I think this is a load of baloney. The requirement can be EASILY modified to only contact a RANDOMLY SELECTED SUBSET this is EXACTLY how auditing firms check validity.

You can simply modify it to say that instead of contacting every indirect POC every year that you are going to select a random group of POCs and contact them - this will verify if the subnet holders are filing SWIPS that are accurate or if they are just making up stuff to meet utilization requirements.

That way the indirect POC holders will never know if this year they are going to be contacted or not - thus they have an incentive to maintain accurate records.

If ARIN is having trouble NOW with validating indirect POCs then it is CRYSTAL CLEAR that the direct allocation holders ARE SHIRKING THEIR
REQUIREMENT FOR HONESTY AND ACCURACY.  The solution of "oh they are
being a bunch of LAZY ASSES and not keeping their paperwork up so we are just going to eliminate the requirement" is to me kind of like saying that since the convicted felon out on parole is not honoring his probation terms and checking in with his probation officer, that we are just going to end his probation.

Clearly the author of this recommendation was one of those kids who got
First prizes for "participation" and other such rubbish when he was growing up.


Ted

On 12/20/2016 10:09 AM, ARIN wrote:
On 15 December 2016, the ARIN Advisory Council (AC) advanced the
following Proposal to Draft Policy status:

ARIN-prop-233: Removal of Indirect POC Validation Requirement

This Draft Policy has been numbered and titled:

Draft Policy ARIN-2016-8: Removal of Indirect POC Validation Requirement

Draft Policy text is below and can be found at:
https://www.arin.net/policy/proposals/2016_8.html

You are encouraged to discuss all Draft Policies on PPML. The AC will
evaluate the discussion in order to assess the conformance of this draft
policy with ARIN's Principles of Internet Number Resource Policy as
stated in the Policy Development Process (PDP). Specifically, these
principles are:

 > Enabling Fair and Impartial Number Resource Administration
 > Technically Sound
 > Supported by the Community

The PDP 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,

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)

##########

ARIN-2016-8: Removal of Indirect POC Validation Requirement

Problem Statement:

There are over 600,000 POCs registered in Whois that are only associated
with indirect assignments (reassignments) and indirect allocations
(reallocations). NRPM 3.6 requires ARIN to contact all 600,000+ of these
every year to validate the POC information. This is problematic for a
few reasons:

1) ARIN does not have a business relationships with these POCs. By
conducting POC validation via email, ARIN is sending Unsolicited
Commercial Emails. Further, because of NRPM 3.6.1, ARIN cannot offer an
opt-out mechanism. Finally, ARIN's resultant listing on anti-spam lists
causes unacceptable damage to ARIN's ability to conduct ordinary
business over email

2) ARIN has previously reported that POC validation to reassignments
causes tremendous work for the staff. It receives many angry phone calls
and emails about the POC validation process. I believe the ARIN staff
should be focused on POC validation efforts for directly issued
resources, as that has more value to internet operations and law
enforcement than end-user POC information.

Policy statement:

Replace the first sentence of 3.6.1:

"During ARIN's annual Whois POC validation, an email will be sent to
every POC in the Whois database."

with

"During ARIN's annual Whois POC validation, an email will be sent to
every POC that is a contact for a direct assignment, direct allocation,
reallocation, and AS number, and their associated OrgIDs."

Timetable for implementation: Immediate
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