Hello, As policy shepherd for DP-2014-2, I am interested in comments about the problem statement, need and efficacy of language drafted. I have included current information below. A statement of support or opposition and brief reasoning would be most helpful, but also suggestions on improvement are also welcomed if you feel this draft moves our region in a positive direction, but currently misses the mark. Thanks!
*Problem Statement:* *Current NRPM Language*: "Source entities within the ARIN region must not have received a transfer, allocation, or assignment of IPv4 number resources from ARIN for the 12 months prior to the approval of a transfer request. This restriction does not include M&A transfers." This prevents anyone who receives BLOCK A in 2014 from transferring to another RIR a different block, BLOCK B, which was issued 5, 10, 15, 20 years ago. In my company, we needed to move a legacy block being used in Asia over to APNIC. But because we had gotten a new block in 2013, we were prevented from moving the old block to a different RIR. *Proposed Language Modification: (Draft Policy statement) Change undelined* Source entities within the ARIN region must not have received a transfer, allocation, or assignment of IPv4 number resources from ARIN for the 12 months prior to the approval of a transfer request. This restriction does not include M&A transfers. *Restrictions related to recent receipt of blocks shall not apply to inter-RIR transfers within the same organization and its subsidiaries.* One comment has suggested that the clause '*and its subsidiaries*' opens opportunity for abuse.......another comment attempting to mitigate this possibility suggested the clause be modified as....'and its subsidiaries *providing network services*' Thank you for sharing your insights and for being part of the ARIN open, bottom up, policy development process. Bill Darte ARIN Advisory Council
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