> On Jul 21, 2020, at 11:29 AM, Fernando Frediani <[email protected]> wrote: > > 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.
Remember that the waitlist is section 4.1.8; it is an animal of section 4 and therefore the “show need” requirements are much more stringent than for 8.3 (specified transfer). A new company (that has no previous history with ARIN and no reassignments from upstreams) will qualify for a /24 (see 4.2.2). > 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. Sure, and tweaks over time may become necessary if this turns out to not be enough friction for a shady transaction. I don’t believe anyone ever thought this will 100.000% eliminate all questionable transactions, only that by keeping a lid on the upside for gaming the system we could minimize the harm without making things unduly difficult on organizations that need space but can wait for it. > 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. The counter argument is that putting such time restrictions in place is not aligned with accuracy in whois, which is of benefit to everyone. > > Fernando -r > > 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 >> >> >> _______________________________________________ >> 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. > _______________________________________________ > 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. _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]). 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