[arin-ppml] Draft Policy ARIN-2020-1: Clarify Holding Period for Resources Received via 4.1.8 Waitlist

[Fernando Frediani]

Just to make it clear for record I oppose this proposal as written for 
the reasons stated below and believe it requires necessary adjustments.
Regards
Fernando

On 26/02/2020 02:54, Fernando Frediani wrote:
> May I ask how this situation will avoid that someone to register a new 
> company, get into the waiting list, receive a /22 and right after that 
> be "purchased" by another company which is not entitled to be in the 
> waiting list anymore bypassing the restriction ?
>
> Although it may not be the easiest thing to do deal with all 
> paperwork, bureaucracy and register company, depending on the rising 
> price of IPv4 in the market someone may find that became worth the 
> effort and this could (not right now, but at some point in the future) 
> turn into a way to bypass the waiting list restriction as the 
> mathematics will cover all the costs involved in the whole transaction.
>
> At first seeing I identify this proposal may bring an issue in such 
> scenario and perhaps there should still be some minimal time 
> restriction, not necessarily 60 months, but something that makes it 
> more difficult for fraudsters to act with such intention.
>
> Regards
> Fernando
>
> On 25/02/2020 18:49, ARIN wrote:
>> On 20 February 2020, the ARIN Advisory Council (AC) accepted 
>> "ARIN-prop-284: Clarify Holding Period for Resources Received via 
>> 4.1.8 Waitlist" as a Draft Policy.
>>
>> Draft Policy ARIN-2020-1 is below and can be found at:
>>
>> https://www.arin.net/participate/policy/drafts/2020_1/
>>
>> You are encouraged to discuss all Draft Policies on PPML. The AC will 
>> evaluate the discussion in order to assess the conformance of this 
>> draft policy with ARIN's Principles of Internet number resource 
>> policy as stated in the Policy Development Process (PDP). 
>> Specifically, these principles are:
>>
>> * Enabling Fair and Impartial Number Resource Administration
>> * Technically Sound
>> * Supported by the Community
>>
>> The PDP can be found at:
>> https://www.arin.net/participate/policy/pdp/
>>
>> Draft Policies and Proposals under discussion can be found at:
>> https://www.arin.net/participate/policy/drafts/
>>
>> Regards,
>>
>> Sean Hopkins
>> Policy Analyst
>> American Registry for Internet Numbers (ARIN)
>>
>>
>>
>> Draft Policy ARIN-2020-1: Clarify Holding Period for Resources 
>> Received via 4.1.8 Waitlist
>>
>> Problem Statement:
>>
>> A recent Policy Experience Report reported ambiguity on the part of 
>> customers as to whether or not the 60-month restriction on 
>> transferring resources received via NRPM Section 4.1.8 applies to M&A 
>> transfers under NRPM Section 8.2. This proposal clarifies this 
>> restriction to exempt 8.2 transfers from this restriction.
>>
>> Policy Statement: Update NRPM Section 4.1.8 as follows:
>>
>> Original Text:
>>
>> Address space distributed from the waitlist will not be eligible for 
>> transfer for a period of 60 months.
>>
>> New Text:
>>
>> Address space distributed from the waitlist will not be eligible for 
>> transfer, with the exception of Section 8.2 transfers, for a period 
>> of 60 months.”
>>
>> Comments:
>>
>> Timetable for implementation: immediate
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