[members-discuss] M&A procedure and transfers restrictions

Hi.

According to the sad document
https://www.ripe.net/publications/docs/ripe-709#transfer36

Internet number resources that are subject to transfer restrictions imposed
by the RIPE Policy "RIPE Resource Transfer Policies
<http://www.ripe.net/publications/docs/transfer-policies>", and that are
transferred due to a change in a member's business structure, must either
remain registered with the original LIR account or be registered with a new
LIR account. The receiving party will be provided with RIPE NCC services
for these Internet number resources via either the original LIR account or
the new LIR account until the policy restrictions are lifted.

We have the next situation:
1. There are 2 legal entities - A and B, their accounts were opened in
Summer 2018.
2. The legal entity B joined to the legal entity A.
3. The NCC transformed the account of the entity B to the additional
account of the entity A. While the NCC prepared the LIR Account Agreement
and sent it by DHL we finalized the procedure in January 2019 only.
4. But the NCC also called it as transfer because of MERGER_OR_ACQUISITION.
5. So we have the transfer restriction period until January 2021 and the
NCC can pay bonus (4200 EUR for 3 accounts) for it's executive board,
stuffs etc.

I thought, because of the account transformation the procedure cannot be
called as transfer of resources. Otherwise the NCC should merge accounts
without additional account creation if the transfer restrictions aren't
applied because of M&A.
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