Hi Noah, Thank you for your response. Your perspective is noted.
Regards, Matthew On Thu., Jun. 23, 2022, 10:07 a.m. Noah, <[email protected]> wrote: > Hi Matthew > > In my humble opinion, attestation is a very fundamental obligation and > responsibility. The obligator is accountable and lack of accountability is > what creates room for fraud. > > Removing a means by which the parties involved are able to retain > confidence in the process is rather unwise. > > If the party in Authority is aware of the transfer transaction, then let > them legitimize that awareness by attesting and in case of fraudsters > gaming the process, then folks at ARIN or parties involved would have a > starting point in ref: accountability. > > The premise for cost and time should not overlook the need for a > legitimate process. > > Cheers > Noah > > On Thu, 23 Jun 2022, 19:06 Matthew Wilder, <[email protected]> > wrote: > >> Hi Noah, et al. >> >> It appears that a few of you are not convinced of the problem statement >> for this Draft policy. Just a reminder this is a draft policy authored by >> the Policy Experience Working Group, to solve a customer experience problem >> identified by staff. Also, taking off my AC hat and putting on my day job >> hat for a moment - I can assure you that if you are at an organization of >> significant scale and complexity - this is indeed a real problem. In the >> case of qualification for transfers (8.5.5) this is a redundant step, in >> practice, since significant sums of money must be approved by executives in >> order to execute transfers. >> >> Swapping back to my AC hat now. To my mind, the introduction of officer >> attestations generally helped achieve two positive outcomes. First, it >> supported the principle of conservation. Second, it reduced the opportunity >> for fraud. There may be other benefits obtained by the requirement for >> officer attestation, and I am open to hearing everyone's perspective on >> this. >> >> This draft policy would do away with the need for officer attestation for >> justification of transfers, but only because the market provides the same >> benefits mentioned above. Would-be fraudsters on the transfer market would >> now face significant cost to execute a transfer, and presumably, an >> organization operating in bad faith could easily provide officer >> attestation. Similarly, documentation of an overly-optimistic plan - >> securing more resources than realistically needed - will mean a higher cost >> to the organization bankrolling the transfer. As a result, the individuals >> accountable for the organization's decisions are well aware of - and >> implicitly supportive of - the plan. An officer attestation is therefore >> redundant in both cases. >> >> To Noah and others who have voiced opposition - let me know if you see a >> case where the officer attestation in 8.5.5 protects the interests of ARIN >> and the community. >> >> Best regards, >> Matthew >> >> >> >> On Tue, Jun 21, 2022 at 9:15 PM Noah <[email protected]> wrote: >> >>> >>> >>> On Wed, 22 Jun 2022, 04:56 ARIN, <[email protected]> wrote: >>> >>>> On 16 June 2022, the ARIN Advisory Council (AC) accepted >>>> "ARIN-prop-309: Remove Officer Attestation Requirement for 8.5.5" as a >>>> Draft Policy. >>>> >>>> Draft Policy ARIN-2022-3: Remove officer attestation requirement for >>>> 8.5.5 >>>> >>>> Problem Statement: >>>> >>>> Requiring an officer attestation requires unnecessary resources and >>>> increases the time to complete an IPv4 transfer. >>>> >>>> >>>> >>>> Policy statement: >>>> >>>> >>>> >>>> 8.5.5. Block Size >>>> >>>> >>>> >>>> Organizations may qualify for the transfer of a larger initial block, >>>> or an additional block, by providing documentation to ARIN which details >>>> the use of at least 50% of the requested IPv4 block size within 24 months. >>>> >>>> >>>> >>>> Removing “An officer of the organization shall attest to the >>>> documentation provided to ARIN. >>>> >>> Using time as an excuse does not fly. Attestation is accountability and >>> enforces legitimacy. >>> >>> An authorized officer should not only be aware but MUST also be involved >>> in attesting of documents that involve any Internet Number Resources >>> transfers. >>> >>> We have experienced fast hand on the negative impact of Admin Contacts >>> being clueless to what its that Tech contacts do. >>> >>> So I oppose the policy for using time as an excuse to remove an >>> important process that ensures legitimacy. >>> >>> Noah >>> >>> _______________________________________________ >>> 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. >>> >> >> >> -- >> >> *Matthew Wilder* >> >> Sr Engineer - IPv6, IP Address Management >> >
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