[arin-ppml] Policy Proposal 105: Simplified M&A transfer policy

Owen DeLong owen at delong.com
Tue Dec 22 17:17:38 EST 2009

> 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.
Perhaps ...ARIN staff will...

> In the event that number resources of the acquired/merged
> organization(s) are no longer efficiently utilized 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 the NRPM.
I think that there's an issue here.  I think that we need to talk about
the number resources of the resultant combined organization rather
than of the acquired/merged organization... Here's why...

The term acquired/merged could be construed to refer only to the
resources that were acquired without regard for the resources already
held by the acquiring organization.  Let's say that two organizations
A and B merge. Prior to merger, A efficiently used 17 /24s and held
a /19, while B efficiently used a /23 and held a /22.  The combined
usage is 19 /24s which would justify a /19, but, would not justify the
/22 of additional space.  The /22 should be returned in this case and
be renumbered into the /19.

> Add "In addition to transfers under section 8.2, " at the beginning of
> section 8.3. Transfers to Specified Recipients.
Otherwise, looks good to me.


> Rationale:
> 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 address space that is not efficiently
> utilized 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. This 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
> https://www.arin.net/resources/request/transfers.html
> Timetable for implementation: Immediate
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