[members-discuss] About transfer policies

Hi,

it's funny how the outcome of a transfer request depends so much on 
which IPRA is handling that request.

We've had numerous tickets with the RIPE NCC and I can confirm that the 
outcome of a request/ticket depends a lot on which IPRA is responding, 
whether the weather was nice that morning or whether the IPRA had a good 
breakfast :)

I've been complaining to the RIPE NCC RS management team for more than a 
decade about inconsistencies in the department (even when I was working 
there as an IPRA, up to 8 years ago) and I am not sure that anything can 
be done.. Some people will follow the procedure to the letter and 
further, some will be more lenient.

The SLA was very important about 10 years when I was working there - 
every message was supposed to receive a reply within 24 hours. Now that 
doesn't seem to matter any more, I don't even know if the NCC still has 
an SLA.

Every time I did not like an answer or the delay of a ticket without an 
actual reason, I've replied to the IPRA and CCed the manager of the 
department. Most of the times, my request has received an answer from a 
manager or a swift resolution from the IPRA.

I used to get the contact details of the managers from the RIPE website, 
but it seems that one is not maintained at all any longer (I've seen 
managers there that have not been working for the NCC for 6-12 or even 
more months). I contacted Fergal about this issue and i hope they are 
working on updating their staff pages (too bad that most managers e-mail 
addresses are no longer public so you can not actually CC them in a 
ticket any longer).

To also address your peculiar issue, it would be very simple to ask a 
lawyer or someone that handles registration of Ukrainian companies what 
that line means and forward the answer to the RIPE NCC. Or wait for the 
RIPE NCC to get that answer directly... however, it is strange that with 
a few Ukrainian employees in house (and hundreds if not thousands of 
Ukrainian registration documents processed over the years) the RIPE NCC 
has decided to contact the Ukrainian Ministry of Justice to request 
clarification in this case.

my 2 cents,

elvis

On 3/2/20 18:11, Dmitry P wrote:
> Hello,
>
> we are in some weird situation with transfering out an IP range and RIPE
> doesn't provide any answers to our questions, the transfer is suspended
> for a very weird reason and we are out of options; I would like to hear
> other members opinions on that subject with a hope of seeking some
> answers that RIPE didn't provide after numerous attempts.
>
> Our company's extracts are created by Ukraine's Ministry of Justice and
> have a specific line near the director field which says '(не має)' right
> after mentioning the director's name, which means "(doesn't have)" from
> Ukrainian.
> ПОЧТАРЬОВ ДМИТРО ОЛЕГОВИЧ - керівник з 25.05.2016 (не має);
>
> We had this line on all our extracts since the company was opened and
> RIPE has a) accepted us as a member by reviewing those extracts b)
> approved numerous in and out transfers with those extracts  since 2016
> c) recently approved a transfer out about 2 weeks ago using the extract
> with the same line.
>
> 4 days ago we have requested another transfer and a RIPE rep. has asked
> us to clarify about what '(не має)' means in our extract. We have no
> clue what it means exactly and never interested because it was present
> since a first extract, also because RIPE has never questioned it before,
> and as I have mentioned, all the previous extracts came with that line.
>
> We don't have a clue of what it means and the RIPE's rep. decided to
> suspend the transfer and make a request to Ukraine's Ministry of
> Justice, which was very unexpected decision from our point of view.
> She told us that "Though we process tens of requests of Ukrainian
> companies every day, it's first time that we see such a record. It's not
> entirely clear what it means and what you as a Director "do not have".",
> to which I responded it's a false statement, because RIPE certainly HAS
> SEEN this line before, at least because my company have performed many
> transfers and requests with RIPE, which have been approved using same
> extracts. In this case, she talked about her own experience in the name
> of RIPE, which already was not very professional.
>
> So I obviously asked why does some her or RIPE's unawareness in
> Ukraine's legislation should concern us, to what I got no answer at all.
> Are we really responsible for RIPE's lack of knowledge on some subject?
> Our company is active and the extracts are all valid on the min. justice
> site, also the signee of the T.A. corresponds to the director name -
> this all makes us compliant to the RIPE's rules and policies, which, we
> believe should have made this transfer complete already.
>
> Notwithstanding our expectations, RIPE didn't provide any answer to our
> questions and also didn't tell why this specific matter should concern
> this specific transfer, since there were already approved transfers
> using same extract. Now we must wait about 2 or 3 weeks until the Min.
> of Justice responds them to clarify this, which made us very
> disappointed, since we still do not understand why this case affects our
> transfer at all.
>
> This is very frustrating and we have no more choices but hearing other
> members opinions and suggestions, if any. Doesn't it look like RIPE is
> very contradictory to its own policies in this case?
>
>
>
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-- 
Elvis Daniel Velea
V4Escrow LLC
Chief Executive Officer
E-mail: elvis at v4escrow.net
Mobile: +1 (702) 970 0921