[arin-ppml] Policy Proposal 105: Simplified M&A transfer policy
Based on feeback so far, here's the updated/revised version of proposal
105. Additional feedback welcome, particularly from folks who have
recently done (or are in process of doing) an M&A transfer.
Policy Proposal 105: Simplified M&A transfer policy
Proposal Version: 1.1
Date: 22 December 2009
Replace section 8.2 with:
8.2. Mergers and Acquisitions
ARIN will consider requests for the transfer of number resources in the
case of properly documented mergers and acquisitions. ARIN will maintain
an up-to-date list of acceptable types of documentation.
In the event that number resources of the combined organizations are no
longer justified under ARIN policy at the time ARIN becomes aware of the
transaction, through a transfer request or otherwise, ARIN will work
with the resource holder(s) to return or aggregate resources as
appropriate via the processes outlined in sections 4.6, 4.7, or 12 of
Add "In addition to transfers under section 8.2, " at the beginning of
section 8.3. Transfers to Specified Recipients.
This policy proposal: attempts to simplify the M&A transfer section of
the NRPM; eliminates the ambiguity discussed at the ARIN Public Policy
Meeting (PPM) in Dearborn by clarifying that transfers can occur under
either 8.2 or 8.3 independently; and attempts to address the concerns
raised in the staff policy implementation report at the Dearborn PPM
The idea here is to simply say that ARIN will allow M&A transfers, and
to require the return of any number resources for which there is no
longer a justified need after the acquisition. Preferably that would
happen voluntarily under the policies of NRPM 4.6 (Amnesty), but it also
leaves the door open for ARIN to revoke space under NRPM 12 (Resource
Review) if necessary. By implication, future needs that would qualify
the organization for an allocation/assignment would likewise justify
keeping transferred space. In particular, see the language of NRPM
section 12, paragraphs 4 and 4a.
This policy also should dramatically increase the completion rate for
transfer requests, as the evaluation of whether space is efficiently
utilized after the transfer can occur in parallel, completely
independently of the transfer request, and can continue even if the
transfer request is abandoned.
The bulleted lists of acceptable documentation removed from the NRPM
should be maintained by ARIN elsewhere on the website, such as at