From the Impact Analysis:
This policy proposal requires the RIPE NCC LIRs to be in compliance with the RIPE NCC's policies. The RIPE NCC will conduct an audit to ensure that this is the case prior to completing a transfer.
I think that this is an excessively strict interpretation of the policy, one which I suspect isn't the intention of the proposer. In my opinion, an LIR should be assumed to be in compliance with the RIPE NCC's [sic] policies; the mere act of participating in an inter-RIR transfer should not cause an automatic LIR Audit. Mandatory LIR Audits would only serve to increase the amount of hassle and bureaucracy involved in completing such transfers, and might well discourage LIRs from participating in them at all. Given that this is the NCC's interpretation of 2012-02, I don't support the proposal as it is currently worded, and hope it could be modified so that it will not cause mandatory or automatic LIR Audits. -- Tore Anderson Redpill Linpro AS - http://www.redpill-linpro.com/