please contact us at info at arin.net.
>
> Regards,
>
> John Curran
> President and CEO
> American Registry for Internet Numbers (ARIN)
>
>
>
> _______________________________________________
> ARIN-Consult
> You are receiving this message because you are subscribed to the ARIN
> Consult Mailing
> List (ARIN-consult at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-consult Please contact the
> ARIN Member Services
> Help Desk at info at arin.net if you experience any issues.
>
>
>
>
>
> --
>
> _______________________________________________________
>
> Jason Schiller|NetOps|jschiller at google.com|571-266-0006
>
>
>
> _______________________________________________
> ARIN-Consult
> You are receiving this message because you are subscribed to the ARIN
> Consult Mailing
> List (ARIN-consult at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-consult Please contact the
> ARIN Member Services
> Help Desk at info at arin.net if you experience any issues.
>
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160906/2327f0a3/attachment.html>

From jcurran at arin.net  Tue Sep  6 16:53:51 2016
From: jcurran at arin.net (John Curran)
Date: Tue, 6 Sep 2016 20:53:51 +0000
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
Message-ID: <47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>


On Sep 6, 2016, at 4:03 PM, David R Huberman <daveid at panix.com<mailto:daveid at panix.com>> wrote:

John,

Thank you for putting this out for community consultation. I think this is a fairly big shift in both thinking and fees, and it is good that the Board is asking for input.

To provide that input, however, I would like to see more data to have a better understanding of the proposed changes.

Baseline data we already know:

- Audited finncials from last year report $31.8M in reserve.

- FY16 budget is $21.7M

- FY16 revenue is projected at $18.8M (a ~$2.9M deficit)

- The audited financials for FY15 show $276,500 in revenue under "Network
transfers"

Questions that come to mind, to try and be informed:

- assuming this was in place Jan 1, what would the projected revenue be for transfers in FY17?

- what assumptions were made to get to this projection?

David -

Approximately 25% of the transfers do not complete (and therefore fees are not collected)
Per https://www.arin.net/knowledge/statistics/transfers.html, 425 blocks address blocks have
been transferred in the first half of 2016.

Expected Fees collected: 425 * $500 = approximately $212.5 thousand, which annualized
(presuming second half of 2016 resembles the first half) should total about $425 thousand.

Note - this does not consider fees waived for parties who already have resources under
registration services agreement, but that is a small portion either way (i.e.most transfers
are legacy resources)

If 2017 resembles 2016, the revenue from transfers would be $425 thousand, absent
any changes.  If the fee change is made, approximately 33% more revenue would be
collected over FY2017 - an additional $146.6 thousand (total $566.6 thousand)

We presently see transfer processing taking an increasing amount of staff time, and
hence proposed the change to avoid having some of these additional costs (particularly
from those who may not make requests fully in good faith) from being absorbed by the
community at large.   One additional benefit is that we?ll be able to more quickly complete
transfers, as presently and approved transfer goes back into the financial side of the house
until the fee collection is complete, and with the change we will instead be able to directly
proceed with the registry update.

Please let me know if you have any further questions - Thanks!
/John

John Curran
President and CEO
ARIN



-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160906/65532aa0/attachment.html>

From mike at iptrading.com  Tue Sep  6 16:59:09 2016
From: mike at iptrading.com (Mike Burns)
Date: Tue, 6 Sep 2016 16:59:09 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <CAGkMwz55bBvPs5wru8bG1k_j=S3sRRyCoBK4Pb+sP1N1qVmEhw@mail.gmail.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>	<CAC4yj2Wo86LSV-GZotj0mi30Jjnqj4UCLowtstGtLDGjCY50PQ@mail.gmail.com>	<011101d2087e$5935df50$0ba19df0$@iptrading.com>
	<CAGkMwz55bBvPs5wru8bG1k_j=S3sRRyCoBK4Pb+sP1N1qVmEhw@mail.gmail.com>
Message-ID: <013601d20881$83520680$89f61380$@iptrading.com>

Hi Scott,

 

Yes, and ARIN charges $100 to do this now as part of the STLS seller-listing process.

Sellers can get prequalified and then choose not to be listed on the STLS if they wish.

If prequalified, they can sell in whole or in parts without further need for vetting.

 

Regards,

Mike

 

 

From: arin-consult-bounces at arin.net [mailto:arin-consult-bounces at arin.net] On Behalf Of Scott Leibrand
Sent: Tuesday, September 06, 2016 4:44 PM
To: arin-consult at arin.net
Subject: Re: [ARIN-consult] Consultation on Transfer Fees Now Open

 

It might be worthwhile to consider the transfer fee on the seller to be a fee for seller "prequalification", not tied to a particular recipient or transfer transaction, but rather to the block(s) being transferred.  If a transfer transaction falls through, the same work ARIN has already performed to validate the chain of custody and the seller's authority to transfer the space would be applicable to a subsequent transfer of the same space.  (Obviously if such validation fails, such as in the case of attempted fraud, the fee would still be non-refundable.)

 

-Scott

 

On Tue, Sep 6, 2016 at 10:36 PM, Mike Burns <mike at iptrading.com <mailto:mike at iptrading.com> > wrote:

Jason wrote:

 

Currently it is the recipient that pays the transfer fee.  Will that still be true and if so

can you clarify that language?

 

 

Hi Jason,

 

Currently the recipient pays except for 8.4 transfers.

ARIN requests the transfer fee from SELLER before the transfer is sent to the recipient registry in those cases.

For inbound 8.4 transfers, the ARIN recipient pays the ARIN fee.

 

For a /24 sold from ARIN to APNIC or vice versa, the transfer fees total $500 from ARIN and $161 from APNIC, or $661. In this case transfer fees represent a whopping $2.60 per address, or almost a quarter of the cost of the addresses themselves. Considering that the number of small transfers is greater than large transfers, and in light of current ARIN reserve$, I suggest reducing the transfer fee for small blocks, or indexing the fee to the transfer size in a way that maintains overall current transfer revenue numbers. 

 

John says 1 in 4 transfers fail. I guess a substantial number are largish blocks that fail as a result of nefarious activity involved in claiming old blocks and selling them. The incentives for this behavior are less for small block sales. Can we get a breakdown of failure rates by transfer size?

 

Ripe charges no transfer fee. APNIC charges a fee tied to the transfer size. LACNIC charges $200 upfront, and $1300 before the transfer completes.  As part of the consideration about making the $500 upfront and non-refundable, are we able to discuss the transfer fee generally?

 

 

Regards,

Mike

 

 

 

From: arin-consult-bounces at arin.net <mailto:arin-consult-bounces at arin.net>  [mailto:arin-consult-bounces at arin.net <mailto:arin-consult-bounces at arin.net> ] On Behalf Of Jason Schiller
Sent: Tuesday, September 06, 2016 3:27 PM
To: ARIN <info at arin.net <mailto:info at arin.net> >
Cc: arin-consult at arin.net <mailto:arin-consult at arin.net> 
Subject: Re: [ARIN-consult] Consultation on Transfer Fees Now Open

 

Can you clarify who is required to pay the fee, the source or the recipient?

 

>From the wording it sounds like if the source does not have an RSA then the source

must pay the fee when the transfer is initiated.  

 

Currently it is the recipient that pays the transfer fee.  Will that still be true and if so

can you clarify that language?

 

__Jason

 

On Thu, Sep 1, 2016 at 3:39 PM, ARIN <info at arin.net <mailto:info at arin.net> > wrote:

During its recent meeting held on 23 August 2016, the ARIN Board of
Trustees considered a change to the fee schedule as it pertains to both
Number Resource Policy Manual (NRPM) section 8.3 and 8.4 transfers
(https://www.arin.net/policy/nrpm.html#eight3).

Currently about 25% of ARIN transfer request processing results in an
unsuccessful outcome, i.e. in 1 out of 4 requests, the transfer is
either abandoned or not approved. When transfer requests are
unsuccessful, ARIN incurs essentially the same processing costs as it
does for successful transfers.

To appropriately recover these costs, ARIN proposes collecting the
present $500 Resource Transfer fee at the beginning of the transfer
process as a non-refundable transfer processing fee. This fee would be
only be applicable to source organizations which do not have a
Registration Services Agreement (RSA) or Legacy Registration Services
Agreement (LRSA) when an 8.3 or 8.4 transfer request is submitted. This
fee change would replace the $500 Resource Transfer fee
(https://www.arin.net/fees/fee_schedule.html) that is currently
collected at the end of the transfer process for approved requests.

We are seeking community feedback on this modification to ARIN?s Fee
schedule.

This consultation will remain open for (30) days, after which a summary
will be provided to the Board of Trustees for their consideration.

Discussion on arin-consult at arin.net <mailto:arin-consult at arin.net>  will close on 30 September 2016.

If you have any questions, please contact us at info at arin.net <mailto:info at arin.net> .

Regards,

John Curran
President and CEO
American Registry for Internet Numbers (ARIN)



_______________________________________________
ARIN-Consult
You are receiving this message because you are subscribed to the ARIN Consult Mailing
List (ARIN-consult at arin.net <mailto:ARIN-consult at arin.net> ).
Unsubscribe or manage your mailing list subscription at:
http://lists.arin.net/mailman/listinfo/arin-consult Please contact the ARIN Member Services
Help Desk at info at arin.net <mailto:info at arin.net>  if you experience any issues.





 

-- 

_______________________________________________________

Jason Schiller|NetOps|jschiller at google.com <mailto:jschiller at google.com> |571-266-0006 <tel:571-266-0006> 

 


_______________________________________________
ARIN-Consult
You are receiving this message because you are subscribed to the ARIN Consult Mailing
List (ARIN-consult at arin.net <mailto:ARIN-consult at arin.net> ).
Unsubscribe or manage your mailing list subscription at:
http://lists.arin.net/mailman/listinfo/arin-consult Please contact the ARIN Member Services
Help Desk at info at arin.net <mailto:info at arin.net>  if you experience any issues.

 

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160906/dc50349c/attachment.html>

From jcurran at arin.net  Tue Sep  6 17:07:39 2016
From: jcurran at arin.net (John Curran)
Date: Tue, 6 Sep 2016 21:07:39 +0000
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <011101d2087e$5935df50$0ba19df0$@iptrading.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<CAC4yj2Wo86LSV-GZotj0mi30Jjnqj4UCLowtstGtLDGjCY50PQ@mail.gmail.com>
	<011101d2087e$5935df50$0ba19df0$@iptrading.com>
Message-ID: <753DEA67-EA65-4396-AE56-05C50462BC10@corp.arin.net>

On Sep 6, 2016, at 4:36 PM, Mike Burns <mike at iptrading.com<mailto:mike at iptrading.com>> wrote:

Currently the recipient pays except for 8.4 transfers.
ARIN requests the transfer fee from SELLER before the transfer is sent to the recipient registry in those cases.
For inbound 8.4 transfers, the ARIN recipient pays the ARIN fee.

Mike -

This is correct, and the proposed transfer fee change would be make the fee process for
transfers within the region be consistent with transfers going out of region (i.e. the source
paying the transfer fee.)

For a /24 sold from ARIN to APNIC or vice versa, the transfer fees total $500 from ARIN and $161 from APNIC, or $661. In this case transfer fees represent a whopping $2.60 per address, or almost a quarter of the cost of the addresses themselves.

True, although the work required is substantially the same regardless of block size...

Considering that the number of small transfers is greater than large transfers, and in light of current ARIN reserve$, I suggest reducing the transfer fee for small blocks, or indexing the fee to the transfer size in a way that maintains overall current transfer revenue numbers.  John says 1 in 4 transfers fail. I guess a substantial number are largish blocks that fail as a result of nefarious activity involved in claiming old blocks and selling them. The incentives for this behavior are less for small block sales. Can we get a breakdown of failure rates by transfer size?

We may not be able to automatically generate such, but even so, we should be able to
manually assemble such data for review.   I shall look into this and report back shortly.

Ripe charges no transfer fee. APNIC charges a fee tied to the transfer size. LACNIC charges $200 upfront, and $1300 before the transfer completes.

While I do recognize the potential interest in fees charged in other regions, I must ask
that folks focus as much as possible on what fees they feel are appropriate for ARIN to
charge.

As part of the consideration about making the $500 upfront and non-refundable, are we able to discuss the transfer fee generally?

Certainly!  (If were to say otherwise, one could simply submit a suggestion to the ARIN
Consultation and Suggestion Process <https://www.arin.net/participate/acsp/acsp.html>,
which would result in another discussion thread on this mailing list; i.e. let us save time
and presume that the transfer fees in general are a fine topic for discussion here.)

Thanks!
/John

John Curran
President and CEO
ARIN



-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160906/f05c9e13/attachment.html>

From mike at iptrading.com  Tue Sep  6 17:24:20 2016
From: mike at iptrading.com (Mike Burns)
Date: Tue, 6 Sep 2016 17:24:20 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <753DEA67-EA65-4396-AE56-05C50462BC10@corp.arin.net>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<CAC4yj2Wo86LSV-GZotj0mi30Jjnqj4UCLowtstGtLDGjCY50PQ@mail.gmail.com>
	<011101d2087e$5935df50$0ba19df0$@iptrading.com>
	<753DEA67-EA65-4396-AE56-05C50462BC10@corp.arin.net>
Message-ID: <014d01d20885$081b5fd0$18521f70$@iptrading.com>

Hi John,

 

In that case I would like to suggest indexing the transfer fee to the size
of the block transferred.

Perhaps the algorithm for this indexing could be adjusted to yield 1.33
times current transfer fee revenue.

In this way we don't have to make transfer fees payable upfront and
non-refundable.

 

It will be harder for us brokers to get sellers to fork over a
non-refundable transfer fee, since the transfer failure could easily be the
fault of the buyer, and what seller wants to risk $500 in that case? Buyer
may or may not be able to justify, should the seller be financing the
buyer's justification test?

 

When we brokers get the buyer to pay all transfer fees, he might cavil over
the fact that the failure cause could be the seller. Maybe the seller is
just using the buyer to finance his quest to get ARIN to recognize his
rights?

 

Yes, buyers can get pre-authorized, and sellers can get pre-authorized for
$100, so there are workarounds. But in general I am against this change to
non-refundable fees, and would prefer any shortfall to come from higher fees
on larger blocks.

 

I also think that overall it is more fair to charge more for larger block
transfers, even when the staff time is similar.

 

Regards,

Mike

 

 

From: John Curran [mailto:jcurran at arin.net] 
Sent: Tuesday, September 06, 2016 5:08 PM
To: Mike Burns <mike at iptrading.com>
Cc: ARIN <info at arin.net>; <arin-consult at arin.net> <arin-consult at arin.net>
Subject: Re: [ARIN-consult] Consultation on Transfer Fees Now Open

 

On Sep 6, 2016, at 4:36 PM, Mike Burns <mike at iptrading.com
<mailto:mike at iptrading.com> > wrote:

 

Currently the recipient pays except for 8.4 transfers.

ARIN requests the transfer fee from SELLER before the transfer is sent to
the recipient registry in those cases.

For inbound 8.4 transfers, the ARIN recipient pays the ARIN fee.

 

Mike - 

 

This is correct, and the proposed transfer fee change would be make the fee
process for

transfers within the region be consistent with transfers going out of region
(i.e. the source

paying the transfer fee.)

 

For a /24 sold from ARIN to APNIC or vice versa, the transfer fees total
$500 from ARIN and $161 from APNIC, or $661. In this case transfer fees
represent a whopping $2.60 per address, or almost a quarter of the cost of
the addresses themselves. 

 

True, although the work required is substantially the same regardless of
block size...

 

Considering that the number of small transfers is greater than large
transfers, and in light of current ARIN reserve$, I suggest reducing the
transfer fee for small blocks, or indexing the fee to the transfer size in a
way that maintains overall current transfer revenue numbers.  John says 1 in
4 transfers fail. I guess a substantial number are largish blocks that fail
as a result of nefarious activity involved in claiming old blocks and
selling them. The incentives for this behavior are less for small block
sales. Can we get a breakdown of failure rates by transfer size?

 

We may not be able to automatically generate such, but even so, we should be
able to 

manually assemble such data for review.   I shall look into this and report
back shortly. 

 

Ripe charges no transfer fee. APNIC charges a fee tied to the transfer size.
LACNIC charges $200 upfront, and $1300 before the transfer completes. 

 

While I do recognize the potential interest in fees charged in other
regions, I must ask 

that folks focus as much as possible on what fees they feel are appropriate
for ARIN to 

charge. 





As part of the consideration about making the $500 upfront and
non-refundable, are we able to discuss the transfer fee generally?

 

Certainly!  (If were to say otherwise, one could simply submit a suggestion
to the ARIN 

Consultation and Suggestion Process
<https://www.arin.net/participate/acsp/acsp.html>,

which would result in another discussion thread on this mailing list; i.e.
let us save time 

and presume that the transfer fees in general are a fine topic for
discussion here.) 

 

Thanks!

/John

 

John Curran

President and CEO

ARIN

 

 

 

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160906/069dff71/attachment.html>

From marty at akamai.com  Tue Sep  6 17:38:41 2016
From: marty at akamai.com (Hannigan, Martin)
Date: Tue, 6 Sep 2016 21:38:41 +0000
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <014d01d20885$081b5fd0$18521f70$@iptrading.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<CAC4yj2Wo86LSV-GZotj0mi30Jjnqj4UCLowtstGtLDGjCY50PQ@mail.gmail.com>
	<011101d2087e$5935df50$0ba19df0$@iptrading.com>
	<753DEA67-EA65-4396-AE56-05C50462BC10@corp.arin.net>,
	<014d01d20885$081b5fd0$18521f70$@iptrading.com>
Message-ID: <3875090B-D70E-4733-BB49-42716404E93F@akamai.com>



On Sep 6, 2016, at 17:24, Mike Burns <mike at iptrading.com<mailto:mike at iptrading.com>> wrote:

Hi John,

In that case I would like to suggest indexing the transfer fee to the size of the block transferred.
Perhaps the algorithm for this indexing could be adjusted to yield 1.33 times current transfer fee revenue.
In this way we don't have to make transfer fees payable upfront and non-refundable.


A % would work and be fair.  It also supports aggregation if applied per block -and split net neutral.


It will be harder for us brokers to get sellers to fork over a non-refundable transfer fee, since the transfer failure could easily be the fault of the buyer, and what seller wants to risk $500 in that case? Buyer may or may not be able to justify, should the seller be financing the buyer's justification test?


Split fees align interests here too.


When we brokers get the buyer to pay all transfer fees, he might cavil over the fact that the failure cause could be the seller. Maybe the seller is just using the buyer to finance his quest to get ARIN to recognize his rights?


[..]


Yes, buyers can get pre-authorized, and sellers can get pre-authorized for $100, so there are workarounds. But in general I am against this change to non-refundable fees, and would prefer any shortfall to come from higher fees on larger blocks.


Shouldn't "everyone" be able to "reasonably" ascertain chain of custody pre charge? Brokers could charge research fees and alleviate the members from wasted time.


I also think that overall it is more fair to charge more for larger block transfers, even when the staff time is similar.


%, net neutral split, fairness, alignment.

$0.02

Best,

Marty

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160906/1f25162f/attachment.html>

From farmer at umn.edu  Tue Sep  6 17:43:14 2016
From: farmer at umn.edu (David Farmer)
Date: Tue, 6 Sep 2016 16:43:14 -0500
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
Message-ID: <CAN-Dau2maCLQp+DMMH0Mv-RwjbnBU_nPZ=sa1VKUi_7oz-54_A@mail.gmail.com>

On Tue, Sep 6, 2016 at 3:53 PM, John Curran <jcurran at arin.net> wrote:

>
> David -
>
> Approximately 25% of the transfers do not complete (and therefore fees are
> not collected)
> Per https://www.arin.net/knowledge/statistics/transfers.html, 425 blocks
> address blocks have
> been transferred in the first half of 2016.
>

John,

Regarding the approximately 25% of the transfers that fail, can you
categorise them a bit?  Especially, are the failures caused on the source
or the recipient side?  But also, are these pre-qualifications or full
attempts at transfer?  Are registered transfer agents involved or not?  Are
the source, recipient, both, or neither, currently party to an RSA and
therefore paying maintenance fees at some level?

Thanks


> Please let me know if you have any further questions - Thanks!
> /John
>
> John Curran
> President and CEO
> ARIN
>
>
>
>
> _______________________________________________
> ARIN-Consult
> You are receiving this message because you are subscribed to the ARIN
> Consult Mailing
> List (ARIN-consult at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-consult Please contact the
> ARIN Member Services
> Help Desk at info at arin.net if you experience any issues.
>



-- 
===============================================
David Farmer               Email:farmer at umn.edu
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SE        Phone: 612-626-0815
Minneapolis, MN 55414-3029   Cell: 612-812-9952
===============================================
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160906/b07cac44/attachment.html>

From daveid at panix.com  Tue Sep  6 17:44:18 2016
From: daveid at panix.com (David R Huberman)
Date: Tue, 6 Sep 2016 17:44:18 -0400 (EDT)
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
Message-ID: <Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>

Hello John,

Thank you for the reply.

If we accept the fundamental idea that ARIN should be charging on a cost 
recovery basis, it seems fair that if ARIN staff are spending more time on 
transfers, and 25% of transfer tickets are not having their costs covered, 
that ARIN should change things around. So conceptually, I support the idea 
being proposed.

But the real numbers are less persuasive than the concepts.  We're talking 
a difference of just about $125,000.  Which is 6 tenths of a percent of 
ARIN's budget.

I therefore OPPOSE this change, as the wrinkles it introduces into an 
opaque and volatile IPv4 address market are scarier than the thought of 
ARIN not recovering an extra $125,000 next year.

Thank you,
David








From paul at egate.net  Tue Sep  6 21:24:15 2016
From: paul at egate.net (Paul Andersen)
Date: Tue, 6 Sep 2016 21:24:15 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
Message-ID: <fa0ed8a3-ec03-49b4-b2b7-27a5c04eaa49@egate.net>


David,

The motivation here was not about increasing our overall revenues but 
rather dealing with what was seen as an area where a non-negligible 
number of requests were not being covered by a transaction fee or a 
subscription plan. Having requests abandoned has obviously been 
something that has occurred regularly on all types of requests through 
ARIN history. The relatively small number of those abandoned requests 
made status quo acceptable; however, in this case the view was the 
number of abandoned requests combined with a non-negligible amount of 
work being done per request could not be ignored.

The overall fees are something I believe the Board is committed to 
continuing to review periodically and where it deems necessary adjust to 
provide for an equitable, cost-recovery process,

With that in mind thank you to all who have commented and I hope 
continue to comment to provide the Board with valuable community 
feedback. It is very helpful in our decision process.

Cheers,

Paul

---
Paul Andersen
Chair, Board of Trustees
ARIN

> On Sep 6, 2016, at 5:44 PM, David R Huberman <daveid at panix.com> wrote:
>
> Hello John,
>
> Thank you for the reply.
>
> If we accept the fundamental idea that ARIN should be charging on a 
> cost recovery basis, it seems fair that if ARIN staff are spending 
> more time on transfers, and 25% of transfer tickets are not having 
> their costs covered, that ARIN should change things around. So 
> conceptually, I support the idea being proposed.
>
> But the real numbers are less persuasive than the concepts.  We're 
> talking a difference of just about $125,000.  Which is 6 tenths of a 
> percent of ARIN's budget.
>
> I therefore OPPOSE this change, as the wrinkles it introduces into an 
> opaque and volatile IPv4 address market are scarier than the thought 
> of ARIN not recovering an extra $125,000 next year.
>
> Thank you,
> David
>


-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160906/1e96635a/attachment.html>

From jcurran at arin.net  Wed Sep  7 06:41:45 2016
From: jcurran at arin.net (John Curran)
Date: Wed, 7 Sep 2016 10:41:45 +0000
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <3875090B-D70E-4733-BB49-42716404E93F@akamai.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<CAC4yj2Wo86LSV-GZotj0mi30Jjnqj4UCLowtstGtLDGjCY50PQ@mail.gmail.com>
	<011101d2087e$5935df50$0ba19df0$@iptrading.com>
	<753DEA67-EA65-4396-AE56-05C50462BC10@corp.arin.net>
	<014d01d20885$081b5fd0$18521f70$@iptrading.com>
	<3875090B-D70E-4733-BB49-42716404E93F@akamai.com>
Message-ID: <CD4BC1EE-1BAE-47E2-A9AD-D0A0003C9D65@arin.net>

On Sep 6, 2016, at 5:38 PM, Hannigan, Martin <marty at akamai.com<mailto:marty at akamai.com>> wrote:
On Sep 6, 2016, at 17:24, Mike Burns <mike at iptrading.com<mailto:mike at iptrading.com>> wrote:

Hi John,

In that case I would like to suggest indexing the transfer fee to the size of the block transferred.
Perhaps the algorithm for this indexing could be adjusted to yield 1.33 times current transfer fee revenue.
In this way we don?t have to make transfer fees payable upfront and non-refundable.


A % would work and be fair.  It also supports aggregation if applied per block -and split net neutral.

Prorating the transfer fee would is ?fair? to the extent that it is deemed
appropriate to change prorated to the value of the transaction to the
parties.  If the goal is recovery based on costs incurred by ARIN, then
flat fees are more fair.

For a real world example, consider processing fees for various auto
and property registration transactions.   Title transfer is generally a
fixed processing fee and not discounted for transfer of less worthy
assets.   (This doesn?t consider that some states _tax_ transactions
in addition and on a percentage basis, but that is an entirely different
aspect.)   States registries generally do flat-rate for transactions because
it is deemed inherently fair based on their processing costs, not because
they intend to discourage the sales of inexpensive automobiles.

If folks want variable fees for different sizes, that can be done;
I would only caution that use of the term ?fair? for describing
such an sized-index fee schedule is quite a subjective matter.

Shouldn't "everyone" be able to "reasonably" ascertain chain of custody pre charge? Brokers could charge research fees and alleviate the members from wasted time.

Most brokers do research these materials, and that speeds up the processing
(since documentation is readily available when ARIN requests such) but that
does not preclude ARIN having to carefully review these materials to confirm
veracity and prevent anyone from hijacking blocks via creative requests...

Thanks!
/John

John Curran
President and CEO
ARIN

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160907/72486783/attachment.html>

From marty at akamai.com  Wed Sep  7 10:14:41 2016
From: marty at akamai.com (Hannigan, Martin)
Date: Wed, 7 Sep 2016 14:14:41 +0000
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <CD4BC1EE-1BAE-47E2-A9AD-D0A0003C9D65@arin.net>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<CAC4yj2Wo86LSV-GZotj0mi30Jjnqj4UCLowtstGtLDGjCY50PQ@mail.gmail.com>
	<011101d2087e$5935df50$0ba19df0$@iptrading.com>
	<753DEA67-EA65-4396-AE56-05C50462BC10@corp.arin.net>
	<014d01d20885$081b5fd0$18521f70$@iptrading.com>
	<3875090B-D70E-4733-BB49-42716404E93F@akamai.com>
	<CD4BC1EE-1BAE-47E2-A9AD-D0A0003C9D65@arin.net>
Message-ID: <1A29EBF9-9363-4366-B432-98DA55030E2D@akamai.com>


> On Sep 7, 2016, at 6:41 AM, John Curran <jcurran at arin.net> wrote:
> 
> On Sep 6, 2016, at 5:38 PM, Hannigan, Martin <marty at akamai.com <mailto:marty at akamai.com>> wrote:
>> On Sep 6, 2016, at 17:24, Mike Burns <mike at iptrading.com <mailto:mike at iptrading.com>> wrote:
>> 
>>> 



[ clip ]


> If folks want variable fees for different sizes, that can be done;
> I would only caution that use of the term ?fair? for describing
> such an sized-index fee schedule is quite a subjective matter.
> 

I?m not suggesting variable fees, I?m suggesting a fixed percentage as a way to more equitably distribute fees along with the two sided application to reduce the impact for both parties. In retrospect, that may be neutral in terms of aggregation, but if it?s applied to each transaction, that may be incentive as well.


>> Shouldn't "everyone" be able to "reasonably" ascertain chain of custody pre charge? Brokers could charge research fees and alleviate the members from wasted time.
> 
> Most brokers do research these materials, and that speeds up the processing
> (since documentation is readily available when ARIN requests such) but that
> does not preclude ARIN having to carefully review these materials to confirm
> veracity and prevent anyone from hijacking blocks via creative requests?


True. That?s a risk I think is fair to assign to the brokers. It's a fair trade for the financial gain, to let them be the first line of defense in terms of fraud.


Best,

-M<



-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160907/960a2b82/attachment.html>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: signature.asc
Type: application/pgp-signature
Size: 236 bytes
Desc: Message signed with OpenPGP using GPGMail
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160907/960a2b82/attachment.sig>

From stephen.r.middleton at verizon.com  Wed Sep  7 10:33:36 2016
From: stephen.r.middleton at verizon.com (Middleton, Stephen R)
Date: Wed, 7 Sep 2016 10:33:36 -0400
Subject: [ARIN-consult] [E] Re:  Consultation on Transfer Fees Now Open
In-Reply-To: <Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
Message-ID: <38C55F57BAA85D478C28F59BE4B064CF2E926B4803@FHDP1LUMXC7V22.us.one.verizon.com>

Hello John,

I'm of a similar opinion to David's; the amount not covered is too small to warrant a significant process/policy change.  Particularly if those that might encourage parties to pursue solutions that involve not updating Whois.

I would be interested to know the reasons for abandonment; however.  Are applications being abandoned after failing one of the process validation points; needs, documents, etc.?  If so, then I think the process is working as the community has intended. 

Best Regards,


Stephen R Middleton, Sr.
Global Wireline IP Address Management
Public Data Network Engineering

22001 Loudoun County Parkway; F1-2-277
Ashburn, VA 20147

stephen.r.middleton at one.verizon.com

????

-----Original Message-----
From: arin-consult-bounces at arin.net [mailto:arin-consult-bounces at arin.net] On Behalf Of David R Huberman
Sent: Tuesday, September 06, 2016 5:44 PM
To: John Curran
Cc: arin-consult at arin.net
Subject: [E] Re: [ARIN-consult] Consultation on Transfer Fees Now Open

Hello John,

Thank you for the reply.

If we accept the fundamental idea that ARIN should be charging on a cost recovery basis, it seems fair that if ARIN staff are spending more time on transfers, and 25% of transfer tickets are not having their costs covered, that ARIN should change things around. So conceptually, I support the idea being proposed.

But the real numbers are less persuasive than the concepts.  We're talking a difference of just about $125,000.  Which is 6 tenths of a percent of ARIN's budget.

I therefore OPPOSE this change, as the wrinkles it introduces into an opaque and volatile IPv4 address market are scarier than the thought of ARIN not recovering an extra $125,000 next year.

Thank you,
David






_______________________________________________
ARIN-Consult
You are receiving this message because you are subscribed to the ARIN Consult Mailing List (ARIN-consult at arin.net).
Unsubscribe or manage your mailing list subscription at:
http://lists.arin.net/mailman/listinfo/arin-consult Please contact the ARIN Member Services Help Desk at info at arin.net if you experience any issues.


From jschiller at google.com  Wed Sep  7 11:44:14 2016
From: jschiller at google.com (Jason Schiller)
Date: Wed, 7 Sep 2016 11:44:14 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <1A29EBF9-9363-4366-B432-98DA55030E2D@akamai.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<CAC4yj2Wo86LSV-GZotj0mi30Jjnqj4UCLowtstGtLDGjCY50PQ@mail.gmail.com>
	<011101d2087e$5935df50$0ba19df0$@iptrading.com>
	<753DEA67-EA65-4396-AE56-05C50462BC10@corp.arin.net>
	<014d01d20885$081b5fd0$18521f70$@iptrading.com>
	<3875090B-D70E-4733-BB49-42716404E93F@akamai.com>
	<CD4BC1EE-1BAE-47E2-A9AD-D0A0003C9D65@arin.net>
	<1A29EBF9-9363-4366-B432-98DA55030E2D@akamai.com>
Message-ID: <CAC4yj2VX_cizwkYP2H+CRecj=LcSYKD8aiqXgKSc8rF8jQwqjA@mail.gmail.com>

I am not sure where I stand on this fee in general...

If there is a fee, I do not oppose have a reduced fee for "small"
organizations in order to avoid a processing fee that is a large
portion of the transaction.

I do however oppose a percentage based fee, which may make it more
difficult to calculate and plan for budgets.

I propose you choose a reasonable price for small transaction
(what is reasonable and what is small is debatable but lets say /23 is
small)

Then bump up the flat fee for all other transactions to cover what is lost
from a reduction on the small transfers.

For reference, what is the cost to take an existing legacy resource and
bring it under RSA?

One way to think about this is it is the cost to research the block and
ensure that the resource
holder is the party that claims to hold the block.  Could ARIN offer a
service that would
certify that the claim resource holder is making is certified via ARIN (to
the same extent
as if an RSA was signed) but without signing an RSA?

___Jason


On Wed, Sep 7, 2016 at 10:14 AM, Hannigan, Martin <marty at akamai.com> wrote:

>
> On Sep 7, 2016, at 6:41 AM, John Curran <jcurran at arin.net> wrote:
>
> On Sep 6, 2016, at 5:38 PM, Hannigan, Martin <marty at akamai.com> wrote:
>
> On Sep 6, 2016, at 17:24, Mike Burns <mike at iptrading.com> wrote:
>
>
>
>
>
> [ clip ]
>
>
> If folks want variable fees for different sizes, that can be done;
> I would only caution that use of the term ?fair? for describing
> such an sized-index fee schedule is quite a subjective matter.
>
>
> I?m not suggesting variable fees, I?m suggesting a fixed percentage as a
> way to more equitably distribute fees along with the two sided application
> to reduce the impact for both parties. In retrospect, that may be neutral
> in terms of aggregation, but if it?s applied to each transaction, that may
> be incentive as well.
>
>
> Shouldn't "everyone" be able to "reasonably" ascertain chain of custody
> pre charge? Brokers could charge research fees and alleviate the members
> from wasted time.
>
>
> Most brokers do research these materials, and that speeds up the processing
> (since documentation is readily available when ARIN requests such) but that
> does not preclude ARIN having to carefully review these materials to
> confirm
> veracity and prevent anyone from hijacking blocks via creative requests?
>
>
>
> True. That?s a risk I think is fair to assign to the brokers. It's a fair
> trade for the financial gain, to let them be the first line of defense in
> terms of fraud.
>
>
> Best,
>
> -M<
>
>
>
>
> _______________________________________________
> ARIN-Consult
> You are receiving this message because you are subscribed to the ARIN
> Consult Mailing
> List (ARIN-consult at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-consult Please contact the
> ARIN Member Services
> Help Desk at info at arin.net if you experience any issues.
>



-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160907/4207e0a8/attachment.html>

From mike at iptrading.com  Wed Sep  7 12:01:40 2016
From: mike at iptrading.com (Mike Burns)
Date: Wed, 7 Sep 2016 12:01:40 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <CAC4yj2VX_cizwkYP2H+CRecj=LcSYKD8aiqXgKSc8rF8jQwqjA@mail.gmail.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>	<CAC4yj2Wo86LSV-GZotj0mi30Jjnqj4UCLowtstGtLDGjCY50PQ@mail.gmail.com>	<011101d2087e$5935df50$0ba19df0$@iptrading.com>	<753DEA67-EA65-4396-AE56-05C50462BC10@corp.arin.net>	<014d01d20885$081b5fd0$18521f70$@iptrading.com>	<3875090B-D70E-4733-BB49-42716404E93F@akamai.com>	<CD4BC1EE-1BAE-47E2-A9AD-D0A0003C9D65@arin.net>	<1A29EBF9-9363-4366-B432-98DA55030E2D@akamai.com>
	<CAC4yj2VX_cizwkYP2H+CRecj=LcSYKD8aiqXgKSc8rF8jQwqjA@mail.gmail.com>
Message-ID: <005101d20921$1f286f00$5d794d00$@iptrading.com>

One way to think about this is it is the cost to research the block and ensure that the resource

holder is the party that claims to hold the block.  Could ARIN offer a service that would 

certify that the claim resource holder is making is certified via ARIN (to the same extent

as if an RSA was signed) but without signing an RSA?

 

___Jason  

 

Hi Jason,

 

ARIN already offers this through STLS validation of sellers.

Although ARIN requires STLS sellers who are listed on the STLS to be under RSA, you can get vetted and choose not to be listed.

So you can become vetted as a seller for $100.

 

This is my reading of https://www.arin.net/resources/transfer_listing/#step1 anyway.

We have done this for sellers, but I don?t remember for sure if they were under RSA.

 

Regards,
Mike

 

 

From: arin-consult-bounces at arin.net [mailto:arin-consult-bounces at arin.net] On Behalf Of Jason Schiller
Sent: Wednesday, September 07, 2016 11:44 AM
To: Hannigan, Martin <marty at akamai.com>
Cc: arin-consult at arin.net
Subject: Re: [ARIN-consult] Consultation on Transfer Fees Now Open

 

I am not sure where I stand on this fee in general... 

 

If there is a fee, I do not oppose have a reduced fee for "small" 

organizations in order to avoid a processing fee that is a large 

portion of the transaction.  

 

I do however oppose a percentage based fee, which may make it more 

difficult to calculate and plan for budgets.

 

I propose you choose a reasonable price for small transaction 

(what is reasonable and what is small is debatable but lets say /23 is small)

 

Then bump up the flat fee for all other transactions to cover what is lost

from a reduction on the small transfers.

 

For reference, what is the cost to take an existing legacy resource and bring it under RSA?

 

One way to think about this is it is the cost to research the block and ensure that the resource

holder is the party that claims to hold the block.  Could ARIN offer a service that would 

certify that the claim resource holder is making is certified via ARIN (to the same extent

as if an RSA was signed) but without signing an RSA?

 

___Jason  

 

 

On Wed, Sep 7, 2016 at 10:14 AM, Hannigan, Martin <marty at akamai.com <mailto:marty at akamai.com> > wrote:

 

On Sep 7, 2016, at 6:41 AM, John Curran <jcurran at arin.net <mailto:jcurran at arin.net> > wrote:

 

On Sep 6, 2016, at 5:38 PM, Hannigan, Martin <marty at akamai.com <mailto:marty at akamai.com> > wrote:

On Sep 6, 2016, at 17:24, Mike Burns < <mailto:mike at iptrading.com> mike at iptrading.com> wrote:

 

 

 

 

 

[ clip ]

 

 

If folks want variable fees for different sizes, that can be done; 

I would only caution that use of the term ?fair? for describing 

such an sized-index fee schedule is quite a subjective matter.

 

 

I?m not suggesting variable fees, I?m suggesting a fixed percentage as a way to more equitably distribute fees along with the two sided application to reduce the impact for both parties. In retrospect, that may be neutral in terms of aggregation, but if it?s applied to each transaction, that may be incentive as well.

 





Shouldn't "everyone" be able to "reasonably" ascertain chain of custody pre charge? Brokers could charge research fees and alleviate the members from wasted time. 

 

Most brokers do research these materials, and that speeds up the processing

(since documentation is readily available when ARIN requests such) but that

does not preclude ARIN having to carefully review these materials to confirm

veracity and prevent anyone from hijacking blocks via creative requests?

 

 

True. That?s a risk I think is fair to assign to the brokers. It's a fair trade for the financial gain, to let them be the first line of defense in terms of fraud. 

 

 

Best,

 

-M<

 

 

 


_______________________________________________
ARIN-Consult
You are receiving this message because you are subscribed to the ARIN Consult Mailing
List (ARIN-consult at arin.net <mailto:ARIN-consult at arin.net> ).
Unsubscribe or manage your mailing list subscription at:
http://lists.arin.net/mailman/listinfo/arin-consult Please contact the ARIN Member Services
Help Desk at info at arin.net <mailto:info at arin.net>  if you experience any issues.





 

-- 

_______________________________________________________

Jason Schiller|NetOps|jschiller at google.com <mailto:jschiller at google.com> |571-266-0006

 

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160907/860063d7/attachment.html>

From marty at akamai.com  Wed Sep  7 12:34:36 2016
From: marty at akamai.com (Hannigan, Martin)
Date: Wed, 7 Sep 2016 16:34:36 +0000
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <CAC4yj2VX_cizwkYP2H+CRecj=LcSYKD8aiqXgKSc8rF8jQwqjA@mail.gmail.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<CAC4yj2Wo86LSV-GZotj0mi30Jjnqj4UCLowtstGtLDGjCY50PQ@mail.gmail.com>
	<011101d2087e$5935df50$0ba19df0$@iptrading.com>
	<753DEA67-EA65-4396-AE56-05C50462BC10@corp.arin.net>
	<014d01d20885$081b5fd0$18521f70$@iptrading.com>
	<3875090B-D70E-4733-BB49-42716404E93F@akamai.com>
	<CD4BC1EE-1BAE-47E2-A9AD-D0A0003C9D65@arin.net>
	<1A29EBF9-9363-4366-B432-98DA55030E2D@akamai.com>,
	<CAC4yj2VX_cizwkYP2H+CRecj=LcSYKD8aiqXgKSc8rF8jQwqjA@mail.gmail.com>
Message-ID: <77F87FF2-2B64-4B12-9CBC-282362488ADA@akamai.com>



> On Sep 7, 2016, at 11:44, Jason Schiller <jschiller at google.com> wrote:
> 
> I am not sure where I stand on this fee in general... 
> 
> If there is a fee, I do not oppose have a reduced fee for "small" 
> organizations in order to avoid a processing fee that is a large 
> portion of the transaction.  
> 
> I do however oppose a percentage based fee, which may make it more 
> difficult to calculate and plan for budgets.

A budget is a bucket of top and bottom line costs e.g. "IPv4 Addresses and Related Expense". I'm at a loss to explain how a commodity with a variable price is easier to budget for than a transaction fee in the range of (example) 0.0000002% per party per transaction. 

I wouldn't be supporting (this type) a fee if I didn't believe it was equitable and was more negligible overall. I believe what's good for smaller parties in this market is also good for the larger ones.

John: There are a number of examples of percentage based fees that also fit the mold like an income tax, excise tax on value, etc. 

Regardless, it's coming from benefits of the sale in one way or another and ARIN shouldn't be shy at all about cost recovery from those parties involved in address transactions.

YMMV, and best,

-M<

From daveid at panix.com  Sun Sep 11 17:20:07 2016
From: daveid at panix.com (David R Huberman)
Date: Sun, 11 Sep 2016 17:20:07 -0400 (EDT)
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
Message-ID: <Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>

John,

Two comments:

1) Would the proposed change -- moving transfer fees to the beginning of 
the process -- assist ARIN staff in stemming significant amount of 
possibly fradulent transfer requests?

2) Instead of assuming the source entity is going to be invoiced, please 
understand that in a 8.3 transfer, there are often 4 parties (source, 
recipient, broker, ARIN), and in a 8.4 transfer, there are at least 5 
parties.  Can ARIN please *ask* the submitter of the transfer request to 
identify the party who will pay the transfer fee, and create an invoice 
accordingly?

Thank you,
David


From jcurran at arin.net  Sun Sep 11 21:22:01 2016
From: jcurran at arin.net (John Curran)
Date: Mon, 12 Sep 2016 01:22:01 +0000
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
	<Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
Message-ID: <4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>

On Sep 11, 2016, at 5:20 PM, David R Huberman <daveid at panix.com> wrote:
> 
> John,
> 
> Two comments:
> 
> 1) Would the proposed change -- moving transfer fees to the beginning of the process -- assist ARIN staff in stemming significant amount of possibly fradulent transfer requests?

David - 

Definitely - we presently have a sizable number of requests made at no cost to the requester
which do not appear to be legitimate, but are initiated speculatively and/or optimistically (i.e. 
in the hope that ARIN won?t detect the attempt at hijacking)   The proposed change is unlikely
to deter bona fide requests (as it does not change the cost of a successful transfer) but could
easily change the economics for ones not made in good faith.

> 2) Instead of assuming the source entity is going to be invoiced, please understand that in a 8.3 transfer, there are often 4 parties (source, recipient, broker, ARIN), and in a 8.4 transfer, there are at least 5 parties.  Can ARIN please *ask* the submitter of the transfer request to identify the party who will pay the transfer fee, and create an invoice accordingly?

Interesting point - I believe this can be done (and will confirm shortly.)

Thanks!
/John

John Curran
President and CEO
ARIN


From rs at seastrom.com  Sun Sep 11 22:22:47 2016
From: rs at seastrom.com (Rob Seastrom)
Date: Sun, 11 Sep 2016 22:22:47 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
	<Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
	<4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
Message-ID: <711803FC-F888-43E0-9EF4-D6C2293E9175@seastrom.com>


> On Sep 11, 2016, at 9:22 PM, John Curran <jcurran at arin.net> wrote:
> 
> On Sep 11, 2016, at 5:20 PM, David R Huberman <daveid at panix.com> wrote:
>> 
>> John,
>> 
>> Two comments:
>> 
>> 1) Would the proposed change -- moving transfer fees to the beginning of the process -- assist ARIN staff in stemming significant amount of possibly fradulent transfer requests?
> 
> David - 
> 
> Definitely - we presently have a sizable number of requests made at no cost to the requester
> which do not appear to be legitimate, but are initiated speculatively and/or optimistically (i.e. 
> in the hope that ARIN won?t detect the attempt at hijacking)   The proposed change is unlikely
> to deter bona fide requests (as it does not change the cost of a successful transfer) but could
> easily change the economics for ones not made in good faith.
> 
>> 2) Instead of assuming the source entity is going to be invoiced, please understand that in a 8.3 transfer, there are often 4 parties (source, recipient, broker, ARIN), and in a 8.4 transfer, there are at least 5 parties.  Can ARIN please *ask* the submitter of the transfer request to identify the party who will pay the transfer fee, and create an invoice accordingly?
> 
> Interesting point - I believe this can be done (and will confirm shortly.)

It seems to me that in order for this to be maximally effective at eliminating the workload associated speculative filings, ARIN would need to not only create an invoice, but delay moving forward with checking the provenance of the number resources in question until after the invoice was paid.  This exercise is reminiscent of the tradeoffs in TCP fast open vs. syn cookies with an eye towards attack surface minimization.

regards,

-r






From farmer at umn.edu  Mon Sep 12 01:13:28 2016
From: farmer at umn.edu (David Farmer)
Date: Mon, 12 Sep 2016 00:13:28 -0500
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <711803FC-F888-43E0-9EF4-D6C2293E9175@seastrom.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
	<Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
	<4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
	<711803FC-F888-43E0-9EF4-D6C2293E9175@seastrom.com>
Message-ID: <CAN-Dau1MjJDrjmy1fgGfSMroLrmw_1Ls5mM_MA5-uY6VG2vKSQ@mail.gmail.com>

On Sun, Sep 11, 2016 at 9:22 PM, Rob Seastrom <rs at seastrom.com> wrote:

>
> > On Sep 11, 2016, at 9:22 PM, John Curran <jcurran at arin.net> wrote:
> >
> > On Sep 11, 2016, at 5:20 PM, David R Huberman <daveid at panix.com> wrote:
> >>
> >> John,
> >>
> >> Two comments:
> >>
> >> 1) Would the proposed change -- moving transfer fees to the beginning
> of the process -- assist ARIN staff in stemming significant amount of
> possibly fradulent transfer requests?
> >
> > David -
> >
> > Definitely - we presently have a sizable number of requests made at no
> cost to the requester
> > which do not appear to be legitimate, but are initiated speculatively
> and/or optimistically (i.e.
> > in the hope that ARIN won?t detect the attempt at hijacking)   The
> proposed change is unlikely
> > to deter bona fide requests (as it does not change the cost of a
> successful transfer) but could
> > easily change the economics for ones not made in good faith.
> >
> >> 2) Instead of assuming the source entity is going to be invoiced,
> please understand that in a 8.3 transfer, there are often 4 parties
> (source, recipient, broker, ARIN), and in a 8.4 transfer, there are at
> least 5 parties.  Can ARIN please *ask* the submitter of the transfer
> request to identify the party who will pay the transfer fee, and create an
> invoice accordingly?
> >
> > Interesting point - I believe this can be done (and will confirm
> shortly.)
>
> It seems to me that in order for this to be maximally effective at
> eliminating the workload associated speculative filings, ARIN would need to
> not only create an invoice, but delay moving forward with checking the
> provenance of the number resources in question until after the invoice was
> paid.  This exercise is reminiscent of the tradeoffs in TCP fast open vs.
> syn cookies with an eye towards attack surface minimization.
>
> regards,
>

I agree transfer fees should be due regardless of the success of the
transfer.  Additionally, I think pre-payment, before any work by ARIN
begins, is a justified when the source resources are not already covered
under an RSA, there seems to be an additional risk of fraud in these
cases.  There is an argument to be made that these changes would increase
the cost to the fraudsters, therefore helping to reduce occurrence of such
fraud, but let's be clear, it won't eliminate fraud.

However, I wonder if the risk of fraud is low enough when the source
resources are already covered under an RSA to allow post-payment instead of
pre-payment, the fees are still due regardless of success of the transfer.
Note: the RSA contract has serious consequences for failure to pay an
invoices, eventually the loss of the resources.

Further, I think some flexibility should be provided allowing the
substitution of the recipient, in cases where failure of the transfer was
due to the recipient's failure to qualify to receive resource.  I think
there should be limits on this flexibility, like maybe two attempted
substitutions within 90 days, more than that the transfer just fails and
the fees are forfeit.  I think this flexibility is justified because the
risk of a failed request in the past has been a community risk.  A
recipient of resources from the free pool was only charged if they
qualified, the failed requests were a community cost.

Finally, if a transfer request can designate the payee, then the payee
should only be allowed post-payment if they have a contract with ARIN and
there are serious consequences for lack of payment, like loss of resources
if the invoice is not paid, otherwise pre-payment should be required.
However, if designation of payee is allow, and a recipient can be
designated, allowing substitution of the recipient seems out of place, and
probably allows a whole in the logic. So, I think we can only have one or
the other of these options, and I think I prefer the payee being the source
with limited recipient substitution over payee designation.

What do others think?

Thanks.

-- 
===============================================
David Farmer               Email:farmer at umn.edu
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SE        Phone: 612-626-0815
Minneapolis, MN 55414-3029   Cell: 612-812-9952
===============================================
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160912/996c961d/attachment.html>

From rs at seastrom.com  Mon Sep 12 06:47:34 2016
From: rs at seastrom.com (Rob Seastrom)
Date: Mon, 12 Sep 2016 06:47:34 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <CAN-Dau1MjJDrjmy1fgGfSMroLrmw_1Ls5mM_MA5-uY6VG2vKSQ@mail.gmail.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
	<Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
	<4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
	<711803FC-F888-43E0-9EF4-D6C2293E9175@seastrom.com>
	<CAN-Dau1MjJDrjmy1fgGfSMroLrmw_1Ls5mM_MA5-uY6VG2vKSQ@mail.gmail.com>
Message-ID: <F0536D5E-8EA8-4DBE-BAC9-1CFEA76F65EC@seastrom.com>


> On Sep 12, 2016, at 1:13 AM, David Farmer <farmer at umn.edu> wrote:
> 
> I agree transfer fees should be due regardless of the success of the transfer.  Additionally, I think pre-payment, before any work by ARIN begins, is a justified when the source resources are not already covered under an RSA, there seems to be an additional risk of fraud in these cases.  There is an argument to be made that these changes would increase the cost to the fraudsters, therefore helping to reduce occurrence of such fraud, but let's be clear, it won't eliminate fraud.  
> 
> However, I wonder if the risk of fraud is low enough when the source resources are already covered under an RSA to allow post-payment instead of pre-payment, the fees are still due regardless of success of the transfer.  Note: the RSA contract has serious consequences for failure to pay an invoices, eventually the loss of the resources. 

I kind of feel as if allowing deferred payment for folks with an existing RSA (or tying non-payment of the generated invoice to a sense of "non-payment of fees due ARIN") creates an attack surface against the misfortunate resource holder, not unlike ordering someone a dozen unsolicited pizzas with their own credit card.

I'm in favor of an implementation that requires as little effort on the part of the resource holder in order to reject the beginning of the request (ignore the invoice) as possible.

JC, any thoughts on the potential implementation risk to the resource holder in the form of a DoS attack?

-r







From mike at iptrading.com  Mon Sep 12 10:23:48 2016
From: mike at iptrading.com (Mike Burns)
Date: Mon, 12 Sep 2016 10:23:48 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>	<Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
	<4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
Message-ID: <000f01d20d01$4725be70$d5713b50$@iptrading.com>

> 2) Instead of assuming the source entity is going to be invoiced, please understand that in a 8.3 transfer, there are often 4 parties (source, recipient, broker, ARIN), and in a 8.4 transfer, there are at least 5 parties.  Can ARIN please *ask* the submitter of the transfer request to identify the party who will pay the transfer fee, and create an invoice accordingly?
Interesting point - I believe this can be done (and will confirm shortly.)

Thanks!
/John

John Curran
President and CEO
ARIN


Hi John,

I would like to voice my strong support for this option.

Regards,
Mike




From owen at delong.com  Thu Sep 15 08:57:48 2016
From: owen at delong.com (Owen DeLong)
Date: Thu, 15 Sep 2016 08:57:48 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <000f01d20d01$4725be70$d5713b50$@iptrading.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
	<Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
	<4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
	<000f01d20d01$4725be70$d5713b50$@iptrading.com>
Message-ID: <5FE61D10-1485-4052-AEE9-3ACF7BA74E17@delong.com>

So I?ve been watching this and thinking about the situation. It occurs to me that perhaps we should consider the following:

1.	Open up a pre-approval process for resource suppliers similar to the current pre-approval process
	for requestors.

2.	Set a fee for pre-approval that would apply only to resources being pre-approved which are not already subject
	to an RSA. Ideally, this fee should be nominal, but large enough to discourage abuse of the process.

3.	Charge the same fee for any supplier of transferred resources not covered by RSA, whether at time of request
	or in a pre-approval process.

4.	Possibly provide some mechanism by which entities that wish to do so can have their pre-approved resources marked
	as such in whois and/or STLS.

This fee would be separate from the fee collected for a transfer at the time of the transfer, though that fee could, potentially, be reduced accordingly to reflect the lower cost of transactions involving known resources. In this way, the seller would be responsible for paying the provenance costs and the buyer would be responsible for paying the administrative costs of processing the transfer.

This seems like a good balance to me.

Thoughts?

Owen



From jcurran at arin.net  Thu Sep 15 09:04:22 2016
From: jcurran at arin.net (John Curran)
Date: Thu, 15 Sep 2016 13:04:22 +0000
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <000f01d20d01$4725be70$d5713b50$@iptrading.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
	<Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
	<4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
	<000f01d20d01$4725be70$d5713b50$@iptrading.com>
Message-ID: <6FCD06BB-7F2B-459C-8C93-6704B7869009@arin.net>

On Sep 12, 2016, at 10:23 AM, Mike Burns <mike at iptrading.com> wrote:
> 
>> 2) Instead of assuming the source entity is going to be invoiced, please understand that in a 8.3 transfer, there are often 4 parties (source, recipient, broker, ARIN), and in a 8.4 transfer, there are at least 5 parties.  Can ARIN please *ask* the submitter of the transfer request to identify the party who will pay the transfer fee, and create an invoice accordingly?
> 
> Interesting point - I believe this can be done (and will confirm shortly.)


David, Mike - 
 
   Yes, we can provide this flexibility with respect to the invoicing & payment of the transfer processing fee.

FYI,
/John

John Curran
President and CEO
ARIN




From jschiller at google.com  Thu Sep 15 11:02:02 2016
From: jschiller at google.com (Jason Schiller)
Date: Thu, 15 Sep 2016 11:02:02 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <5FE61D10-1485-4052-AEE9-3ACF7BA74E17@delong.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
	<Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
	<4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
	<000f01d20d01$4725be70$d5713b50$@iptrading.com>
	<5FE61D10-1485-4052-AEE9-3ACF7BA74E17@delong.com>
Message-ID: <CAC4yj2UXwO7uag2B90AFk_jsuL1uV1Ktj8vwMtowv_fXSyDRXA@mail.gmail.com>

Owen,

I like your suggestions, but offer a few friendly amendments.

I think the fee for source block pre-certification should be primarily
based
on the cost to investigate providence of the number space.  Use
that cost as the starting point, and possibly increase the price
if it is not sufficiently high to to discourage abuse of the process.

The research of providence should relate to the entire aggregate
even if only a small portion is considered for transfer.  In other words,
it is a one time resource certification fee for the first transfer out of
the aggregate, and future transfers out of the same aggregate do
not carry an additional fee.


If there are multiple blocks sharing the same providence,
(e.g. company Xyz, Inc. was issues A.B.C.0/20 and D.E.F.0/16.
Company Xyz, Inc. was bought by company Lmno, LLC. and
merged into Newco Inc.) then the fee should cover all of those blocks.

WRT marking, I think it needs to equally apply to resources under RSA or
under pre-certification of providence.  I am agnostic if it needs to be
distinguishable
between RSA and non-RSA pre-certification, or not.

The listing of the providence either needs to be public, or the seller
needs to be
able to get some sort of certified proof from ARIN of its status that can
be used
anonymously by any potential purchaser to verify its authenticity.

I also agree with David, about needing some flexibility in redirecting
payment of these fees.

__Jason






On Thu, Sep 15, 2016 at 8:57 AM, Owen DeLong <owen at delong.com> wrote:

> So I?ve been watching this and thinking about the situation. It occurs to
> me that perhaps we should consider the following:
>
> 1.      Open up a pre-approval process for resource suppliers similar to
> the current pre-approval process
>         for requestors.
>
> 2.      Set a fee for pre-approval that would apply only to resources
> being pre-approved which are not already subject
>         to an RSA. Ideally, this fee should be nominal, but large enough
> to discourage abuse of the process.
>
> 3.      Charge the same fee for any supplier of transferred resources not
> covered by RSA, whether at time of request
>         or in a pre-approval process.
>
> 4.      Possibly provide some mechanism by which entities that wish to do
> so can have their pre-approved resources marked
>         as such in whois and/or STLS.
>
> This fee would be separate from the fee collected for a transfer at the
> time of the transfer, though that fee could, potentially, be reduced
> accordingly to reflect the lower cost of transactions involving known
> resources. In this way, the seller would be responsible for paying the
> provenance costs and the buyer would be responsible for paying the
> administrative costs of processing the transfer.
>
> This seems like a good balance to me.
>
> Thoughts?
>
> Owen
>
> _______________________________________________
> ARIN-Consult
> You are receiving this message because you are subscribed to the ARIN
> Consult Mailing
> List (ARIN-consult at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-consult Please contact the
> ARIN Member Services
> Help Desk at info at arin.net if you experience any issues.
>



-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160915/9b00d562/attachment.html>

From cliffb at cjbsys.bdb.com  Thu Sep 15 11:48:42 2016
From: cliffb at cjbsys.bdb.com (Cliff Bedore)
Date: Thu, 15 Sep 2016 11:48:42 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <5FE61D10-1485-4052-AEE9-3ACF7BA74E17@delong.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
	<Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
	<4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
	<000f01d20d01$4725be70$d5713b50$@iptrading.com>
	<5FE61D10-1485-4052-AEE9-3ACF7BA74E17@delong.com>
Message-ID: <363c0d5a-7f63-bd8b-3076-da89169aa224@cjbsys.bdb.com>

Owen

This sounds like a reasonable approach to me but I may have a biased 
viewpoint.  I am one of the non-RSA/LRSA "owners" of a /24 that I've had 
since since 1990.  For years I was connected to the internet via a DSL 
line via Verizon to Megapath.  When the line went bad, I had to switch 
to a big provider since my provider could not offer another cost 
effective alternative.  I now have 5 non-portable addresses (Verizon in 
a twist of fate) and in theory the /24 is not in use.  I may want to 
"sell" it at some point so I would like a simple procedure where I could 
show it's been mine (see http://www.bdb.com/~cliffb/bdb_netreg.jpg) for 
a nominal fee and then be able to decide at some point later to "sell" it.

 From a practical standpoint, the simpler you make it, the more people 
will be willing to follow the rules.  I think something like Owen 
suggests would do this.

Cliff

On 9/15/2016 8:57 AM, Owen DeLong wrote:
> So I?ve been watching this and thinking about the situation. It occurs to me that perhaps we should consider the following:
>
> 1.	Open up a pre-approval process for resource suppliers similar to the current pre-approval process
> 	for requestors.
>
> 2.	Set a fee for pre-approval that would apply only to resources being pre-approved which are not already subject
> 	to an RSA. Ideally, this fee should be nominal, but large enough to discourage abuse of the process.
>
> 3.	Charge the same fee for any supplier of transferred resources not covered by RSA, whether at time of request
> 	or in a pre-approval process.
>
> 4.	Possibly provide some mechanism by which entities that wish to do so can have their pre-approved resources marked
> 	as such in whois and/or STLS.
>
> This fee would be separate from the fee collected for a transfer at the time of the transfer, though that fee could, potentially, be reduced accordingly to reflect the lower cost of transactions involving known resources. In this way, the seller would be responsible for paying the provenance costs and the buyer would be responsible for paying the administrative costs of processing the transfer.
>
> This seems like a good balance to me.
>
> Thoughts?
>
> Owen
>
> _______________________________________________
> ARIN-Consult
> You are receiving this message because you are subscribed to the ARIN Consult Mailing
> List (ARIN-consult at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-consult Please contact the ARIN Member Services
> Help Desk at info at arin.net if you experience any issues.
>



From jcurran at arin.net  Thu Sep 15 12:13:56 2016
From: jcurran at arin.net (John Curran)
Date: Thu, 15 Sep 2016 16:13:56 +0000
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <363c0d5a-7f63-bd8b-3076-da89169aa224@cjbsys.bdb.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
	<Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
	<4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
	<000f01d20d01$4725be70$d5713b50$@iptrading.com>
	<5FE61D10-1485-4052-AEE9-3ACF7BA74E17@delong.com>
	<363c0d5a-7f63-bd8b-3076-da89169aa224@cjbsys.bdb.com>
Message-ID: <7B1A2FB1-9246-4C41-A7E2-F69CE489EC47@corp.arin.net>

On Sep 15, 2016, at 11:48 AM, Cliff Bedore <cliffb at cjbsys.bdb.com> wrote:
> 
> Owen
> 
> This sounds like a reasonable approach to me but I may have a biased viewpoint.  I am one of the non-RSA/LRSA "owners" of a /24 that I've had since since 1990.  For years I was connected to the internet via a DSL line via Verizon to Megapath.  When the line went bad, I had to switch to a big provider since my provider could not offer another cost effective alternative.  I now have 5 non-portable addresses (Verizon in a twist of fate) and in theory the /24 is not in use.  I may want to "sell" it at some point so I would like a simple procedure where I could show it's been mine (see http://www.bdb.com/~cliffb/bdb_netreg.jpg) for a nominal fee and then be able to decide at some point later to "sell" it. 


Cliff - 

   The particular process that you seek presently exists via the Specified Transfer
   Listing Service  <https://www.arin.net/resources/transfer_listing/>

   You may register as an approved source of IP address space with the block in 
   question, and ARIN will confirm that your organization has rights to the specified 
   block and that may be transferred in accordance with policy.   ARIN charges a
   one-time $100 fee to offset the costs involved in providing the service.)   You 
   may also (optionally) have your contact info and block size shown in the list of 
   available blocks for transfer, if you so choose. 

   (Note - The rights to the address block are held by the organization shown,
   i.e. "BDB Systems?, so presuming that you did not merge or sell that entity
   to another firm, it should be fairly straightforward to confirm that the rights 
   to BDB-NET remain valid.) 

Thanks!
/John

John Curran
President and CEO
ARIN


From jcurran at arin.net  Thu Sep 15 12:20:29 2016
From: jcurran at arin.net (John Curran)
Date: Thu, 15 Sep 2016 16:20:29 +0000
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <CAC4yj2UXwO7uag2B90AFk_jsuL1uV1Ktj8vwMtowv_fXSyDRXA@mail.gmail.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
	<Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
	<4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
	<000f01d20d01$4725be70$d5713b50$@iptrading.com>
	<5FE61D10-1485-4052-AEE9-3ACF7BA74E17@delong.com>
	<CAC4yj2UXwO7uag2B90AFk_jsuL1uV1Ktj8vwMtowv_fXSyDRXA@mail.gmail.com>
Message-ID: <06401FEC-E24C-49CA-92F0-256D4602C260@corp.arin.net>

On Sep 15, 2016, at 11:02 AM, Jason Schiller <jschiller at google.com<mailto:jschiller at google.com>> wrote:

The listing of the providence either needs to be public, or the seller needs to be
able to get some sort of certified proof from ARIN of its status that can be used
anonymously by any potential purchaser to verify its authenticity.

To be clear, such an statement can only be valid on date x, since that party can
come in to ARIN with a transaction immediately thereafter, thus rendering the
statement of rights not longer valid?

/John

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160915/bd90edaa/attachment.html>

From jschiller at google.com  Thu Sep 15 13:23:55 2016
From: jschiller at google.com (Jason Schiller)
Date: Thu, 15 Sep 2016 13:23:55 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <06401FEC-E24C-49CA-92F0-256D4602C260@corp.arin.net>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
	<Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
	<4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
	<000f01d20d01$4725be70$d5713b50$@iptrading.com>
	<5FE61D10-1485-4052-AEE9-3ACF7BA74E17@delong.com>
	<CAC4yj2UXwO7uag2B90AFk_jsuL1uV1Ktj8vwMtowv_fXSyDRXA@mail.gmail.com>
	<06401FEC-E24C-49CA-92F0-256D4602C260@corp.arin.net>
Message-ID: <CAC4yj2VMX-ekdwXRkCTuy-5XsKrU024FTew10Kky-ybBMSXvwA@mail.gmail.com>

John,

Yes of course.  My thinking was Company A says they
have clean providence for block B.  Buyer C can validate
with ARIN that block B has clean providence, and that
at the current time, it does belong to Company A.

My thinking is wrt a particular IP address,
If ARIN has determined that the providence is good,
then it will continue to be good through every ARIN
recognized transfer.

__Jason

On Thu, Sep 15, 2016 at 12:20 PM, John Curran <jcurran at arin.net> wrote:

> On Sep 15, 2016, at 11:02 AM, Jason Schiller <jschiller at google.com> wrote:
>
>
> The listing of the providence either needs to be public, or the seller
> needs to be
> able to get some sort of certified proof from ARIN of its status that can
> be used
> anonymously by any potential purchaser to verify its authenticity.
>
>
> To be clear, such an statement can only be valid on date x, since that
> party can
> come in to ARIN with a transaction immediately thereafter, thus rendering
> the
> statement of rights not longer valid?
>
> /John
>
>


-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160915/3e140cd1/attachment.html>

From jschiller at google.com  Thu Sep 15 13:33:49 2016
From: jschiller at google.com (Jason Schiller)
Date: Thu, 15 Sep 2016 13:33:49 -0400
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <CAC4yj2VMX-ekdwXRkCTuy-5XsKrU024FTew10Kky-ybBMSXvwA@mail.gmail.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
	<Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
	<4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
	<000f01d20d01$4725be70$d5713b50$@iptrading.com>
	<5FE61D10-1485-4052-AEE9-3ACF7BA74E17@delong.com>
	<CAC4yj2UXwO7uag2B90AFk_jsuL1uV1Ktj8vwMtowv_fXSyDRXA@mail.gmail.com>
	<06401FEC-E24C-49CA-92F0-256D4602C260@corp.arin.net>
	<CAC4yj2VMX-ekdwXRkCTuy-5XsKrU024FTew10Kky-ybBMSXvwA@mail.gmail.com>
Message-ID: <CAC4yj2Wn61QstfauMd8LNZG=c3+b7c97-dY5qGx5T8=RAEeBTA@mail.gmail.com>

Apologies for the spell checking issue...

Provenance is the word I am looking for.

Although sometimes it seems like a prayer is needed when trying to get
enough IP space.

__Jason


On Thu, Sep 15, 2016 at 1:23 PM, Jason Schiller <jschiller at google.com>
wrote:

> John,
>
> Yes of course.  My thinking was Company A says they
> have clean providence for block B.  Buyer C can validate
> with ARIN that block B has clean providence, and that
> at the current time, it does belong to Company A.
>
> My thinking is wrt a particular IP address,
> If ARIN has determined that the providence is good,
> then it will continue to be good through every ARIN
> recognized transfer.
>
> __Jason
>
> On Thu, Sep 15, 2016 at 12:20 PM, John Curran <jcurran at arin.net> wrote:
>
>> On Sep 15, 2016, at 11:02 AM, Jason Schiller <jschiller at google.com>
>> wrote:
>>
>>
>> The listing of the providence either needs to be public, or the seller
>> needs to be
>> able to get some sort of certified proof from ARIN of its status that can
>> be used
>> anonymously by any potential purchaser to verify its authenticity.
>>
>>
>> To be clear, such an statement can only be valid on date x, since that
>> party can
>> come in to ARIN with a transaction immediately thereafter, thus rendering
>> the
>> statement of rights not longer valid?
>>
>> /John
>>
>>
>
>
> --
> _______________________________________________________
> Jason Schiller|NetOps|jschiller at google.com|571-266-0006
>
>


-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-consult/attachments/20160915/dd5edeba/attachment.html>

From jcurran at arin.net  Thu Sep 15 13:41:38 2016
From: jcurran at arin.net (John Curran)
Date: Thu, 15 Sep 2016 17:41:38 +0000
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <CAC4yj2VMX-ekdwXRkCTuy-5XsKrU024FTew10Kky-ybBMSXvwA@mail.gmail.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
	<Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
	<4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
	<000f01d20d01$4725be70$d5713b50$@iptrading.com>
	<5FE61D10-1485-4052-AEE9-3ACF7BA74E17@delong.com>
	<CAC4yj2UXwO7uag2B90AFk_jsuL1uV1Ktj8vwMtowv_fXSyDRXA@mail.gmail.com>
	<06401FEC-E24C-49CA-92F0-256D4602C260@corp.arin.net>
	<CAC4yj2VMX-ekdwXRkCTuy-5XsKrU024FTew10Kky-ybBMSXvwA@mail.gmail.com>
Message-ID: <203F90DA-6D15-4D46-B2AC-C949C933C99A@arin.net>

On Sep 15, 2016, at 1:23 PM, Jason Schiller <jschiller at google.com> wrote:
> 
> John,
> 
> Yes of course.  My thinking was Company A says they 
> have clean providence for block B.  Buyer C can validate
> with ARIN that block B has clean providence, and that 
> at the current time, it does belong to Company A.

Jason - 

That is effectively what we do; ARIN confirms that the parties 
who make use of the STLS service as a source for ?block B?
are the ones who presently hold the rights to that block and
that such rights may be transferred to another party.  We then
allow the source organization (if they wish) to be included in
the STLS listing of available number resources for transfer.

> My thinking is wrt a particular IP address, 
> If ARIN has determined that the providence is good,
> then it will continue to be good through every ARIN 
> recognized transfer.

Short of a very unusual event, that will be the case for the
entire address block.  (Obviously if we determine later that
fraudulent representations where made in asserting the
rights in question, that would change things.) 

/John

John Curran
President and CEO
ARIN



From jcurran at arin.net  Thu Sep 15 13:43:37 2016
From: jcurran at arin.net (John Curran)
Date: Thu, 15 Sep 2016 17:43:37 +0000
Subject: [ARIN-consult] Consultation on Transfer Fees Now Open
In-Reply-To: <CAC4yj2Wn61QstfauMd8LNZG=c3+b7c97-dY5qGx5T8=RAEeBTA@mail.gmail.com>
References: <5323d4e8-1c98-136a-95bd-5895b1a3e3af@arin.net>
	<Pine.NEB.4.64.1609061546480.24018@panix1.panix.com>
	<47B341A7-2C28-4633-90BE-30CB9364F11B@corp.arin.net>
	<Pine.NEB.4.64.1609061714390.17136@panix1.panix.com>
	<Pine.NEB.4.64.1609111716470.5478@panix2.panix.com>
	<4E222AF6-19DE-4C81-B81C-FC25D485DC79@arin.net>
	<000f01d20d01$4725be70$d5713b50$@iptrading.com>
	<5FE61D10-1485-4052-AEE9-3ACF7BA74E17@delong.com>
	<CAC4yj2UXwO7uag2B90AFk_jsuL1uV1Ktj8vwMtowv_fXSyDRXA@mail.gmail.com>
	<06401FEC-E24C-49CA-92F0-256D4602C260@corp.arin.net>
	<CAC4yj2VMX-ekdwXRkCTuy-5XsKrU024FTew10Kky-ybBMSXvwA@mail.gmail.com>
	<CAC4yj2Wn61QstfauMd8LNZG=c3+b7c97-dY5qGx5T8=RAEeBTA@mail.gmail.com>
Message-ID: <C06E4505-862C-4AF7-AC8E-7CDFC82C5A5E@arin.net>

On Sep 15, 2016, at 1:33 PM, Jason Schiller <jschiller at google.com> wrote:
> 
> Apologies for the spell checking issue...
> 
> Provenance is the word I am looking for.

Indeed.
 
> Although sometimes it seems like a prayer is needed when trying to get enough IP space.

IPv6 is the answer to your prayers!  

:-) 
/John