For the record, I support the policy. The problematic language in the NRPM is this:

"Source entities within the ARIN region must not have received a transfer, allocation, or assignment of IPv4 number resources from ARIN for the 12 months prior to the approval of a transfer request. This restriction does not include M&A transfers."

It means that if I go start a new company, and I buy a big chunk of address space for my existing plans (which meet the 24-month need assessment), and then get a contract that requires that some of that space be registered elsewhere for legal reasons (e.g., China), I need to either A) sit around and not fulfill the contract until the 12 month timer runs out (and hope I have no other reason to acquire addresses on the transfer market in the meantime) or B) buy more addresses that are already in the region I need them to be in, even though I have plenty of addresses in hand already and would rather not buy more addresses than I need.

That makes no sense at all. Fixing the policy does.

Matthew Kaufman

ps. The language also suggests that any time you buy addresses from someone, you should buy a little shell company to go with them so that you can process it as an (exempted) 8.2 transfer.
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