Hi Radu, Thank you for providing concrete cases! This is now something that can be discussed.
Three: - That other LIR opens up a second LIR - They get their /22 (free) - They can no longer apply "M&A" because the definition of "M&A" changed, and they have to do a regular transfer.
On a general basis, there may be reasons for which you have to proceed with a regular transfer, other than "get IPs from NCC in order to sell them".
It is my understanding, and please someone from RIPE NCC confirm or infirm that in public, that M&A has "slightly" changed recently, and the following operations are no longer M&A: - merging several existing LIRs having the same owner. - re-organisation of address space between the LIRs of a group. - purchasing a company but keeping the purchased company's legal entity (you accountant will give you good reasons for this; if you live in counties like France, your HR will give a few more reasons). - putting together resources of several entities within a group without proceeding with heavy legal and administrative paperwork.
So basically what you are worried about is that RIPE NCC will not treat all M&A as M&A and might apply the transfer policy instead, and that with this proposal stopping transfers of the /22 the M&A would be blocked, causing such members to be forced to keep multiple LIRs open. Let's ask our friendly PDO to ask his colleagues within RIPE NCC how the cases you mention would be treated.
currently violating the policy by requesting my /22 for the wrong reasons
Policy-wise, there are no "wrong reasons".
Yes there are. The policy explicitly states "The LIR must confirm it will make assignment(s) from the allocation". If you request an allocation without the intention of making assignments from it you have lied during your allocation request. That is a policy violation. But anyway: let's wait for the RIPE NCC to get back to this list with more data on M&A! Cheers, Sander