Hi Tom, I agree with your point that the transfer market has been an excellent vehicle for moving space around the ARIN community. If people want to lose 15% of their money to a broker vs. finding a buyer themselves, that is up to them. I don’t think this constitutes bad behavior to any parties involved and I am definitely for brokerage services operating in the space.
> Furthermore, even within the waiting list, the problem appears with only a > small percentage of recipients (25 re-transfers out of 682 total), although > this does impact a high percentage of the waiting list block space since the > abusers are almost entirely doing this with larger blocks. > Yes, its possible there is abuse with the small blocks off the waiting list > as well, but so far we arent seeing it (only 3% of smaller blocks have been > re-transferred vs. 42% of the larger blocks). Now, perhaps if we restrict > the waiting list block size to a /22 these bad actors will start playing the > same game with /22s, but we dont have any evidence that will occur. As I have mentioned on at least 2 occasions in the past few days; the re-transfers statistics are not an indication of the actual scale of the fraud problem we have here in the community. It is in ARIN’s policies that re-transfers are under careful supervision, and I’m sure any smart criminal wouldn’t think to transfer it out immediately but rather sub-lease the space in the meantime. Why are you clinging to the re-transfer stats and not acknowledging the basic misalignment of incentives with the current system? Best Regards, Robert Clarke CubeMotion LLC [email protected] M: +1 (844) 244-8140 ex. 512 300 Lenora Street #454, Seattle, WA, 98121 > On Mar 1, 2019, at 10:26 AM, Tom Fantacone <[email protected]> wrote: > > Hi Bill, > > At 06:35 PM 2/28/2019, William Herrin wrote: >> On Tue, Feb 26, 2019 at 9:49 AM ARIN <[email protected]> wrote: >> > A significant percentage of organizations that receive blocks >> > from the waiting list subsequently issue these blocks to other >> > organizations via 8.3 or 8.4 transfers shortly after the one year >> > waiting period required before engaging in such outbound transfers. >> >> I'm shocked to learn that people are playing arbitrage with the >> transfer process. Oh wait, no I'm not. I may have even expressed my >> expectation that we'd see this sort of behavior back when we debated >> the transfer policies. If I had the time, I might dig out my old >> emails just so I could say I told you so. > > While we have a problem with the waiting list that were trying to address > here, I think it's important to point out that the transfer market as a whole > has proven an excellent vehicle for moving number resources from those who no > longer need them to those who do. This gaming of the system is restricted > to a subset of the waiting list, and the number of blocks issued on the > waiting list is less than 10% of the blocks transferred in the ARIN region > during the same time period. (682 blocks have been issued via the waiting > list, and a quick look at ARINs transfer stats indicates roughly 8,000 > blocks transferred in the same time frame since 2015 if Im reading it > correctly). If we look at the ratio in terms of total address space, I > suspect the waiting list comprises an even smaller percentage, though I cant > readily find those figures. > > Furthermore, even within the waiting list, the problem appears with only a > small percentage of recipients (25 re-transfers out of 682 total), although > this does impact a high percentage of the waiting list block space since the > abusers are almost entirely doing this with larger blocks. > > The point is that while The problem statement is pretty damning > (quoting Kevin Blumberg), the sky is not falling due to the transfer > markets. Its damning within the small subset of re-transfers of blocks > received off the waiting list. > >> > the organization will be provided the option to be placed on >> > a waiting list of pre-qualified recipients, listing both the block size >> > qualified for or a /22, whichever is smaller, and the smallest block >> > size acceptable, not to exceed a /22. >> >> I fail to see how this solves the problem. For $20k a pop, I can clear >> a tidy profit on a year, a shell company and some paperwork. Sure I'd >> rather get $200k a pop but the change doesn't make the effort >> unattractive. I really just need to create more shell companies. >> >> This approach is reactive. Oh, the fraud is mostly on the big blocks >> so stop that. Oh, now the fraud is on the smaller blocks, what do we >> do? Don't react. Get ahead of the problem. That's what you do. > > Yes, its possible there is abuse with the small blocks off the waiting list > as well, but so far we arent seeing it (only 3% of smaller blocks have been > re-transferred vs. 42% of the larger blocks). Now, perhaps if we restrict > the waiting list block size to a /22 these bad actors will start playing the > same game with /22s, but we dont have any evidence that will occur. > > Others have pointed out issues of abuse in RIPE where LIRs are spun up to > grab /22s from the final /8, but the 2 environments are different. First, > there is no justification requirement in RIPE. Form a corp, have a presence > in the RIPE region, and you get a /22 whether you can justify it or not. > That may not exactly be a noble action in support of the spirit of the RIPE > community, but for the most part, it is policy-compliant. In ARIN, you have > to justify your need and sign an affidavit affirming your justification which > makes willful misrepresentation fraudulent. Thats a much higher > disincentive to go through for a /22 than in RIPE, where basically its just > frowned upon. And per John Currans remarks, ARIN has revoked address space > when investigating why some of these actors are selling their waiting list > space shortly after receiving it. So these gamers could risk an audit of > their full address holdings in order to con ARIN out of a /22. The abuse > in RIPE regarding the final /8 is also heavily concentrated in a few member > nations and, suffice it to say, those same nations are not ARIN members. > > Regards, > > Tom > > > _______________________________________________ > ARIN-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: > https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues.
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