[arin-ppml] Last Call - Recommended Draft Policy ARIN-2019-10

[ARIN]

On 20 August 2020, the ARIN Advisory Council (AC) sent the following 
Recommended Draft Policy to Last Call:

* ARIN-2019-10: Inter-RIR M&A

Feedback is encouraged during the Last Call period. All comments should 
be provided to the Public Policy Mailing List. Last Call will expire on 
9 September 2020 (accounting for one United States federal holiday).

The Recommended Draft Policy text is below and available at:
https://www.arin.net/participate/policy/drafts/2019_10/

The ARIN Policy Development Process is available at:
https://www.arin.net/participate/policy/pdp/

Regards,

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)



Recommended Draft Policy ARIN-2019-10: Inter-RIR M&A

AC Assessment of Conformance with the Principles of Internet Number 
Resource Policy:

This Recommended Draft Policy is technically sound and is fair and 
impartial number policy. The intent of the draft policy is to clarify 
handling of mergers and acquisition transfer processing between RIRs who 
have compatible transfer policies. The proposed change would not be a 
change from present practice but the policy change would make ARIN 
implementation of the current policy clearer.

Problem Statement:

Merger, acquisition, or reorganization activity sometimes results in a 
restructuring where company resources, the management of number 
resources, or the use of number resources are concentrated outside the 
ARIN service region. In this case it may be desirable for the current 
legal entity or a legal entity that is a parent, child or sister to move 
the servicing of the number resources to a different RIR.

Example:

Imagine a case where a global company has decided to discontinue service 
in the ARIN service region (shuttering ARIN region offices laying off 
ARIN region employees, and canceling ARIN region customers) and 
repurpose the network resources and number resources in the rest of its 
global footprint.

Imagine a case where a global company has decided to divest its service 
in the ARIN region (selling all ARIN region offices, all ARIN region 
network assets, all ARIN service region customers, all number resources 
used in the ARIN (associated with previous noted sale of network and 
customers), but retaining ARIN issued resources in use outside of the 
ARIN service region.

Policy Statement:

In section 8.4, under “Conditions on source of the transfer”, replace 
the third bullet point:

* Source entities within the ARIN region must not have received a 
transfer, allocation, or assignment of IPv4 number resources from ARIN 
for the 12 months prior to the approval of a transfer request, unless 
either the source or recipient entity owns or controls the other, or 
both are under common ownership or control. This restriction does not 
include 8.2 transfers.

with

* Source entities within the ARIN region must not have received a 
transfer, allocation, or assignment of IPv4 number resources from ARIN 
for the 12 months prior to the approval of a transfer request, unless 
either the source or recipient entity owns or controls the other, or 
both are under common ownership or control. Number resources received as 
the result of an 8.2 transfer are out of scope for the purposes of this 
restriction.

AND

In section 8.4, under “Conditions on recipient of the transfer”, replace 
the second bullet point:

* Recipients within the ARIN region must meet the transfer requirements 
as defined in section 8.5.

with

* Specified Recipients within the ARIN region must meet the transfer 
requirements as defined in section 8.5.

Timetable for Implementation: Immediate