[ARIN-consult] Consultation on Retiring the Officer Attestation Requirement
mike at iptrading.com
Tue Aug 3 17:25:15 EDT 2021
+1 to Scott's comments.
From: ARIN-consult <arin-consult-bounces at arin.net> On Behalf Of Scott Leibrand
Sent: Tuesday, August 03, 2021 12:21 PM
To: John Curran <jcurran at arin.net>
Cc: arin-consult at arin.net
Subject: Re: [ARIN-consult] Consultation on Retiring the Officer Attestation Requirement
I support removal of the attestation requirement. It has now outlived its original purpose, and likely wouldn’t pass a cost-benefit test if proposed today.
> On Aug 3, 2021, at 7:15 AM, John Curran <jcurran at arin.net> wrote:
> On 3 Aug 2021, at 9:47 AM, Rob Seastrom <rs at seastrom.com> wrote:
>>>> On Aug 3, 2021, at 8:13 AM, ARIN <info at arin.net> wrote:
>>> ... conditions have changed since this requirement was established, and ARIN believes that the Officer Attestation for resource request tickets is no longer necessary for the following reasons:
>>> - Today IPv4 resources are issued by ARIN predominantly via the Waitlist policy, and this policy has been revised to only allow one small request per party (thus avoiding the original risk of “hoarding” via large suspect requests prior to runout).
>> To what degree did the requirement for officer attestation contribute to ARIN staff smoking out the abuse of the waitlist that resulted in the revision of the policy a couple of years back?
> Officer attestation did not contribute to the detection - by
> definition, the parties who utilized the waitlist were requests whose
> need assessment supporting documentation was attested to and then
> approved. (One can theorize that even large requests would have been
> made absent such attestations but that would be purely conjecture.)
>> Is there any kind of downside in terms of getting law enforcement involved for fraudulent requests if we get rid of this requirement? That is to say, does LE view the application differently with vs. without the officer attestation when evaluating whether there was an act that they're going to use scarce prosecutorial resources on? Interested in Counsel's take on this.
> The proposed change has been reviewed with ARIN’s legal counsel prior to recommendation to the community. As a person intimately familiar with the prosecution of fraudulent requests here at ARIN, I can say that the change to drop attestation of needs-request documentation should not materially affect our anti-fraud processing.
>> I have never been wholly in favor of requiring an officer attestation for resources for which there is no scarcity/hoarding incentive (i.e. IPv6 blocks and 32 bit ASNs). For those resources I agree that the administrative burden significantly exceeds any potential upside.
> It is true that the change regarding attestation for IPv4 blocks is enabled as a result of being post-depletion with ARIN issuance per the waitlist being of very modestly-sized IPv4 blocks. Under such circumstances the officer attestation is a lengthy delay to certify information which is rather routine in both information and scope.
>> For IPv4 number resources, my position requires some more thought and am eagerly anticipating more community input.
> Acknowledged (and thanks!)
> John Curran
> President and CEO
> American Registry for Internet Numbers
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