[arin-ppml] LAST CALL - Draft Policy ARIN-2012-8: Aligning 8.2 and 8.3 Transfer Policy
The ARIN Advisory Council (AC) met on 20 December 2012 and decided to
send the following draft policy to last call:
Draft Policy ARIN-2012-8: Aligning 8.2 and 8.3 Transfer Policy
The AC revised the text after the ARIN XXX Public Policy Meeting and
asked for an updated staff assessment of the revised text. The
assessment is available at:
Feedback is encouraged during the last call period. All comments should
be provided to the Public Policy Mailing List. Last call for 2012-8 will
expire on 15 January 2013. After last call the AC will conduct their
last call review.
The draft policy text is below and available at:
The ARIN Policy Development Process is available at:
Communications and Member Services
American Registry for Internet Numbers (ARIN)
## * ##
Draft Policy ARIN-2012-8
Aligning 8.2 and 8.3 Transfer Policy
Date: 27 December 2012
Replace the first paragraph of section 8.2 with the following (second
paragraph remains unchanged):
ARIN will consider requests for the transfer of number resources in the
case of mergers and acquisitions under the following conditions:
* The new entity must provide evidence that they have acquired assets
that use the resources to be transferred from the current
registrant. ARIN will maintain an up-to-date list of acceptable
types of documentation.
* The current registrant must not be involved in any dispute as to the
status of the resources to be transferred.
* The new entity must sign an RSA covering all resources to be
* The resources to be transferred will be subject to ARIN policies.
* The minimum transfer size is the smaller of the original allocation
size or the applicable minimum allocation size in current policy.
The base intent here is to lower confusion, raise clarity, and level the
bar between 8.2 and 8.3 transfers. M&A transfers are distinct from
specified transfers and not all of the same rules can apply - but many
can and should. Therefor this policy change explicitly adds requirements
which do not exist in 8.2 policy text today: Source must be the
undisputed current registered holder, recipient must sign an RSA (and is
subject to policy), and /24 minimum for IPv4, /48 for IPv6.
Changes following discussion at the ARIN XXX public policy meeting: 1)
Changed the first bullet. This was an area for objections because it did
not allow chain of custody transfers, so now instead of saying that the
purchased company must be the current registrant holder it simply says
that there can not be any dispute as to who the registered holder is. 2)
Removed the " such that their continued need is justified" text from the
second bullet, this was another area of debate at the meeting and
justification is already covered in paragraph 2 of 8.2 (which remains
unchanged). 3) Swapped the first two bullets. 4) Added "covering all
transferred resources" to the RSA bullet, for clarity. 5) Swapped the
third and fourth bullets. 3) Altered the IPv4 minimum allocation to
bring it in line with 4.10 resources and any future exceptions.
Changes following PPML discussion in November 2012: a) 'used' was
changed back to 'use' in the first bullet to prevent a backdoor around
specified transfers leveraging asset liquidation. b) The third bullet
was shortened for clarity (removed the word 'current' before 'policy')
c) The minimum transfer sizes are now pinned to policy rather than hard-set.
Timetable for implementation: immediate