Hi Marla, I'm the policy author. I wrote the policy in reaction to Richard Jimmerson's staff experience report published at: https://www.arin.net/participate/meetings/reports/ARIN_35/PDF/monday/jimmerson_policy.pdf On pages 7 and 8, Richard asked for specific changes, including: - fixing the title to include reorganizations - fixing the language:
" the recipient entity must provide evidence that they have acquired assets that use the resources to be transferred from the current registrant. ARIN will maintain an up-to-date list of acceptable types of documentation." ... to make it clear it does NOT apply to reorganizations. So I fixed the title of 8.2 (I added the word re-organizations) and I CHANGED the order of the bullet points to read more clearly to the lay reader. No text was changed except the last bullet point where I prefaced the text with "For mergers and acquisition transfer". 2015-4 is a very minor change, was requested by staff, and makes 8.2 more readable for the lay reader. The AC considered this as an editorial change, but for reasons I don’t remember, we decided to put it through PDP. It was a close call, I think. Hope that helps :) David David R Huberman Principal, Global IP Addressing Microsoft Corporation > -----Original Message----- > From: [email protected] [mailto:[email protected]] On > Behalf Of Andrew Dul > Sent: Tuesday, October 6, 2015 6:56 AM > To: Azinger, Marla <[email protected]> > Cc: [email protected] > Subject: Re: [arin-ppml] Recommended Draft Policy ARIN-2015-4: Modify 8.2 > section to better reflect how ARIN handles reorganizations > > The intent here is to clarify that a reorganization is not required to go > through > the larger process of showing that assets were acquired and the other needs > testing that is currently done on mergers & acquisitions. > > Andrew > > > On Oct 5, 2015, at 3:26 PM, Azinger, Marla <[email protected]> > wrote: > > > > It looks like all that was changed was they added the word “re- > organization”. Am I missing some other text change? > > > > Regards > > Marla Azinger > > > > -----Original Message----- > > From: [email protected] [mailto:[email protected]] > > On Behalf Of ARIN > > Sent: Tuesday, July 21, 2015 10:33 AM > > To: [email protected] > > Subject: [arin-ppml] Recommended Draft Policy ARIN-2015-4: Modify 8.2 > > section to better reflect how ARIN handles reorganizations > > > > Recommended Draft Policy ARIN-2015-4 > > Modify 8.2 section to better reflect how ARIN handles reorganizations > > > > On 16 July 2015 the ARIN Advisory Council (AC) recommended > > ARIN-2015-4 for adoption, making it a Recommended Draft Policy. > > > > ARIN-2015-4 is below and can be found at: > > > https://na01.safelinks.protection.outlook.com/?url=https%3a%2f%2fwww.a > > > rin.net%2fpolicy%2fproposals%2f2015_4.html&data=01%7c01%7cdavid.hube > rm > > > an%40microsoft.com%7c4ff87465e393490ca8b208d2ce55ea5a%7c72f988bf86 > f141 > > > af91ab2d7cd011db47%7c1&sdata=S%2bCm4qFN%2fqWIWPqajQOBcYhnEtdr > zDaAl5MzW > > G4jd2s%3d > > > > You are encouraged to discuss Draft Policy 2015-4 on the PPML prior to the > ARIN Public Policy Consultation at ARIN 36 in Montreal in October 2015. Both > the discussion on the list and at the meeting will be used by the ARIN > Advisory Council to determine the community consensus for adopting this as > policy. > > > > The ARIN Policy Development Process can be found at: > > > https://na01.safelinks.protection.outlook.com/?url=https%3a%2f%2fwww.a > > > rin.net%2fpolicy%2fpdp.html&data=01%7c01%7cdavid.huberman%40micros > oft. > > > com%7c4ff87465e393490ca8b208d2ce55ea5a%7c72f988bf86f141af91ab2d7cd > 011d > > b47%7c1&sdata=zsfZBQTnd7KE8YVEOz6Lote4HhEJjd4VsBKNKj3o5pQ%3d > > > > Draft Policies and Proposals under discussion can be found at: > > > https://na01.safelinks.protection.outlook.com/?url=https%3a%2f%2fwww.a > > > rin.net%2fpolicy%2fproposals%2findex.html&data=01%7c01%7cdavid.huber > ma > > > n%40microsoft.com%7c4ff87465e393490ca8b208d2ce55ea5a%7c72f988bf86f > 141a > > > f91ab2d7cd011db47%7c1&sdata=PPDRFP%2bdKCH1b4WrdOzy4%2b2pERfXM > Mpy7U6Yi6 > > IRx4g%3d > > > > Regards, > > > > Communications and Member Services > > American Registry for Internet Numbers (ARIN) > > > > > > ## * ## > > > > > > Recommended Draft Policy ARIN-2015-4 > > Modify 8.2 section to better reflect how ARIN handles reorganizations > > > > Date: 21 July 2015 > > > > AC's assessment of conformance with the Principles of Internet Number > Resource Policy: > > > > 2015-4 is largely editorial in nature and does not change policy > implementation, but clarifies existing use of policy. The proposal is fair in > that > it provides a consistent interface for transfers and clarifies the transfer > policy. > It is technically sound in that it is already effectively implemented. The > proposal has received support on the mailing list and we expect it to be > generally supported by the community as it is the direct result of community > feed back on the existing policy. > > > > Problem Statement: > > > > ARIN staff indicated that NRPM 8.2 does not clearly indicate how ARIN > procedures handle reorganizations. ARIN staff indicated that the first policy > bullet point does not apply to reorganizations. > > > > Policy statement: > > > > Replacement text for entire 8.2 section: > > > > 8.2. Mergers, Acquisitions, and Reorganizations > > > > ARIN will consider requests for the transfer of number resources in > > the case of mergers, acquisitions, and reorganizations under the > > following > > conditions: > > > > -The current registrant must not be involved in any dispute as to the status > of the resources to be transferred. > > > > -The new entity must sign an RSA covering all resources to be transferred. > > > > -The resources to be transferred will be subject to ARIN policies. > > > > -The minimum transfer size is the smaller of the original allocation size or > the applicable minimum allocation size in current policy. > > > > -For mergers and acquisition transfers, the recipient entity must provide > evidence that they have acquired assets that use the resources to be > transferred from the current registrant. ARIN will maintain an up-to-date list > of acceptable types of documentation. > > > > In the event that number resources of the combined organizations are no > longer justified under ARIN policy at the time ARIN becomes aware of the > transaction, through a transfer request or otherwise, ARIN will work with the > resource holder(s) to return or transfer resources as needed to restore > compliance via the processes outlined in current ARIN policy. > > > > Comments: > > > > The problem statement is addressed by: > > > > -re-title 8.2 > > > > -clarify the documentation bullet point > > > > -rearrange the documentation bullet to the end of the list since it only > applies to some requestors, while the other bullet points apply to all > requestors. > > > > a.Timetable for implementation: Immediate > > > > b.Anything else > > > > ##### > > > > ARIN STAFF & LEGAL ASSESSMENT > > Draft Policy ARIN-2015-4 > > Modify 8.2 section to better reflect how ARIN handles reorganizations > > > https://na01.safelinks.protection.outlook.com/?url=https%3a%2f%2fwww.a > > > rin.net%2fpolicy%2fproposals%2f2015_4.html&data=01%7c01%7cdavid.hube > rm > > > an%40microsoft.com%7c4ff87465e393490ca8b208d2ce55ea5a%7c72f988bf86 > f141 > > > af91ab2d7cd011db47%7c1&sdata=S%2bCm4qFN%2fqWIWPqajQOBcYhnEtdr > zDaAl5MzW > > G4jd2s%3d > > > > Date of Assessment: July 14, 2015 > > > > ___ > > 1. Summary (Staff Understanding) > > This proposal would provide clarification to the 8.2 transfer policy for > reorganizations. It does this by adding "reorganizations" to the title, and > clarifies that evidence of acquired assets is only required for merger and > acquisition transfers; not reorganizations. > > > > ___ > > 2. Comments > > A. ARIN Staff Comments > > This proposal can be implemented as written. Minimal staff training and > preparation would be needed to implement this if it were to become policy. > The proposal clarifies a point about reorganizations that has been confusing > to customers in the past. We see no negative impacts. > > > > B. ARIN General Counsel – Legal Assessment Counsel sees no material legal > issues in this policy. > > > > ___ > > 3. Resource Impact > > This policy would require minimal staff training and preparation. We see no > negative impacts. > > > > ___ > > 4. Proposal / Draft Policy Text Assessed > > > > Draft Policy ARIN-2015-4 > > > > Modify 8.2 section to better reflect how ARIN handles reorganizations > > > > Problem Statement: > > > > ARIN staff indicated that NRPM 8.2 does not clearly indicate how ARIN > procedures handle reorganizations. ARIN staff indicated that the first policy > bullet point does not apply to reorganizations. > > > > Policy statement: > > > > Replacement text for entire 8.2 section: > > > > 8.2. Mergers, Acquisitions, and Reorganizations > > > > ARIN will consider requests for the transfer of number resources in > > the case of mergers, acquisitions, and reorganizations under the > > following > > conditions: > > > > -The current registrant must not be involved in any dispute as to the status > of the resources to be transferred. > > -The new entity must sign an RSA covering all resources to be transferred. > > -The resources to be transferred will be subject to ARIN policies. > > -The minimum transfer size is the smaller of the original allocation size or > the applicable minimum allocation size in current policy. > > -For mergers and acquisition transfers, the recipient entity must provide > evidence that they have acquired assets that use the resources to be > transferred from the current registrant. ARIN will maintain an up-to-date list > of acceptable types of documentation. > > > > In the event that number resources of the combined organizations are no > longer justified under ARIN policy at the time ARIN becomes aware of the > transaction, through a transfer request or otherwise, ARIN will work with the > resource holder(s) to return or transfer resources as needed to restore > compliance via the processes outlined in current ARIN policy. > > > > Comments: > > > > The problem statement is addressed by: > > > > -re-title 8.2 > > -clarify the documentation bullet point -rearrange the documentation > > bullet to the end of the list since it only applies to some requestors, > > while > the other bullet points apply to all requestors. > > > > a.Timetable for implementation: Immediate > > > > b.Anything else > > _______________________________________________ > > 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://na01.safelinks.protection.outlook.com/?url=http%3a%2f%2flists. > > arin.net%2fmailman%2flistinfo%2farin- > ppml&data=01%7c01%7cdavid.huberma > > > n%40microsoft.com%7c4ff87465e393490ca8b208d2ce55ea5a%7c72f988bf86f > 141a > > > f91ab2d7cd011db47%7c1&sdata=VliIkQb0pzX46tbwUjcvQS3KOkTqroWer9ES > o6SGDy > > M%3d Please contact [email protected] if you experience any issues. > > > > ________________________________ > > > > This communication is confidential. Frontier only sends and receives > > email on the basis of the terms set out at > > > https://na01.safelinks.protection.outlook.com/?url=http%3a%2f%2fwww.fr > > > ontier.com%2femail_disclaimer.&data=01%7c01%7cdavid.huberman%40micr > oso > > > ft.com%7c4ff87465e393490ca8b208d2ce55ea5a%7c72f988bf86f141af91ab2d7 > cd0 > > > 11db47%7c1&sdata=R6TYATTBmacXyZdxStkd9o3D7di3LIp0YXBu3Xd9OyE%3d > > _______________________________________________ > > 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://na01.safelinks.protection.outlook.com/?url=http%3a%2f%2flists. > > arin.net%2fmailman%2flistinfo%2farin- > ppml&data=01%7c01%7cdavid.huberma > > > n%40microsoft.com%7c4ff87465e393490ca8b208d2ce55ea5a%7c72f988bf86f > 141a > > > f91ab2d7cd011db47%7c1&sdata=VliIkQb0pzX46tbwUjcvQS3KOkTqroWer9ES > o6SGDy > > M%3d Please contact [email protected] if you experience any issues. > _______________________________________________ > 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://na01.safelinks.protection.outlook.com/?url=http%3a%2f%2flists.arin > .net%2fmailman%2flistinfo%2farin- > ppml&data=01%7c01%7cdavid.huberman%40microsoft.com%7c4ff87465e39 > 3490ca8b208d2ce55ea5a%7c72f988bf86f141af91ab2d7cd011db47%7c1&sdata > =VliIkQb0pzX46tbwUjcvQS3KOkTqroWer9ESo6SGDyM%3d > Please contact [email protected] if you experience any issues. _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]). 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