Consultation Tracking Information
- Requested By: Staff
- Status: Closed
- Comments Opened: Linked to Discussion Archives: 10 September 2018
- Comments Closed: 21 September 2018
- Suggestion Number : 2018.20
Subject of Consultation
Today ARIN operates a service referred to as the Specified Transfer Listing Service (STLS). One aspect of this service provides a listing of individuals and organizations that have registered with ARIN as a transfer facilitator. This is a service intended to provide the community with an easily accessible list of possible facilitators to assist them in either being a source for a transfer or a recipient of a transfer. All transfer facilitators must pay a $1,000 (USD) fee and agree to the STLS Terms of Service before being listed publicly on our Registered Transfer Facilitators List. This list is not intended to endorse or recommend any of the facilitators listed but rather to provide contact information for anyone interested. It is recommended that anyone engaging one of these facilitators perform their own due diligence. ARIN will not act as a referral or comment on the services that any of these facilitators perform.
ARIN has received a suggestion via the ARIN Consultation & Suggestion Process (ACSP) regarding potential changes to the registered transfer facilitator service. The suggestion has been closed due to specific terms and conditions being outside the scope of ACSP; however, the suggestion and its accompanying documentation are still available for review. It may help this discussion if interested parties reviewed that documentation prior to commenting on this consultation.
ARIN is opening this consultation to gauge the community's interest in possible changes to the registered transfer facilitator service. This consultation is intended to be a high-level discussion of community interest to determine if further analysis or actions are recommended by the community.
Question #1: Should ARIN continue to offer the registered transfer facilitator service?
At present, we do offer a registered transfer facilitator service with 26 registered facilitators. Staff will point customers to this list if requested, but will make it very clear that ARIN does not endorse nor recommend any particular member of the list. ARIN will not answer any questions about any members on the list or even confirm that they have been involved in the completion of any transfers. This consultation seeks community feedback as to the usefulness of this service and whether ARIN should continue to provide this service in its current form. We appreciate any and all community feedback to help us evaluate this service.
Question #2: Should ARIN perform some form of verification to confirm the facilitator actually provides transfer facilitation?
At present, ARIN staff conducts very little verification of facilitators. Should there be some minimum set of criteria that must be met in order to be registered as a transfer facilitator? Examples might include:
- Verify the organization has a web site advertising transfer service
- Verify the organization has completed a minimum number of transfers
- Verify customers who have used the facilitator
- Vet a facilitator the same as any organization wishing to do business with ARIN
- Any other criteria?
Question #3: Should ARIN verify the business is capable of completing transfers – for example, verifying licensing/bonding, or insurance?
At present, we do not conduct any checks of licensing, financing, or insurance. Should there be some set of business criteria a transfer facilitator must meet in order to be registered? Examples might include:
- Appropriate business licensing
- Verification of bonding, insurance, or similar
Question #4: Should ARIN offer the ability for customers to provide feedback on facilitators?
At present, we offer no ability for customers to leave feedback on facilitators. Should we offer this service? If so, should ARIN verify customer providing the feedback has actually used that facilitator before allowing feedback? Should there be a mechanism for registered facilitators to contest feedback they believe is not legitimate?
Question #5: Should the fees for registered transfer facilitators be adjusted?
At present, we charge a $1,000 annual fee. Since we operate on a cost-recovery basis, and since some of the possible enhancements would likely increase the cost required to process each facilitator registration request, should fees be increased to cover this added cost?
We welcome the community's feedback. This consultation will remain open for two weeks and close on 21 September 2018.