We have already brokered sales of 103 blocks in the past.
What about those who have received 103 blocks via transfer and not direct
allocation?
Are they exempted or grandfathered-in, or did they purchase something they
expected to be resellable, only to find that option has been removed from
them via policy change?

I suggest, since APNIC has the records of 103 blocks which have already been
transferred, that those blocks be explicitly treated as non-103 blocks,
allowing those blocks to be re-transferred.  I am sure the number is small
relative to the number of /22s in 103/8.

While I understand the nature of 103/8 is different from other blocks, in
general I am against waiting periods. They are designed to prevent
"flipping", but in fact they cause grief for those whose business plans or
environments change.  And they prevent normal market activities that I think
would be good for the IPv4 market.

For example, we have done almost 500 transfers, and we think we could be
more efficient at the job of say, breaking down and selling a /16 as small
blocks than most /16 holders would be. In exchange for this efficiency, we
would extract profit. But holding-periods and needs-tests, imposed by
registry stewards, preclude this efficiency from entering the market.  IPv4
addresses are bought and sold every day, but artificial market restrictions
warp the market to the detriment of  participants.  The purported reason for
these restrictions is to prevent speculation and hoarding, none of which has
appeared in the RIPE community, which is where it would be expected to
appear, since RIPE removed the needs-test from transfers years ago.

I think five years is too long, and no waiting period at all is preferable. 

Regards,
Mike Burns


-----Original Message-----
From: sig-policy-boun...@lists.apnic.net
[mailto:sig-policy-boun...@lists.apnic.net] On Behalf Of Brown Kevin
Sent: Friday, October 13, 2017 5:36 AM
To: sig-policy@lists.apnic.net
Subject: [sig-policy] sig-policy Digest, Vol 160, Issue 27--- apply in the
address allocated after the policy officially issued

There is a big problem what is the range of the transfer prohibition, all
the allocated 103/8 or new allocated after this policy officially issued.
I noticed that in the current policy, there is no special prohibit term for
103/8 transfer. and the ploicy is part of the contract between members and
NIRs or LIRs or APNIC.
If the modified policy applied in these old 103/8 address which was applied
befeore this new policy. Is it a kind of break contract?
I think this policy should only apply the address applied after the policy
officially issued.


Best Regards,
Kevin
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