I remain opposed to this proposal for the same reasons stated before.
I don't see what can avoid that someone to register a new company, get
into the waiting list, receive an allocation and right after that be
"purchased" by another company which is not entitled to be in the
waiting list anymore bypassing the 60 months restriction.
Although it may not be the easiest thing to do deal with all paperwork,
bureaucracy and register company, depending on the rising price of IPv4
in the market someone may find that became worth the efforts and this
could (not right now, but at some point in the future) turn into a way
to bypass the waiting list restriction as the mathematics will cover all
the costs involved in the whole transaction.
This proposal may bring an issue in such scenario and perhaps there
should still be some minimal time restriction that makes it more
difficult for fraudsters to act with such intention.
Fernando
On 21/07/2020 12:02, ARIN wrote:
On 16 July 2020, the ARIN Advisory Council (AC) advanced the following
Draft Policy to Recommended Draft Policy status:
ARIN-2020-1: Clarify Holding Period for Resources Received via 4.1.8
Waitlist
The text of the Recommended Draft Policy is below, and may also be
found at:
https://www.arin.net/participate/policy/drafts/2020_1/
You are encouraged to discuss all Recommended Draft Policies on PPML
prior to their presentation at the next ARIN Public Policy
Consultation (PPC). PPML and PPC discussions are invaluable to the AC
when determining community consensus.
The PDP can be found at:
https://www.arin.net/participate/policy/pdp/
Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/participate/policy/drafts/
Regards,
Sean Hopkins
Policy Analyst
American Registry for Internet Numbers
Recommended Draft Policy ARIN-2020-1: Clarify Holding Period for
Resources Received via 4.1.8 Waitlist
AC Assessment of Conformance with the Principles of Internet Number
Resource Policy:
Recommended Draft Policy ARIN-2020-1 (“RDP 2020-1”) clarifies that
IPv4 address space distributed from the waitlist will not be eligible
for transfer for a period of 60 months with the exception of transfers
under section 8.2 of the ARIN Number Resource Policy Manual (“NRPM”).
RDP 2020-1 enables fair and impartial number resource administration
by eliminating an ambiguity concerning whether NRPM section 8.2
transfers constitute an intended exception to the 60 month hold period
under the waitlist policy. RDP 2020-1 is technically sound by
fostering clarity and consistency in the application of the waitlist
policy, while meeting community needs expressed in section 8.2 of the
NRPM, all of which contributes to improved directory accuracy. RDP
2020-1 enjoys community support.
Problem Statement:
A recent Policy Experience Report reported ambiguity on the part of
customers as to whether or not the 60-month restriction on
transferring resources received via NRPM Section 4.1.8 applies to M&A
transfers under NRPM Section 8.2. This proposal clarifies this
restriction to exempt 8.2 transfers from this restriction.
Policy Statement:
Update NRPM Section 4.1.8 as follows:
Original Text: Address space distributed from the waitlist will not be
eligible for transfer for a period of 60 months.
New Text: Address space distributed from the waitlist will not be
eligible for transfer, with the exception of Section 8.2 transfers,
for a period of 60 months.”
Timetable for Implementation: Immediate
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