On 17 Jul 2017, at 9:47 AM, [email protected] wrote:
> ,,,
> This is the problem.  ARIN is not a carrier.  While disclosure to ARIN to 
> obtain number resources for the connection is OK, Public disclosure by or at 
> the direction of ARIN policy of elements like domain name, name, address and 
> telephone number is not.  Since name, address, telephone number and domain 
> name have already been identified have been defined in the order as elements 
> of CPNI that are protected, world disclosure by ARIN or because of ARIN rules 
> would not be a protected disclosure.
> 
> The ISP might also be in trouble for providing the information to ARIN, if 
> they know that ARIN intends to publish this information in a public 
> directory, rather than disclosing it to ARIN solely to maintain number 
> resources.  As suggested by the OP, might have to call them customer 1-n. 
> However that would violate the NRPM as written.  Since the City, State and 
> Zip Code are part of the address, even the "protected" residential records 
> CPNI are being disclosed in violation of the CPNI Order.
> 
> There is a big difference between disclosure to ARIN for taking care of 
> numbering policy, and disclosure to the entire world.  Third party disclosure 
> is the main thing that the CPNI rules are intended to address. That is only 
> permitted when it is needed for the provision of service.

Compliance with registry policy is indeed necessary to receive number 
resources; 
it is up to you to determine whether IP number resources are necessary for 
provision 
of your Internet services.  

If you choose not to make use of Internet Numbers Registry System resources for 
provision of Internet services (or not assign them to your customers), then 
that is 
your choice.   Some ISPs may feel that it is necessary to seek consent of 
customers 
who wish to have public IP number resources assigned in the size that would 
result in
their publication in the public registry, whereas others may not based on their 
reading
of applicable regulations regarding handling of CPNI information.  Such choices 
are 
an operational and business matter left to each ISP to decide based on their 
individual 
understanding and circumstances.

Thanks!
/John

John Curran
President and CEO
ARIN


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