Draft Policy ARIN-2012-8: Aligning 8.2 and 8.3 Transfer Policy [Archived]

Status: NRPM 8.2

Tracking Information

Discussion Tracking

Mailing List:

Formal introduction on PPML on 5 September 2012

Origin - ARIN-prop-175

Draft Policy - 5 September 2012 (with staff assessment)

Remains on AC’s docket - 31 October 2012

Revised - 19 November 2012

Revised staff assessment - 10 December 2012

Last call - 27 December 2012 through 15 January 2013

New Policy Development Process - 14 January 2013

AC recommended adoption - 31 January 2013

Adopted, to be implemented no later than 31 March 2013

Implemented - 20 March 2013

Public Policy Mailing List

ARIN Public Policy Meeting:

ARIN XXX

ARIN Advisory Council:

AC Shepherds:
Chris Grundemann and David Farmer

• 16 August 2012
• 20 September 2012
• 26 October 2012
• 15 November 2012
• 20 December 2012
• 25 January 2013

ARIN Board of Trustees:

15 February 2013

Revisions:

Previous version(s)

Implementation:

20 March 2013

Draft Policy ARIN-2012-8
Aligning 8.2 and 8.3 Transfer Policy

Date: 27 December 2012

Policy statement:

Replace the first paragraph of section 8.2 with the following (second paragraph remains unchanged):

ARIN will consider requests for the transfer of number resources in the case of mergers and acquisitions under the following conditions:

• The new entity must provide evidence that they have acquired assets that use the resources to be transferred from the current registrant. ARIN will maintain an up-to-date list of acceptable types of documentation.
• The current registrant must not be involved in any dispute as to the status of the resources to be transferred.
• The new entity must sign an RSA covering all resources to be transferred.
• The resources to be transferred will be subject to ARIN policies.
• The minimum transfer size is the smaller of the original allocation size or the applicable minimum allocation size in current policy.

Rationale:

The base intent here is to lower confusion, raise clarity, and level the bar between 8.2 and 8.3 transfers. M&A transfers are distinct from specified transfers and not all of the same rules can apply - but many can and should. Therefor this policy change explicitly adds requirements which do not exist in 8.2 policy text today: Source must be the undisputed current registered holder, recipient must sign an RSA (and is subject to policy), and /24 minimum for IPv4, /48 for IPv6.

Changes following discussion at the ARIN XXX public policy meeting: 1) Changed the first bullet. This was an area for objections because it did not allow chain of custody transfers, so now instead of saying that the purchased company must be the current registrant holder it simply says that there can not be any dispute as to who the registered holder is. 2) Removed the " such that their continued need is justified" text from the second bullet, this was another area of debate at the meeting and justification is already covered in paragraph 2 of 8.2 (which remains unchanged). 3) Swapped the first two bullets. 4) Added “covering all transferred resources” to the RSA bullet, for clarity. 5) Swapped the third and fourth bullets. 3) Altered the IPv4 minimum allocation to bring it in line with 4.10 resources and any future exceptions.

Changes following PPML discussion in November 2012: a) ‘used’ was changed back to ‘use’ in the first bullet to prevent a backdoor around specified transfers leveraging asset liquidation. b) The third bullet was shortened for clarity (removed the word ‘current’ before ‘policy’) c) The minimum transfer sizes are now pinned to policy rather than hard-set.

Timetable for implementation: immediate