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

John Sweeting jsweeting at arin.net
Fri Sep 23 11:34:36 EDT 2022

Hi John,

Sorry for the late reply but yes ARIN would accept the individual that signed your organization’s RSA as the individual signing the attestation pursuant to NRPM 8.5.5.


John Sweeting

Begin forwarded message:

From: "John W. O'Brien" <obrienjw at upenn.edu<mailto:obrienjw at upenn.edu>>
Subject: Re: [arin-ppml] Draft Policy ARIN-2022-3: Remove Officer Attestation Requirement for 8.5.5
Date: 14 September 2022 at 12:44:53 PM EDT
To: <ppml at rsuc.gweep.net<mailto:ppml at rsuc.gweep.net>>, "arin-ppml at arin.net<mailto:arin-ppml at arin.net>" <arin-ppml at arin.net<mailto:arin-ppml at arin.net>>

Signed PGP part
Much of the opposition to the draft is due to the real or perceived difficulty that a member of the networking staff would have in obtaining the required officer attestation.

About a year ago, Penn placed its legacy IPv4 number resources under the LRSA, which also required executing a revised RSA to true up the ORG's formal name. Those contracts were signed on the "Authorized Officer" line by the same IT Procurement Specialist who signs contracts to buy routers and switches and so forth. As a practical matter, would ARIN accept an attestation pursuant to the current 8.5.5 requirement that was signed by that same individual?

Forgive me if I missed the answer to this question earlier in the thread.

I neither support nor oppose this draft at this time.


On 9/12/22 12:51 PM, Joe Provo wrote:

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!
On Wed, Aug 24, 2022 at 12:50:13PM -0700, Matthew Wilder wrote:


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
"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:


*Matthew Wilder*

On Wed, Aug 3, 2022 at 12:24 PM Matthew Wilder <matthew.wilder at telus.com<mailto:matthew.wilder at telus.com>>


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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