[arin-ppml] Draft Policy ARIN-2022-3: Remove Officer Attestation Requirement for 8.5.5

[Owen DeLong]

> On Jun 23, 2022, at 09:06 , Matthew Wilder <matthew.wilder at telus.com> wrote:
> 
> Hi Noah, et al.
> 
> It appears that a few of you are not convinced of the problem statement for this Draft policy. Just a reminder this is a draft policy authored by the Policy Experience Working Group, to solve a customer experience problem identified by staff. Also, taking off my AC hat and putting on my day job hat for a moment - I can assure you that if you are at an organization of significant scale and complexity - this is indeed a real problem. In the case of qualification for transfers (8.5.5) this is a redundant step, in practice, since significant sums of money must be approved by executives in order to execute transfers.

It’s not entirely redundant… The significant sums approval doesn’t provide the necessary nexus of evidence for ARIN to hold the officers accountable in the event of resource fraud.

Companies often escape prosecution by throwing lower level employees under the bus and claiming officers had no knowledge of the action in question.

This step prevents that from occurring in the case of ARIN resource fraud.

So yes, while I have some limited sympathy to the problem statement, I am in fact unconvinced that the problem requires a solution or that the current state imposes an unnecessary burden.

> Swapping back to my AC hat now. To my mind, the introduction of officer attestations generally helped achieve two positive outcomes. First, it supported the principle of conservation. Second, it reduced the opportunity for fraud. There may be other benefits obtained by the requirement for officer attestation, and I am open to hearing everyone's perspective on this.

In my opinion it never really did much for the latter, and I’m not convinced it did much for the former, either.

From my perspective it has always been about ensuring accountability and making sure that an accountable corporate officer (section 16 where applicable or equivalent elsewhere) is accountable for the actions of the company with regard to ARIN resource registrations. I think that’s still a valid need.

> This draft policy would do away with the need for officer attestation for justification of transfers, but only because the market provides the same benefits mentioned above. Would-be fraudsters on the transfer market would now face significant cost to execute a transfer, and presumably, an organization operating in bad faith could easily provide officer attestation. Similarly, documentation of an overly-optimistic plan - securing more resources than realistically needed - will mean a higher cost to the organization bankrolling the transfer. As a result, the individuals accountable for the organization's decisions are well aware of - and implicitly supportive of - the plan. An officer attestation is therefore redundant in both cases.

If I agreed with your understanding of the benefits of attestation, then I’d probably agree about the market providing equivalent benefits. However, as pointed out above, the market does NOT provide the benefit of accountability and therefore, I think that it is still quite necessary and does protect the interests of ARIN and the community.

> 
> To Noah and others who have voiced opposition - let me know if you see a case where the officer attestation in 8.5.5 protects the interests of ARIN and the community.

Yes… See above.

Owen

> 
> Best regards,
> Matthew
> 
> 
> 
> On Tue, Jun 21, 2022 at 9:15 PM Noah <noah at neo.co.tz <mailto:noah at neo.co.tz>> wrote:
> 
> 
> On Wed, 22 Jun 2022, 04:56 ARIN, <info at arin.net <mailto:info at arin.net>> wrote:
> On 16 June 2022, the ARIN Advisory Council (AC) accepted "ARIN-prop-309: Remove Officer Attestation Requirement for 8.5.5" as a Draft Policy.
> 
> 
> Draft Policy ARIN-2022-3: Remove officer attestation requirement for 8.5.5
> 
> Problem Statement:
> 
> Requiring an officer attestation requires unnecessary resources and increases the time to complete an IPv4 transfer.
> 
>  
> 
> Policy statement:
> 
>  
> 
> 8.5.5. Block Size
> 
>  
> 
> Organizations may qualify for the transfer of a larger initial block, or an additional block, by providing documentation to ARIN which details the use of at least 50% of the requested IPv4 block size within 24 months.
> 
>  
> 
> Removing “An officer of the organization shall attest to the documentation provided to ARIN.
> 
> Using time as an excuse does not fly. Attestation is accountability and enforces legitimacy.
> 
> An authorized officer should not only be aware but MUST also be involved in attesting of documents that involve any Internet Number Resources transfers.
> 
> We have experienced fast hand on the negative impact of Admin Contacts being clueless to what its that Tech contacts do.
> 
> So I oppose the policy for using time as an excuse to remove an important process that ensures legitimacy.
> 
> Noah
> 
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> 
> -- 
> Matthew Wilder
> 
> Sr Engineer - IPv6, IP Address Management
> 
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