The intent here is to clarify that a reorganization is not required to go through the larger process of showing that assets were acquired and the other needs testing that is currently done on mergers & acquisitions.
Andrew > On Oct 5, 2015, at 3:26 PM, Azinger, Marla <[email protected]> wrote: > > It looks like all that was changed was they added the word “re-organization”. > Am I missing some other text change? > > Regards > Marla Azinger > > -----Original Message----- > From: [email protected] [mailto:[email protected]] On > Behalf Of ARIN > Sent: Tuesday, July 21, 2015 10:33 AM > To: [email protected] > Subject: [arin-ppml] Recommended Draft Policy ARIN-2015-4: Modify 8.2 section > to better reflect how ARIN handles reorganizations > > Recommended Draft Policy ARIN-2015-4 > Modify 8.2 section to better reflect how ARIN handles reorganizations > > On 16 July 2015 the ARIN Advisory Council (AC) recommended > ARIN-2015-4 for adoption, making it a Recommended Draft Policy. > > ARIN-2015-4 is below and can be found at: > https://www.arin.net/policy/proposals/2015_4.html > > You are encouraged to discuss Draft Policy 2015-4 on the PPML prior to the > ARIN Public Policy Consultation at ARIN 36 in Montreal in October 2015. Both > the discussion on the list and at the meeting will be used by the ARIN > Advisory Council to determine the community consensus for adopting this as > policy. > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/pdp.html > > Draft Policies and Proposals under discussion can be found at: > https://www.arin.net/policy/proposals/index.html > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > ## * ## > > > Recommended Draft Policy ARIN-2015-4 > Modify 8.2 section to better reflect how ARIN handles reorganizations > > Date: 21 July 2015 > > AC's assessment of conformance with the Principles of Internet Number > Resource Policy: > > 2015-4 is largely editorial in nature and does not change policy > implementation, but clarifies existing use of policy. The proposal is fair in > that it provides a consistent interface for transfers and clarifies the > transfer policy. It is technically sound in that it is already effectively > implemented. The proposal has received support on the mailing list and we > expect it to be generally supported by the community as it is the direct > result of community feed back on the existing policy. > > Problem Statement: > > ARIN staff indicated that NRPM 8.2 does not clearly indicate how ARIN > procedures handle reorganizations. ARIN staff indicated that the first policy > bullet point does not apply to reorganizations. > > Policy statement: > > Replacement text for entire 8.2 section: > > 8.2. Mergers, Acquisitions, and Reorganizations > > ARIN will consider requests for the transfer of number resources in the case > of mergers, acquisitions, and reorganizations under the following > conditions: > > -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. > > -For mergers and acquisition transfers, the recipient 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. > > In the event that number resources of the combined organizations are no > longer justified under ARIN policy at the time ARIN becomes aware of the > transaction, through a transfer request or otherwise, ARIN will work with the > resource holder(s) to return or transfer resources as needed to restore > compliance via the processes outlined in current ARIN policy. > > Comments: > > The problem statement is addressed by: > > -re-title 8.2 > > -clarify the documentation bullet point > > -rearrange the documentation bullet to the end of the list since it only > applies to some requestors, while the other bullet points apply to all > requestors. > > a.Timetable for implementation: Immediate > > b.Anything else > > ##### > > ARIN STAFF & LEGAL ASSESSMENT > Draft Policy ARIN-2015-4 > Modify 8.2 section to better reflect how ARIN handles reorganizations > https://www.arin.net/policy/proposals/2015_4.html > > Date of Assessment: July 14, 2015 > > ___ > 1. Summary (Staff Understanding) > This proposal would provide clarification to the 8.2 transfer policy for > reorganizations. It does this by adding "reorganizations" to the title, and > clarifies that evidence of acquired assets is only required for merger and > acquisition transfers; not reorganizations. > > ___ > 2. Comments > A. ARIN Staff Comments > This proposal can be implemented as written. Minimal staff training and > preparation would be needed to implement this if it were to become policy. > The proposal clarifies a point about reorganizations that has been confusing > to customers in the past. We see no negative impacts. > > B. ARIN General Counsel – Legal Assessment Counsel sees no material legal > issues in this policy. > > ___ > 3. Resource Impact > This policy would require minimal staff training and preparation. We see no > negative impacts. > > ___ > 4. Proposal / Draft Policy Text Assessed > > Draft Policy ARIN-2015-4 > > Modify 8.2 section to better reflect how ARIN handles reorganizations > > Problem Statement: > > ARIN staff indicated that NRPM 8.2 does not clearly indicate how ARIN > procedures handle reorganizations. ARIN staff indicated that the first policy > bullet point does not apply to reorganizations. > > Policy statement: > > Replacement text for entire 8.2 section: > > 8.2. Mergers, Acquisitions, and Reorganizations > > ARIN will consider requests for the transfer of number resources in the case > of mergers, acquisitions, and reorganizations under the following > conditions: > > -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. > -For mergers and acquisition transfers, the recipient 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. > > In the event that number resources of the combined organizations are no > longer justified under ARIN policy at the time ARIN becomes aware of the > transaction, through a transfer request or otherwise, ARIN will work with the > resource holder(s) to return or transfer resources as needed to restore > compliance via the processes outlined in current ARIN policy. > > Comments: > > The problem statement is addressed by: > > -re-title 8.2 > -clarify the documentation bullet point > -rearrange the documentation bullet to the end of the list since it only > applies to some requestors, while the other bullet points apply to all > requestors. > > a.Timetable for implementation: Immediate > > b.Anything else > _______________________________________________ > PPML > You are receiving this message because you are subscribed to the ARIN Public > Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues. > > ________________________________ > > This communication is confidential. Frontier only sends and receives email on > the basis of the terms set out at http://www.frontier.com/email_disclaimer. > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues. _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]). Unsubscribe or manage your mailing list subscription at: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected] if you experience any issues.
