[arin-ppml] Draft Policy 2017-12: Require POC Validation Upon Reassignment

Tue Apr 17 16:54:20 EDT 2018

Howdy folks I very much hope I’m not a significant part of this problem but we do submit 50-100 reassigns a week. If there is any evidence of us causing trouble in the data I’d be happy to try to run it down and improve. As noted by others we do this primarily to offload abuse but also to assist LEO’s and to be upfront with the community how our space is being use. We also try as hard as we can to populate those records with valid info and have our sales guys collect and input into our system then the provisioning team validates at turn up and the system auto generates at activation the record. I worry greatly that if an entry we send up goes unvalidated for 10 days that it must be deleted. I think you are going to be losing a lot of good data of legit usage simply because folks maybe too lazy to click off on an acknowledgment. If implemented I could be sending all these updates and not seeing them appear and wondering till 10 days down the road which ones I have to reattempt? Will there be a notification back that the record did not populate? That reattempt piece will be a lot of fun to workout with our IT guys I can tell you it’ll just be dropped for a long time until they work out the code to automate and thus usability of whois will be impacted.

Anthony Delacruz
Senior Lead Engineer
IP Admin Backbone Planning and Design
Office: +1 703 363 8503
Anthony.DeLaCruz at CenturyLink.com
ipadmin at centurylink.com

From: ARIN-PPML [mailto:arin-ppml-bounces at arin.net] On Behalf Of John Santos
Sent: Tuesday, April 17, 2018 1:58 PM
To: arin-ppml at arin.net
Subject: Re: [arin-ppml] Draft Policy 2017-12: Require POC Validation Upon Reassignment

I think anyone who supplies someone else's email address to a third party without their permission is responsible for any mail they receive.  Unless a SWIPer has permission from their customer to SWIP the customer's email address, the ISP doing the SWIPing is responsible, not ARIN.  If they do this repeatedly or as a matter of course, they should be barred from SWIPing and any subnets they have previously SWIPed should revert to them, making them responsible for all network abuse and connectivity problems originating from those subnets.

Isn't the entire point of SWIP to allow ISPs to offload the abuse and other points of contact to their customers, who presumably are more capable of dealing with the issues?  And shouldn't the customers expect to receive email at those POC addresses as part of that?  Either the ISP has explained that to their customers, who have agreed to this, in which case no mail sent to them as a consequence is SPAM, or  the ISP has not, in which case the POC (and SWIP) should be removed or never allowed in the first place.

On 4/17/2018 11:11 AM, Christian Tacit wrote:
Hi Jason,

After discussion with staff, I can report that it would be much easier to send a notification to the email that is swipped as the POC but to add in any type of ACK or NACK turns it into a very, very heavy lift for the organizations as it completely changes the flow. Furthemore, the addition of a requirement for a response could end up creating issues (whether real or perceived) that ARIN would be sending UCE (Unsolicited Commercial Email) (SPAM) to all of those contacts as we do not have a formal relationship with them.

Chris

Christian S. Tacit,
Tacit Law

P.O. Box 24210 RPO Hazeldean
Kanata, Ontario
K2M 2C3 Canada

Tel: +1 613 599 5345
Fax: +1 613 248 5175
E-mail: ctacit at tacitlaw.com<mailto:ctacit at tacitlaw.com>

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From: Jason Schiller <jschiller at google.com><mailto:jschiller at google.com>
Sent: April 16, 2018 3:05 PM
To: Christian Tacit <ctacit at tacitlaw.com><mailto:ctacit at tacitlaw.com>
Cc: ARIN-PPML List <arin-ppml at arin.net><mailto:arin-ppml at arin.net>
Subject: Re: [arin-ppml] Draft Policy 2017-12: Require POC Validation Upon Reassignment

Chris,

Thanks.

One of the problems with POC validation is that ARIN tries to validate all POCS, and does not have a relationship with some.

There is a proposal to reduce the validation to only the set of POCs that ARIN has a direct relationship with.

This is problematic because it is through this annual validation that one finds they have become a POC on some resource.
So without out the annual check, those organizations will NOT have the awareness and knowledge to resolve that issue between themselves.

The solution is a bi-directional check.

I think the ARIN objection is that it is problematic for the SWIPee to modify the record of the SWIPer.
But I see no problem with the SWIPee getting notified, or even ACKing or NACKIing the SWIP.

__Jason

On Sat, Apr 14, 2018 at 2:23 PM Christian Tacit <ctacit at tacitlaw.com<mailto:ctacit at tacitlaw.com>> wrote:
Hi Jason,

Although I did look into the issue raised by your March 15 email promptly after receiving it. I inadvertently forgot to reply to you. Please accept my apology.

Based on ARIN Staff input, a major impediment to the proposed Section 3.8 is that ARIN cannot be involved in the contractual relationship between its customer and any of the customer’s customers. The ARIN customer may be submitting a simple reassignment, precisely because it wants to maintain control over POC records. Examples may include branches located in different states of an entity that may want to use address information corresponding to its  head office and or other locations in which it has a presence. If there is a dispute with an entity that already has an OrgID with ARIN and its upstream provider on how to register the entity’s reassignments, those organizations will have the awareness and knowledge to resolve that issue between themselves.

Chris

From: Jason Schiller <jschiller at google.com<mailto:jschiller at google.com>>
Sent: March 15, 2018 4:29 PM
To: Christian Tacit <ctacit at tacitlaw.com<mailto:ctacit at tacitlaw.com>>
Cc: arin-ppml at arin.net<mailto:arin-ppml at arin.net>
Subject: Re: [arin-ppml] Draft Policy 2017-12: Require POC Validation Upon Reassignment

This problem is not scoped only to with a new POC is created.

This was also supposed to be a check in 3.7 to insure a resource is not
randomly SWIP'd to a pre-existing org.

3.8 was intended to chatch when a resource is SWIP'd to a pre-existing org,
but that org ID is not used, and that org's address is put into a reassign simple.

I don't see how this is not implementable..

- If the compnay name is a match for something ARIN already has a relationship with,
  then they should have good contact info.

- If the contact info is a known address of a compnay that ARIN already has a
  relationship with, then they should have good contact info for that compnay.

- If all else fails they can send a post card to the mailing address.

At a mimimum, if the post card is undeliverable, or a holder of the the post card
contacts ARIN, they should revoke the SWIP.

___Jason

On Mon, Mar 12, 2018 at 5:47 PM, Christian Tacit <ctacit at tacitlaw.com<mailto:ctacit at tacitlaw.com>> wrote:
Dear Community Members,

The shepherds for the Draft Policy 2017-12: Require POC Validation Upon Reassignment, are making two changes to its text.

First, the problem statement is being expanded a bit to explain how POCs for reassigned blocks can be assigned without the knowledge of the individuals so assigned under the present policy.

Second, proposed section 3.8 has been deleted. This is because it is unintentionally misleading because a simple reassignment results in a customer identifier versus an OrgID.   There is no contact information contained in a simple reassignment other than street address that could be used for notification, and thus it does not appear that the proposed NRPM 3.8 policy text is implementable.  Even if notification were possible, the “OR postal address” in this section may also cause significant problems for some companies as many companies have the same name associated with many different locations and there are several locations that have many companies registered there.

Based on these changes, the revised text reads:

Version Date: March 12, 2018

Problem Statement:

Some large ISPs assign individuals to be POCs for reassigned blocks without consultation of the individual they are inserting into Whois. For example, during the reassignment/reallocation process, some large ISPs automatically create POCs from their customer’s order form. This process is automated for many ISPs and therefore the resulting POCs are not validated prior to being created in the ARIN Whois database. This creates unknowing POCs that have no idea what Whois is or even who ARIN is at the time they receive the annual POC validation email. It can also create multiple POCs per email address causing that same person to receive a multitude of POC Validation emails each year.

This policy proposal seeks to improve the situation where a POC is unwittingly and unintentionally inserted into Whois.

It also seeks to mitigate the significant amount of time that ARIN staff reports that they spend fielding phone calls from POCs who have no idea they are in Whois.

Finally, it is hopeful that this proposal will improve the overall POC validation situation, by forcing ISPs and customers to work together to insert proper information into Whois at the time of sub-delegation.

Policy statement:

Insert one new section into NRPM 3:

3.7 New POC Validation Upon Reassignment

When an ISP submits a valid reallocation or detailed reassignment request to ARIN which would result in a new POC object being created, ARIN must (before otherwise approving the request) contact the new POC by email for validation. ARIN's notification will, at a minimum, notify the POC of:

- the information about the organization submitting the record; and
- the resource(s) to which the POC is being attached; and
- the organization(s) to which the POC is being attached.

If the POC validates the request, the request shall be accepted by ARIN and the new objects inserted into Whois.  If the POC does not validate the request within 10 days, ARIN must reject the request.

Timetable for implementation: Immediate

Comments from the community are welcome!

Christian S. Tacit

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_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com<mailto:jschiller at google.com>|571-266-0006

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John Santos

Evans Griffiths & Hart, Inc.

781-861-0670 ext 539

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