[arin-ppml] Draft Policy ARIN-2019-14: No Specified Transfers for 4.1.8.2 Blocks

[Fernando Frediani]

I like the 60 month restriction and finds it adequate as a mechanism to 
discourage fraud.

I don't think a complete prohibition on transfers is necessary, just a 
significant delay so those who are really committed in using the 
resources as they should and not to especulate or stockpiling can do 
things in an appropriate manner when the time comes for them.

Regards
Fernando Frediani

On 08/07/2019 14:56, Andrew Dul wrote:
> Hello,
>
> With the ARIN board recently adopting the AC's recommendation to 
> re-instate the wait-list policy, we should now reconsider this draft 
> policy to the wait-list policy in light of those changes. In the AC's 
> recommendation, a 60 month transfer restriction was placed on any 
> block received from the wait-list starting with the re-implementation 
> of the policy.
>
> Do you feel this 60 month restriction is sufficient?
>
>
> This draft policy calls for prohibition on non M&A transfers and 
> restricts M&A transfers to the same purpose as requested under the 
> wait-list policy.
>
> Would you prefer a complete prohibition on transfer of these blocks?  
> Should an exception & restrictions be allowed for M&A transfers?
>
>
> Your input here is helpful to help the AC determine if this draft 
> policy should be updated to reflect the recently adopted re-instated 
> wait-list policy text or if this draft policy should now be abandoned 
> given the 60 month restriction in the current wait-list policy.
>
>
> Thanks,
>
> Andrew
>
>
> On 5/21/2019 11:06 AM, ARIN wrote:
>> On 16 May 2019, the ARIN Advisory Council (AC) accepted 
>> "ARIN-prop-274: No Specified Transfers for 4.1.8.2 Blocks" as a Draft 
>> Policy.
>>
>> Draft Policy ARIN-2019-14 is below and can be found at:
>> https://www.arin.net/participate/policy/drafts/2019_14/
>>
>>
>> Draft Policy ARIN-2019-14: No Specified Transfers for 4.1.8.2 Blocks
>>
>> Problem Statement:
>>
>> The ARIN “Unfulfilled Requests” policy creates an opportunity for an 
>> ARIN member to claim need for number resources, wait for those 
>> resources to become available via returns or reclamations, acquire 
>> them (per 4.1.8.2 of the NRPM), wait a day after the mandatory “hold 
>> time”, and then profit from them via a specified transfer transaction.
>>
>> This waiting list policy freely provides number resources, creating 
>> an incentive for profit-taking through fraudulent applications or 
>> making misrepresentations to registration services.
>>
>> ARIN can avoid this problem by prohibiting non-8.2 transfers for 
>> blocks distributed under 4.1.8.2 using language very similar to 
>> policy elsewhere in the NRPM.
>>
>> Policy Statement:
>>
>> Add a second paragraph to 4.1.8.2:
>>
>> IP allocations issued through 4.1.8.2 are non-transferable via 
>> section 8.3 and section 8.4. In the case of a section 8.2, transfer 
>> of the IP assignment must be utilized for the same purpose or needs 
>> justified used for the original 4.1.8 application.
>>
>> Comments:
>>
>> Timetable for implementation: Immediate
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