Dear Members, I support the views of Chku. In case of M&A cases policy should be simple enough and APNIC need to act as a facilitator.
Regards, Rajesh Panwala For Smartlink Solutions Pvt Ltd On Tue, Feb 2, 2021, 9:55 AM chku <c...@twnic.tw> wrote: > Dear SIG members, > > A new version of the proposal "prop-130: Modification of transfer policies" > has been sent to the Policy SIG for review. > > It will be presented during the Open Policy Meeting at APRICOT2021/APNIC 51 > online-only conference on Wednesday, 03 February 2021. > > We invite you to review and comment on the proposal on the mailing list > before the meeting. > > The comment period on the mailing list before an APNIC conference is an > important part of the policy development process. We encourage you to > express your views on the proposal: > > - Do you support or oppose this proposal? > - Does this proposal solve a problem you are experiencing? If so, > tell the community about your situation. > - Do you see any disadvantages in this proposal? > - Is there anything in the proposal that is not clear? > - What changes could be made to this proposal to make it more > effective? > > Information about this proposal is available at: > http://www.apnic.net/policy/proposals/prop-130 > > Regards, > Bertrand and Ching-Heng > APNIC Policy SIG Chairs > > > ------------------------------------------------------- > > prop-130-v003: Modification of transfer policies > > ------------------------------------------------------- > > Proposer: Jordi Palet Martnez > jordi.pa...@theipv6company.com > > > 1. Problem statement > -------------------- > > Existing transfer policies for IPv4, IPv6 and ASN resources have some > differences among what is allowed and what not, if in the case of > intra-RIR and inter-RIR, and it is not clear if in case of merger and > acquisitions it is referring to a complete company, part of it, or even > if in case of a company reorganization or relocation, the policy is > supportive to that case. > > In some regions, this may not be a policy, but an administrative > procedure, but this may change in the future by means of a policy proposal. > > In the caser of inter-RIR, the counterpart RIR need to have a reciprocal > policy or procedure that allows it. > > Finally, there should not be differences from the APNIC perspective, on > the considerations of an M&A for different type of resources, because > there is no reason for allowing, for example, IPv4 resources to be > transferred, and instead IPv6 ones not. For example, an organization may > be hosting services in a Data Center, by means of Virtual Machines and > moving to a different DC in another region. It is ridiculous to allow to > keep the IPv4 addresses (so not renumber the VMs) and instead ask to > renumber IPv6. It is a big and unnecessary disruptive complexity. > > > 2. Objective of policy change > ------------------------------ > To ensure that the policy text is clarified, if those cases are > supported by the community. > > It will also facilitate companies or business units, moving or being > established in other regions. > > It will minimize legal issues in case an acquisition claiming their > rights over the acquired company and their existing assets (resources). > > > 3. Situation in other regions > ------------------------------ > There is a variety of support of all those cases in different regions. > The one more open is RIPE, followed by ARIN and LACNIC. A similar policy > proposal is being discussed in AFRINIC. > > > 4. Proposed policy solution > ---------------------------- > Actual Text > 8.4. Mergers & acquisitions > APNIC will process and record the transfer of IPv4 resources as the > result of merger or acquisition. > > 11.0. Transfer of IPv6 resources > APNIC will only recognize the transfer or IPv6 addresses as the result > of Merger & Acquisition activity. The following conditions and > consequences apply. > > 13.3. Mergers & acquisitions > APNIC will recognize the transfer of ASNs as the result of merger or > acquisition. > > > Proposed Text > 8.4. Mergers, acquisitions and relocations > APNIC will recognize the transfer of IPv4 resources resulting from a > partial or complete merger, acquisition, reorganization or relocation. > > In the case of inter-RIR, the counterpart RIR need to have a reciprocal > policy/procedure that allows it. > > > 11.0. Transfer of IPv6 resources > APNIC will recognize the transfer or IPv6 resources resulting from a > partial or complete merger, acquisition, reorganization or relocation. > > In the case of inter-RIR, the counterpart RIR need to have a reciprocal > policy/procedure that allows it. > > > 13.3. Mergers, acquisitions and relocations > APNIC will recognize the transfer of ASNs resulting from a partial or > complete merger, acquisition, reorganization or relocation. > > In the case of inter-RIR, the counterpart RIR need to have a reciprocal > policy/procedure that allows it. > > > 5. Advantages / Disadvantages > ----------------------------- > Advantages: > Fulfilling the objectives above indicated and ensuring clarity on what > is allowed and what not. > > The proposal makes clear that this may only happen, in case of Inter-RIR > cases, when both RIRs have a reciprocal policy. > > Minimizing possible legal issues. > > > Disadvantages: > It could be considered that it can create further disaggregation, > especially in IPv6, however, those cases are rare and only happening > from time to time, so the impact is negligible, and justified by the > documentation provided when the transfer is requested. > > In the Inter-RIR cases, coordination with the counter-part RIR is > needed, but this is already an ongoing activity because all the regions > (with the exception of AFRINIC), already have those mechanisms in place > (for both, administrative and technical aspects). > > > 6. Impact on resource holders > ------------------------------ > None. > > > 7. References > -------------- > RIPE NCC: > https://www.ripe.net/publications/docs/ripe-682 > > ARIN: > https://www.arin.net/policy/nrpm.html#eight2 > > LACNIC: > https://politicas.lacnic.net/politicas/detail/id/LAC-2019-4/language/en > https://politicas.lacnic.net/politicas/detail/id/LAC-2019-3/language/en > https://politicas.lacnic.net/politicas/detail/id/LAC-2019-2/language/en > _______________________________________________ > * sig-policy: APNIC SIG on resource management policy > * > _______________________________________________ > sig-policy mailing list > sig-policy@lists.apnic.net > https://mailman.apnic.net/mailman/listinfo/sig-policy >
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