Preston - I don’t think any of the present discussion has been predicated on fraud concerns.
(Note that ARIN currently has some extensive anti-fraud practices that include various forms of government issued ID presentation and verification.) Thanks, /John John Curran President and CEO American Registry for Internet Numbers On Apr 17, 2025, at 7:39 PM, Preston Ursini <[email protected]> wrote: Would I be correct in that there hasn’t been an actually policy proposal submitted for this? I believe that whether or not this new policy were to be considered, that a copy of a government issued identification document be submitted to the person signing the Registration Services Agreement whenever an OrgID is issued. This can help immensely in tracking down fraud which seems to be a pillar concern. For simplicity sake, I’d also say in any such policy allowing an Individual to obtain numbering assets simply be issued an OrgID just as sole proprietors are as to minimize disruption to ARIN operations in implementing this policy. Preston Ursini On Apr 17, 2025, at 6:28 PM, John Curran <[email protected]> wrote: Preston - That’s a reasonable question (“why an individual cannot be accepted as they are generally the same legal entity…”) You’re right that a sole proprietorship is legally tied to the individual behind it, but that doesn’t make it the same as issuing resources to individuals. At the time of ARIN’s formation (and for a suibstantial period before), number resources were issued to organizations. The old netnumber.txt request forms made that clear, asking for “the organization responsible for establishing the network” along with a postal address. That model is what ARIN inherited when it was formed in 1997, and it’s what we continue to operate under. While it’s true in theory that ARIN could adopt a model where it directly serves individuals, this would represent a significant departure from the registry model we inherited and have operated under for decades. Even though individuals and organizations can both be “legal entities,” that does not mean they are treated identically under law. For example, companies that predominantly focus on serving businesses (often referred to as B2B) are often subject to different laws, regulations, and tax policy than those that hold themselves out to serve individuals. Thus, shifting to a model that openly includes individuals could have significant unintended implications for ARIN. That doesn’t mean it can’t be done, but it would be important to understand the problem that such a change would solve. ARIN accepts incorporated entities, DBAs, sole proprietors, etc.—because we know networks are run by all kinds of operators. But in every case, we’re still issuing to an organization, however minimal the structure might be. Thanks! /John John Curran President and CEO American Registry for Internet Numbers On Apr 17, 2025, at 2:09 PM, Preston Ursini via ARIN-PPML <[email protected]> wrote: If a sole proprietorship is accepted, I am confused as to why an Individual cannot be accepted as they are generally the same legal entity unless it is an individual? There are over 20,000 political subdivisions within the United States when you count cities, counties, townships, etc., all with their own rules when it comes to business licenses and conducting business, trying to tie every sole proprietorship down with a business license when one may not be required in many of these jurisdictions seems strange at best. In general the law sees Corporations and Individuals as all in the same, so I’m a little confused as to why ARIN would be ok with doing business with a sole proprietor but not an "individual"? If the issue is fraud prevention, it seems like a better approach would be tying all accounts regardless of whether it is a business/individual, with a government issued identification document; the trend with having an officer of a company sign an RSA seems to be a step in the direction in tying real people to accounts; assuming the goal here is to ensure accountability for resource allocation? Preston Ursini On Apr 17, 2025, at 7:21 AM, [email protected] wrote: Send ARIN-PPML mailing list submissions to [email protected] To subscribe or unsubscribe via the World Wide Web, visit https://lists.arin.net/mailman/listinfo/arin-ppml or, via email, send a message with subject or body 'help' to [email protected] You can reach the person managing the list at [email protected] When replying, please edit your Subject line so it is more specific than "Re: Contents of ARIN-PPML digest..." Today's Topics: 1. Re: distributing resources for individuals ([email protected]) 2. Re: distributing resources for individuals (John Curran) ---------------------------------------------------------------------- Message: 1 Date: Thu, 17 Apr 2025 09:00:26 +0200 From: "[email protected]" <[email protected]> To: arin-ppml <[email protected]> Subject: Re: [arin-ppml] distributing resources for individuals Message-ID: <[email protected]> Content-Type: text/plain; charset="utf-8" Hi John, A couple of questions on this: 1) There is a formal confirmation that this ?simple and ?inexpensive? procedure is the same in all the ?areas? (states, whatever is te division in each country) for all the service region countries of ARIN? 2) Are we sure that in all those areas/countries the cost of keeping that ?status? (the one that is valid for ARIN), and I mean not only money, but also recurrent paperwork (like for example if you need to present quarterly/yearly tax reports, even if you don?t had economical activity), is close to ?zero"? 3) As 1 and 2 above may change (a country law may decide that a sole-proprietorship may be enforced to something else much more expensive or cease that status), do it make sense that the policy and/or membership documents ask for something that doesn?t depend on ARIN decisions, instead of relaying in making sure that you provide ?real documents? and of course a valid justification for the resources that you request (which is already set in the policies for each type of resource)? Regards, Jordi @jordipalet El 17 abr 2025, a las 2:34, John Curran <[email protected]> escribi?: Ryan - Indeed. As both myself (and Bill Herrin) have pointed out a few times in this discussion, ARIN already has flexibility in this regard and we do have sole proprietorships that enter into agreements and obtain number resources. Sole proprietorship works, DBA name registration works, incorporation of a legal entity works ? hence the reason for further discussion in order to gain a better understanding of the problem to be solved. Thanks, /John John Curran President and CEO American Registry for Internet Numbers On Apr 16, 2025, at 8:16?PM, Ryan Hamel <[email protected]> wrote: John, I echo David's point coming from California. My ARIN resources are under my legal name, which was approved by the team that handles org tickets, and the legal team. A sole proprietor without a DBA, can legally conduct business in several states and potentially provinces too, and that also includes signing ARIN's agreements. Kind regards, Ryan Hamel From: ARIN-PPML <[email protected]> on behalf of David Farmer via ARIN-PPML <[email protected]> Sent: Wednesday, April 16, 2025 4:58:48 PM To: John Curran <[email protected]> Cc: arin-ppml <[email protected]> Subject: Re: [arin-ppml] distributing resources for individuals Caution: This is an external email and may be malicious. Please take care when clicking links or opening attachments. John, The issue is in Missouri, Minnesota, and probably many other states; if you are doing business under your own name and not a DBA, you don't need to register with the state to operate a sole proprietorship. So, if ARIN procedures require a lookup with the Secretary of State, effectively, that requires more than just operating as a business; it also requires operating that business under a fictitious name, not under the owner's name. Section 9 of the NRPM gives a lot of latitude for demonstrating that an organization operates within the ARIN region. A similar amount of latitude should be available to establish that an individual is acting as a business and not an individual, even if the jurisdiction's laws and procedures don't neatly align with ARIN procedures. Thanks On Wed, Apr 16, 2025 at 6:04?PM John Curran <[email protected] <mailto:[email protected]>> wrote: On Apr 16, 2025, at 6:02?PM, Paul E McNary <[email protected] <mailto:[email protected]>> wrote: Originally 12 years ago when I tried to get ARIN resources, I was greatly harmed by this. In Missouri at that time a Sole Proprietor did not have to register with the Secretary of State. ARIN would not issue resources unless they could verify you with Secretary of State database. We had a State Sales Tax and Employment Tax ID for 20 years, but that wasn't good enough. Paul - To be certain there?s a clear understanding of the problem that resulted from the organization requirement ? are you saying that you were unable to register a DBA name with Missouri Secretary of State in 2013? There is a 7$ fee associated with such registration (every 5 years) but from all appearances it is otherwise a rather nominal process, so if there is/was some other barrier it would be good to explain it so that folks understand the scope of the problem that you experienced when trying to do so. Thanks, /John John Curran President and CEO American Registry for Internet Numbers _______________________________________________ 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. ********************************************** IPv4 is over Are you ready for the new Internet ? http://www.theipv6company.com The IPv6 Company This electronic message contains information which may be privileged or confidential. The information is intended to be for the exclusive use of the individual(s) named above and further non-explicilty authorized disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited and will be considered a criminal offense. If you are not the intended recipient be aware that any disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited, will be considered a criminal offense, so you must reply to the original sender to inform about this communication and delete it. -------------- next part -------------- An HTML attachment was scrubbed... URL: <https://lists.arin.net/pipermail/arin-ppml/attachments/20250417/59eecf73/attachment-0001.htm> ------------------------------ Message: 2 Date: Thu, 17 Apr 2025 12:21:30 +0000 From: John Curran <[email protected]> To: "[email protected]" <[email protected]> Cc: arin-ppml <[email protected]> Subject: Re: [arin-ppml] distributing resources for individuals Message-ID: <[email protected]> Content-Type: text/plain; charset="utf-8" Jordi - The representation you seek from ARIN regarding government procedures across the the entire region is not possible to make ? and as you note, it would be meaningless the very next day because such laws and regulations are outside of ARIN?s control and subject to change. Note that this is the case regardless of whether speaking of networks run by organizations or individuals ? the legal requirements on networks in any given portion of the ARIN region are not determined by ARIN. What we can say is that our customers want us to be reasonably flexible in our processes to the extent possible, just as we are with respect to confirming whether organizations requesting resources operate within the ARIN region. We?ve evolved our processes over time to make be more straightforward, and this includes handling entities that are incorporated, those using DBA registrations, sole proprietorships, etc. Your original query noted that ? In LACNIC we are having a discussion because the policy manual only allows to distribute resources to ?organizations legally registered? ? ? To be clear, ARIN is effectively the same, but we are quite flexible in recognition of how our network customers may go about their legal registration. Thanks! /John John Curran President and CEO American Registry for Internet Numbers On Apr 17, 2025, at 3:00?AM, jordi.palet--- via ARIN-PPML <[email protected]> wrote: Hi John, A couple of questions on this: 1) There is a formal confirmation that this ?simple and ?inexpensive? procedure is the same in all the ?areas? (states, whatever is te division in each country) for all the service region countries of ARIN? 2) Are we sure that in all those areas/countries the cost of keeping that ?status? (the one that is valid for ARIN), and I mean not only money, but also recurrent paperwork (like for example if you need to present quarterly/yearly tax reports, even if you don?t had economical activity), is close to ?zero"? 3) As 1 and 2 above may change (a country law may decide that a sole-proprietorship may be enforced to something else much more expensive or cease that status), do it make sense that the policy and/or membership documents ask for something that doesn?t depend on ARIN decisions, instead of relaying in making sure that you provide ?real documents? and of course a valid justification for the resources that you request (which is already set in the policies for each type of resource)? Regards, Jordi @jordipalet El 17 abr 2025, a las 2:34, John Curran <[email protected]> escribi?: Ryan - Indeed. As both myself (and Bill Herrin) have pointed out a few times in this discussion, ARIN already has flexibility in this regard and we do have sole proprietorships that enter into agreements and obtain number resources. Sole proprietorship works, DBA name registration works, incorporation of a legal entity works ? hence the reason for further discussion in order to gain a better understanding of the problem to be solved. Thanks, /John John Curran President and CEO American Registry for Internet Numbers On Apr 16, 2025, at 8:16?PM, Ryan Hamel <[email protected]> wrote: John, I echo David's point coming from California. My ARIN resources are under my legal name, which was approved by the team that handles org tickets, and the legal team. A sole proprietor without a DBA, can legally conduct business in several states and potentially provinces too, and that also includes signing ARIN's agreements. Kind regards, Ryan Hamel ________________________________ From: ARIN-PPML <[email protected]> on behalf of David Farmer via ARIN-PPML <[email protected]> Sent: Wednesday, April 16, 2025 4:58:48 PM To: John Curran <[email protected]> Cc: arin-ppml <[email protected]> Subject: Re: [arin-ppml] distributing resources for individuals Caution: This is an external email and may be malicious. Please take care when clicking links or opening attachments. John, The issue is in Missouri, Minnesota, and probably many other states; if you are doing business under your own name and not a DBA, you don't need to register with the state to operate a sole proprietorship. So, if ARIN procedures require a lookup with the Secretary of State, effectively, that requires more than just operating as a business; it also requires operating that business under a fictitious name, not under the owner's name. Section 9 of the NRPM gives a lot of latitude for demonstrating that an organization operates within the ARIN region. A similar amount of latitude should be available to establish that an individual is acting as a business and not an individual, even if the jurisdiction's laws and procedures don't neatly align with ARIN procedures. Thanks On Wed, Apr 16, 2025 at 6:04?PM John Curran <[email protected]<mailto:[email protected]>> wrote: On Apr 16, 2025, at 6:02?PM, Paul E McNary <[email protected]<mailto:[email protected]>> wrote: Originally 12 years ago when I tried to get ARIN resources, I was greatly harmed by this. In Missouri at that time a Sole Proprietor did not have to register with the Secretary of State. ARIN would not issue resources unless they could verify you with Secretary of State database. We had a State Sales Tax and Employment Tax ID for 20 years, but that wasn't good enough. Paul - To be certain there?s a clear understanding of the problem that resulted from the organization requirement ? are you saying that you were unable to register a DBA name with Missouri Secretary of State in 2013? There is a 7$ fee associated with such registration (every 5 years) but from all appearances it is otherwise a rather nominal process, so if there is/was some other barrier it would be good to explain it so that folks understand the scope of the problem that you experienced when trying to do so. Thanks, /John John Curran President and CEO American Registry for Internet Numbers _______________________________________________ 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. ********************************************** IPv4 is over Are you ready for the new Internet ? http://www.theipv6company.com The IPv6 Company This electronic message contains information which may be privileged or confidential. The information is intended to be for the exclusive use of the individual(s) named above and further non-explicilty authorized disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited and will be considered a criminal offense. If you are not the intended recipient be aware that any disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited, will be considered a criminal offense, so you must reply to the original sender to inform about this communication and delete it. _______________________________________________ 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. -------------- next part -------------- An HTML attachment was scrubbed... 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_______________________________________________ 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.
