There is IPV4 exhaustion and many ISPs lease IPV4 space from other entities, such as brokers and other providers. One of the biggest IPv4 lessors is Cogent. By Cogent having legacy IP space from IANA which it inherited when it acquired PSInet, Cogent was not required to sign a contract when RIR ARIN was created.
Therefore, Cogent currently does not have and is not member of ARIN. It refuses to sign contract with ARIN and currently Cogent is not bound by this RUD rules and regulations.
There is one downfall to not being ARIN member, Cogent cannot currently issue ROAs or RPKIs. They only update RIR in ROADB database for the leased out IP addresses.
By implicitly requiring ROA or RPKI for IPv4 space leased from Covent, about 70% of small ISPs that were created after IPv4 space exhaustion, would not be able to route their IPV4 traffic, because currently they lease IPv4 space from Cogent, and as we mentioned, by Cogent refusing to become ARIN member, it cannot issue ROAs or RPKIs, and therefore ISPs using this leased IPV4 space can only use LOAs for validation.