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

[Adam Thompson]

I approve, tentatively, of the new policy.  In many situations, officer attestation is a punitively-high bar, preventing certain organizations from accessing the resources and/or services they need and should have access to.

In any organization of any size, the networking staff can be 4 or 5 layers away from a corporate officer (as typically defined by the local Corporations Act or similar).  Considering how much political/social capital I have to expend to even send an email that many rungs up the ladder, never mind get an attestation, leads to the "punitive" comment above.

The current language also fails to address non-corporate clients, of which there are many (myself included) - who's an officer of my organization, King Charles III?  An elected official?  A bureaucrat?  Conversely (IIRC...) every "professional" grade employee of the Province is styled an "Officer of the Civil Service", so can I just attest everything myself?  I think there used to be language defining this, but I can't find it right now - did it get deleted with previous deletions of language concerning attestation?  Or maybe I just haven't woken up enough yet?

If I could think of a replacement text that included some assurance that the org, as a whole, was on board with a request (transfer, in this case) that doesn't have gaps at least as large as the current wording, I'd suggest that instead.  But if it's functionally impossible or implausible to craft a broad policy that applies to all ARIN clients equally, then no policy is better than a flawed policy, in this case.

In short - good idea; flawed implementation; I do not believe it currently helps more than it hinders; ergo it should be removed.  

Note that I'm still on the make-accessing-services-easier side of things, not on the apply-restrictions-to-make-it-harder side.  I remain far more concerned about the accuracy of ARIN's database(s) than I am about fraudulent use of resources.
 
-Adam

Adam Thompson
Consultant, Infrastructure Services
MERLIN
100 - 135 Innovation Drive
Winnipeg, MB R3T 6A8
(204) 977-6824 or 1-800-430-6404 (MB only)
https://www.merlin.mb.ca
Chat with me on Teams: athompson at merlin.mb.ca

> -----Original Message-----
> From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of Joe Provo
> Sent: September 12, 2022 11:51 AM
> To: arin-ppml at arin.net
> Subject: Re: [arin-ppml] Draft Policy ARIN-2022-3: Remove Officer
> Attestation Requirement for 8.5.5
> 
> 
> Hey folks,
> 
> We haven't had any feedback here after the publication
> of the Staff & Legal review as noted in Matthew's message
> below.  Given that it speaks directly to concerns raised
> here on PPML, we need community feedback here to confirm
> *our* impressions.
> 
> Please let us know!
> 
> Joe
> 
> 
> On Wed, Aug 24, 2022 at 12:50:13PM -0700, Matthew Wilder wrote:
> > Hi PPML,
> >
> > Staff and Legal review has been conducted for Draft Policy ARIN-2022-3.
> The
> > relevant bit for the community to consider is the legal review, which is
> as
> > follows:
> > "No material legal issue. Removal of the officer attestation would not
> > materially impact ARIN???s ability to pursue cases of fraud."
> >
> > As shepherds, we believe this directly resolves the primary concern voiced
> > by members of the community.
> >
> > For the full staff and legal review, please check the following:
> > https://www.arin.net/participate/policy/drafts/2022_3/#staff-and-legal-
> review-15-august-2022
> >
> > Regards,
> >
> > *Matthew Wilder*
> >
> >
> > On Wed, Aug 3, 2022 at 12:24 PM Matthew Wilder <matthew.wilder at telus.com>
> > wrote:
> >
> > > Hi PPML,
> > >
> > > I appreciate the lively discussion thus far on ARIN-2022-3, including
> > > concerns around what prosecutorial powers might be lost if officer
> > > attestations are no longer required. Thanks also to staff for
> summarizing
> > > the result of the ACSP Consultation 2021.4 retiring the officer
> attestation
> > > requirement for documentation of needs assessment.
> > >
> > > The prevailing concern in the community around ARIN-2022-3 appears to be
> > > that removing officer attestation would impede the prosecution of those
> > > conducting fraud. In order to have the experts address this concern, I
> > > (along with my fellow policy shepherd Joe) have requested a staff and
> legal
> > > review. Our hope is that staff (and legal counsel in particular) might
> > > directly weigh in on how important the officer attestation is.
> > >
> > > We will make sure that relevant points are highlighted back to PPML for
> > > the community to consider in further discussion of the draft policy.
> > >
> > > Warm regards,
> > >
> > > *Matthew Wilder*
> > >
> 
> > _______________________________________________
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> 
> 
> --
> Posted from my personal account - see X-Disclaimer header.
> Joe Provo / Gweep / Earthling
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