[ARIN-consult] Consultation on Changes to the Specified Transfer Listing Service (STLS)

[Mike Burns]

Question #1: Should ARIN continue to offer the registered transfer facilitator service?

Yes, I think ARIN should continue to offer the facilitator service. The STLS can go.

Question #2: Should ARIN perform some form of verification to confirm the facilitator actually provides transfer facilitation?

No, just continue to state that ARIN doesn't perform any verifications. Perform the listing service while avoiding any legal risks.

Question #3: Should ARIN verify the business is capable of completing transfers – for example, verifying licensing/bonding, or insurance?

No, especially as there are no licensing/bonding/insurance requirements to complete the brokerage of a transfer.

Question #4: Should ARIN offer the ability for customers to provide feedback on facilitators?

Not sure whether it's worth any legal risk to ARIN but at least worth considering this further.

Question #5: Should the fees for registered transfer facilitators be adjusted?

No, they just increased 10-fold.


ARIN should beware regulatory capture.

Regards,
Mike