On Jul 11, 2023, at 11:47 AM, Owen DeLong <owen@delong.com> wrote: Actually, I couldn’t find anything in the NRPM which leads me to believe that there is any distinction in the documentation requirements for reassignment/reallocation regardless of associated connectivity. None of the policies seemed to specify this. As such, I would think that Connectivity Independent Leasing (CIL) and Connectivity Related Leasing (CRL) would be subject to exactly the same recording/reporting requirements. Owen – ARIN NRPM Section 4.2.3. "Reassigning and Reallocating Address Space to Customers" utilizes the term “Downstream” in references to both downstream end-users and downstream ISPs documentation requirements. As the community has historically interpreted the phrase “downstream" to refer to connectivity customers (and further that the requirements documented are applied in oder to have accurate operational utilization), ARIN continues to interpret the policy as applicable to reissuance of resources to connectivity customers. Of course, further policy clarity (whether to make clear that it does apply to non-connectivity reassignments or to make clear it does not apply beyond downstream customers) would be most welcome; I believe you are already aware of the policy proposal submission process if you want to propose updating it accordingly. Thanks! /John John Curran President and CEO American Registry for Internet Numbers