I support.

I think this will go a long way in getting correct POC's in the database at the start. Currently, whoever is doing the ordering might end up with their contacts in the database, because that is the only information that the service provider has. This is how we end up with purchasing or accounting contacts in Whois who have no clue as to abuse complaints and/or the annual validation email. This will force the service provider to actually ASK who the company wants as a Whois contact, and to explain to them what duties this involves, including a reminder of the annual validation email that they need to respond to.

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Mon, 12 Mar 2018, Christian Tacit wrote:

Dear Community Members,

The shepherds for the Draft Policy 2017-12: Require POC Validation Upon 
Reassignment, are making two changes to its text.

First, the problem statement is being expanded a bit to explain how POCs for reassigned blocks can be assigned without the knowledge of the individuals so assigned under the present policy.

Second, proposed section 3.8 has been deleted. This is because it is unintentionally misleading because a simple reassignment results in a customer identifier versus an OrgID. There is no contact information contained in a simple reassignment other than street address that could be used for notification, and thus it does not appear that the proposed NRPM 3.8 policy text is implementable. Even if notification were possible, the "OR postal address" in this section may also cause significant problems for some companies as many companies have the same name associated with many different locations and there are several locations that have many companies registered there.

Based on these changes, the revised text reads:

Version Date: March 12, 2018

Problem Statement:

Some large ISPs assign individuals to be POCs for reassigned blocks without 
consultation of the individual they are inserting into Whois. For example, 
during the reassignment/reallocation process, some large ISPs automatically 
create POCs from their customer's order form. This process is automated for 
many ISPs and therefore the resulting POCs are not validated prior to being 
created in the ARIN Whois database. This creates unknowing POCs that have no 
idea what Whois is or even who ARIN is at the time they receive the annual POC 
validation email. It can also create multiple POCs per email address causing 
that same person to receive a multitude of POC Validation emails each year.

This policy proposal seeks to improve the situation where a POC is unwittingly 
and unintentionally inserted into Whois.

It also seeks to mitigate the significant amount of time that ARIN staff 
reports that they spend fielding phone calls from POCs who have no idea they 
are in Whois.

Finally, it is hopeful that this proposal will improve the overall POC 
validation situation, by forcing ISPs and customers to work together to insert 
proper information into Whois at the time of sub-delegation.

Policy statement:

Insert one new section into NRPM 3:

3.7 New POC Validation Upon Reassignment

When an ISP submits a valid reallocation or detailed reassignment request to 
ARIN which would result in a new POC object being created, ARIN must (before 
otherwise approving the request) contact the new POC by email for validation. 
ARIN's notification will, at a minimum, notify the POC of:

- the information about the organization submitting the record; and
- the resource(s) to which the POC is being attached; and
- the organization(s) to which the POC is being attached.

If the POC validates the request, the request shall be accepted by ARIN and the 
new objects inserted into Whois.  If the POC does not validate the request 
within 10 days, ARIN must reject the request.

Timetable for implementation: Immediate

Comments from the community are welcome!

Christian S. Tacit

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