I strongly oppose this draft policy. Preventing transfers because someone else 
prevents transfers is not helpful. 

Scott

> On Jun 20, 2017, at 10:37 AM, ARIN <[email protected]> wrote:
> 
> On 15 June 2017, the ARIN Advisory Council (AC) advanced "ARIN-prop-241: 
> Improve Reciprocity Requirement for Inter-RIR Transfers" to Draft Policy 
> status.
> 
> Draft Policy ARIN-2017-6 is below and can be found at:
> https://www.arin.net/policy/proposals/2017_6.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)
> 
> 
> 
> Draft Policy ARIN-2017-6: Improve Reciprocity Requirement for Inter-RIR 
> Transfers
> 
> Problem Statement:
> 
> Currently ARIN's requirement that inter-RIR transfer policies be reciprocal 
> has a glaring hole in it in that RIRs which have NIRs and/or a two-hop RIR 
> transfer process can be used to circumvent the intent of the requirement. 
> Rather than eliminate the requirement, a better approach would be to close 
> the loophole.
> 
> Policy statement:
> 
> Amend section 8.4 (included here for reference):
> 
> 8.4. Inter-RIR Transfers to Specified Recipients
> 
> Inter-regional transfers may take place only via RIRs who agree to the 
> transfer and share reciprocal, compatible, needs-based policies.
> 
> Conditions on source of the transfer:
> 
> The source entity must be the current rights holder of the IPv4 address 
> resources recognized by the RIR responsible for the resources, and not be 
> involved in any dispute as to the status of those resources.
> 
> Source entities outside of the ARIN region must meet any requirements defined 
> by the RIR where the source entity holds the registration.
> 
> 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, unless either the source 
> or recipient entity owns or controls the other, or both are under common 
> ownership or control. This restriction does not include M&A transfers.
> 
> Address resources from a reserved pool (including those designated in Section 
> 4.4 and 4.10) are not eligible for transfer.
> 
> Conditions on recipient of the transfer:
> 
> The conditions on a recipient outside of the ARIN region will be defined by 
> the policies of the receiving RIR.
> 
> Recipients within the ARIN region must meet the transfer requirements as 
> defined in section 8.5.
> 
> Recipients within the ARIN region will be subject to current ARIN policies.
> 
> Make the following change:
> 
> Add an additional bullet to "Conditions on recipient" which states:
> 
> + Recipient RIR policy must not permit transfers to other RIRs or NIRs whose 
> policies do not support bi-directional transfers.
> 
> Comments:
> 
> a. Timetable for implementation: Immediate
> _______________________________________________
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