[address-policy-wg] 2015-01 Draft Document and Impact Analysis Published (Alignment of Transfer Requirements for IPv4 Allocations)

Hi David,

Thanks for your question - it's good to be able to provide clarity.

The proposal would apply to allocations that were made in the past. When 
the RIPE NCC received a transfer request, we would check to see that at 
least 24 months had elapsed since the allocation was made. For example, 
a /22 allocation that was made 23 months before the proposal was 
accepted would have a waiting period of one month before it could be 
transferred.

Regarding your other question, the proposal being discussed doesn't 
apply to mergers or acquisitions. The Executive Board resolution 
mentioned in the impact analysis is separate to the proposal and *does* 
affect transfers, mergers, acquisitions and closures, and simply 
requires that the full 12 month membership fee must be paid before a new 
LIR can do any of these things.

So, in your example, Company B would be able to merge with Company A 
immediately. However, if it was only two months old, it would need to 
pay a full 12 month membership fee before this could be processed. As 
Company A and B are merging, this is not considered a transfer, so the 
24 month restriction would not apply.

Kind regards,
Marco Schmidt
Policy Development Officer
RIPE NCC

On 11/05/15 17:15, David Freedman wrote:
> Hi Marco, All,
>
> I'd just like Clarity on what could be some conflicting points in the
> impact analysis section of this document:
>
> It starts out with:
>
> "A. RIPE NCC's Understanding of the Proposed Policy -> The proposed policy
> would not affect existing procedures for mergers and acquisitions. The
> transfers of resources related to ownership changes of networks would
> remain possible at any time. The process of becoming a RIPE NCC member
> would not be impacted.:
>
> It then continues to say:
>
> "C. Impact of Policy on RIPE NCC Operations/Services -> Billing/Finance
> Department -> A RIPE NCC Executive Board resolution on 20 March 2015
> requires that LIRs pay one full annual service fee before commencement of
> a merger, transfer or closure procedure. The proposed policy change would
> require LIRs to keep their IPv4 allocation for at least 24 months before
> it could be transferred and pay the annual fee during this time"
>
> So, in the case of a merger related to ownership (I.e Company A acquires
> Company B) and Company B has one of these /22 allocations, then Company A
> has to wait for 24 months (and pay for two membership cycles) before being
> allowed to merge this in to their LIR? or did I misunderstand?
>
> Also, since I see no mention of this being retrospective in the proposal,
> I take it, that it will only apply to /22 allocations made from the date
> this proposal is accepted? and not before?
>
> Dave.
>
>
>