Hi Aleksey,
On the 7th of September the NCC implemeted the document https://www.ripe.net/publications/docs/ripe-709#transfer35 (The document is published on the 21th of September). The support clarify it that you cannot merge one LIR into the second LIR in case of M&A procedure because of the 24 month resource transfer restriction.
That section doesn't seem to be about M&A. It talks about normal transfers between LIRs that belong to the same member.However there is another document https://www.ripe.net/publications/docs/ripe-682#2-2-transfer…
where you can read the next:
2.2 Transfer Restrictions
This restriction does not prevent the resources from being transferred due to further mergers or acquisitions within the 24-month period.
M&A is a different thing. It involves changes in legal business structures. Take a look at https://www.ripe.net/publications/docs/ripe-709#transfer31 item ii:
"""
If the transfer is taking place due to a change in the structure of the organisation(s) involved (e.g., merger, acquisition), a description of the changes among these organisation(s) is necessary. This description must be accompanied by the official legal documents issued by the relevant national authorities proving/supporting the changes the request is based on.
If the change in the structure of the organisation(s) involved cannot be proven/supported by official documentation from national authorities describing this change (e.g., a network acquisition from one member to another), then these cases will fall within the scope of RIPE Policy "RIPE Resource Transfer Policies".
"""
If it is not M&A then the normal policies apply, even when transferring between LIRs belonging to the same member. That includes the 24 month waiting period.In this case the NCC doesn't follow own policies. Or am I wrong?
As far as I can see the NCC is following the policy.
Cheers,
Sander