I like the 60 month restriction and finds it adequate as a mechanism to discourage fraud.

I don't think a complete prohibition on transfers is necessary, just a significant delay so those who are really committed in using the resources as they should and not to especulate or stockpiling can do things in an appropriate manner when the time comes for them.

Regards
Fernando Frediani

On 08/07/2019 14:56, Andrew Dul wrote:
Hello,

With the ARIN board recently adopting the AC's recommendation to re-instate the wait-list policy, we should now reconsider this draft policy to the wait-list policy in light of those changes. In the AC's recommendation, a 60 month transfer restriction was placed on any block received from the wait-list starting with the re-implementation of the policy.

Do you feel this 60 month restriction is sufficient?


This draft policy calls for prohibition on non M&A transfers and restricts M&A transfers to the same purpose as requested under the wait-list policy.

Would you prefer a complete prohibition on transfer of these blocks?  Should an exception & restrictions be allowed for M&A transfers?


Your input here is helpful to help the AC determine if this draft policy should be updated to reflect the recently adopted re-instated wait-list policy text or if this draft policy should now be abandoned given the 60 month restriction in the current wait-list policy.


Thanks,

Andrew


On 5/21/2019 11:06 AM, ARIN wrote:
On 16 May 2019, the ARIN Advisory Council (AC) accepted "ARIN-prop-274: No Specified Transfers for 4.1.8.2 Blocks" as a Draft Policy.

Draft Policy ARIN-2019-14 is below and can be found at:
https://www.arin.net/participate/policy/drafts/2019_14/


Draft Policy ARIN-2019-14: No Specified Transfers for 4.1.8.2 Blocks

Problem Statement:

The ARIN “Unfulfilled Requests” policy creates an opportunity for an ARIN member to claim need for number resources, wait for those resources to become available via returns or reclamations, acquire them (per 4.1.8.2 of the NRPM), wait a day after the mandatory “hold time”, and then profit from them via a specified transfer transaction.

This waiting list policy freely provides number resources, creating an incentive for profit-taking through fraudulent applications or making misrepresentations to registration services.

ARIN can avoid this problem by prohibiting non-8.2 transfers for blocks distributed under 4.1.8.2 using language very similar to policy elsewhere in the NRPM.

Policy Statement:

Add a second paragraph to 4.1.8.2:

IP allocations issued through 4.1.8.2 are non-transferable via section 8.3 and section 8.4. In the case of a section 8.2, transfer of the IP assignment must be utilized for the same purpose or needs justified used for the original 4.1.8 application.

Comments:

Timetable for implementation: Immediate
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