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

Owen DeLong owen at delong.com
Mon Jun 27 17:43:56 EDT 2022 

Ah, with that clarification, I would support expanding the requirement to include ASNs and IPv6 issuances (and IPv4 if applicable) rather than removing it from 8.5.5.

I agree we should be consistent about requiring it or not, but I think it is a key tool in reducing fraud and would prefer it to be preserved. IIRC, I commented roughly the same in the consultation, but I had forgotten about it and its outcome.

Owen


> On Jun 27, 2022, at 14:30, John Sweeting <jsweeting at arin.net> wrote:
> 
> Hi Owen,
>  
> Not any longer, we did a consultation on removing the attestation some months ago and stopped requiring it as a result. The only place it was left was in this one policy for 8.3 transfers. It was Consultation 2021.04 Retiring the Officer Attestation Requirement <https://www.arin.net/participate/community/acsp/consultations/2021/2021-4/>
>  
> Thanks
> John S. 
>  
> From: Owen DeLong <owen at delong.com>
> Date: Monday, June 27, 2022 at 3:55 PM
> To: John Sweeting <jsweeting at arin.net>
> Cc: ARIN PPML <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] Draft Policy ARIN-2022-3: Remove Officer Attestation Requirement for 8.5.5
>  
> John, 
>  
> Correct me if I am wrong, but I believe the attestation is required of ALL recipients, not only specified transfer recipients.
>  
> This would include recipients receiving v4 or v6 resources from an ARIN application as well as those receiving them through specified transfers. I don’t recall whether this applies to merger/acquisition transfers or not, so clarification there would also probably be useful.
>  
> I realize that the DP in question proposes removing the requirement only from certain specified transfers.
>  
> I’m still opposed to this proposal for the reasons stated and I thank you for this clarification to the community.
>  
> Owen
>  
> 
> 
> On Jun 27, 2022, at 12:03, John Sweeting <jsweeting at arin.net <mailto:jsweeting at arin.net>> wrote:
>  
> Hello PPML,
>  
> ARIN would like to provide a clarification on both the Officer Attestation which is what is highlighted in DP ARIN-2022-3 and the Officer Acknowledgement which is not included in that Draft Policy.
>  
> Officer Attestation, as referenced in ARIN Number Resource Policy Manual (NRPM) 8.5.5 Block Size is specifically asking for an officer of the organization to attest to the documented justification that states at least 50% of the requested block size will be used within the next 24 months. There is no notarization required and it serves to state and confirm that yes, that is our plan for the next 24 months and the information and documentation provided is accurate. This is only asked for in conjunction with a specified transfer recipient.
>  
> On the other hand, Officer Acknowledgement, which is not contained in the NRPM, is an operational requirement for Source Organizations (Current Registrant) found at:
>  
> https://www.arin.net/resources/registry/transfers/ <https://www.arin.net/resources/registry/transfers/>
>  
> This requirement states that “The source organization must provide a signed and notarized Officer Acknowledgement Letter <https://www.arin.net/about/corporate/agreements/office_acknowledgement.pdf>. The purposes of this requirement are:
>  
> -to state that there are no known disputes from another party to claim rights to these Internet number resources
> -to ensure that a duly authorized officer has the authority to legally bind the source registrant
> -to document the authorization to transfer said resources
> -to provide indemnification to ARIN
> -to verify that the data in the transfer request ticket is accurate
> -to agree to all terms and release the rights to the Internet number resources contained in the specified transfer ticket.
>  
> As you can see there is really no comparison to the two separate and distinct documents that serve two very different purposes.
>  
> If there is further information required please reply and we will get that out to the list.
>  
> Thanks,
> John S.
>  
>  
> From: Sylvain Baya <abscoco at gmail.com <mailto:abscoco at gmail.com>>
> Date: Monday, June 27, 2022 at 11:33 AM
> To: John Sweeting <jsweeting at arin.net <mailto:jsweeting at arin.net>>
> Cc: Tom Fantacone <tom at iptrading.com <mailto:tom at iptrading.com>>, ARIN PPML <arin-ppml at arin.net <mailto:arin-ppml at arin.net>>
> Subject: [arin-ppml] Draft Policy ARIN-2022-3: Remove Officer Attestation Requirement for 8.5.5
>  
> Dear ARIN-PPML, 
>  
> Please find my comments below, inline...
> Thanks.
> 
> Le lundi 27 juin 2022, John Sweeting <jsweeting at arin.net <mailto:jsweeting at arin.net>> a écrit :
> Hi PPML,
>  
> Please be patient on this one. There is a lot of incorrect information reference these two forms 
>  
>  
> Hi John,
> Thanks for confirming this, brother :'-(
>  
>  
>  
> and we will be sending out a clarification to this list later this morning with exact details of each form.
>  
>  
> Great!
> ...i look forward to obtaining authoritative insights :-)
>  
> Shalom,
> --sb.
>  
>  
>  
> Thanks,
> John S.
>  
> From: ARIN-PPML <arin-ppml-bounces at arin.net <mailto:arin-ppml-bounces at arin.net>> on behalf of Tom Fantacone <tom at iptrading.com <mailto:tom at iptrading.com>>
> Date: Monday, June 27, 2022 at 6:57 AM
> To: Sylvain Baya <abscoco at gmail.com <mailto:abscoco at gmail.com>>
> Cc: ARIN PPML <arin-ppml at arin.net <mailto:arin-ppml at arin.net>>
> Subject: Re: [arin-ppml] Draft Policy ARIN-2022-3: Remove Officer Attestation Requirement for 8.5.5
>  
> I don't believe either form (Acknowledgement or Attestation) are currently optional.  Only the Acknowledgement form needs to be notarized, however.
>  
>  
>  
> ---- On Sun, 26 Jun 2022 17:58:21 -0400 Sylvain Baya <abscoco at gmail.com <mailto:abscoco at gmail.com>> wrote ---
>  
>  
>  
> [...]
>  
>  
>  
> 
> 
> 
> -- 
> Best Regards !
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