Hello Arash,
Thank you for sharing your feedback on the proposal, I appreciate your feedback
and suggestions. To address your suggestions:
On the topic of a phased rollout, to my knowledge the Secretariat currently
operate (and I believe if prop-168 is adopted would continue to operate) on a
First-In-First-Out basis, that is, applications would be processed in the order
in which they are received. If there is a concern that this could affect
response times which in turn would affect SLAs for application processing, the
Secretariat may review and adjust their SLAs, or if approved by senior
management exempt subsequent resource requests from SLA metrics. This, to my
knowledge, would sit outside the scope of INR policy.
As for genuine M&As, the change to 14.0 was primarily for consistent wording
throughout the policy document. The intent of this change (as is also the case
based on my understanding) is that if an account holder receives a subsequent
delegation, and is then merged into or acquired by another account holder and
the request is indeed legitimate, all resources transferred in from the losing
account holder would not be transferrable for 5 years from the date of the most
recent delegation to the losing account holder.
To give you an example of how prop-168 would tie in with M&As (to use RFC1918
space in this example as there are no documentation prefixes larger than a /24):
ACME Internet receives the allocation 192.168.0.0/23 from APNIC on 01 July 2024.
Prop-168 reaches consensus during the Policy SIG meeting and AMM, is
implemented, and becomes policy.
On 13 March 2027, ACME Internet receives a second /23 (that they applied for a
few weeks earlier) as permitted under policy, meaning that the earliest they
can transfer any of their resources out of their account is 13 March 2032, when
the 5-year transfer lock expires as the clock on 192.168.0.0/23 was reset when
they received their subsequent delegation.
On 27 August 2029, Bigger Broadband acquires 100% ownership of ACME Internet,
and makes the decision to transfer all resources from ACME Internet's account
across to theirs. The resources that came across from ACME to Bigger would
still be subject to the original transfer lock expiration date of 13 March 2032
as these resources are transferred, not delegated.
The Secretariat is permitted to request sufficient evidence to demonstrate that
the merger or acquisition is legitimate for the purpose of transfers under
existing M&A policy. This would help to prevent "sham acquisitions" whereby
falsified or fraudulent documents are provided in an attempt to circumvent the
5-year transfer lock for market transfers.
Regards,Christopher Hawker
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