Aleksey, 

You do as if this was a surprise, but this is clearly documented and discussed. And you have been on the mailinglist for long enough to know that up front as well. 

If you have 3 LIR accounts this year, and want to put the resources in a single LIR, you MUST wait for 2 years before you can do so. 

All LIR accounts that are in either entity should be paid in FULL for the hole year once you start transferring resources.

This means you pay per LIR : 

2000 euro setup fee.
1400 euro first year
1400 euro second year

Times 3 ...

After that, you can request for a transfer of the resources in to a single account and close the 2 other LIR's.

After which, you have a single LIR account with 3 resources in it and a future cost of 1400 euro per year. 

What you want to do has nothing to do with a Policy violation ... the policy is clear, RIPE NCC is executing the policy as documented.

Regards,
Erik Bais



On 17/12/2018, 19:22, "address-policy-wg on behalf of Aleksey Bulgakov" <address-policy-wg-bounces@ripe.net on behalf of aleksbulgakov@gmail.com> wrote:

    Hi.

    Regarding our situation. We have 3 accounts opened this year (for
    different legal entities). We provided the oficial government
    documents that confirm M&A procedure. But the NCC doesn't want to
    merge 2 accounts (of closed organizations) into the 1st account due to
    it is necessary to convert such accounts into additional account of
    receiving party, regarding
    https://www.ripe.net/publications/docs/ripe-709#transfer36.

    But there is restriction to transfer the resources during 24 month
    between accounts of the same member. So we should pay for additional 2
    years fees.
    пн, 17 дек. 2018 г. в 21:12, Jens Ott - Opteamax GmbH <ripe@opteamax.de>:
    >
    >
    > > Which is kind of the point.  The 24 month restriction holds, unless
    > >  one LIR gets bought/merged, and the latter needs to be proved by
    > > official documents.
    >
    > This is also not correct! At least from my experience, the restriction
    > also persists on being bought!
    >
    > The difference between being bought and merged is, at least from
    > German legal point of view, that in a merge (=Verschmelzung) the $OLD
    > company does not exist any longer but becomes fully integrated into
    > $NEW company, while in buying a company, $OLD stays it's own legal entit
    > y.
    >
    > From my experience ONLY A MERGE IS accepted by RIPE to not apply
    > 24month restriction, while being bought does not shorten this restrictio
    > n.
    >
    > BR
    >
    > --
    > Jens Ott
    > Geschäftsführer
    >
    > Opteamax GmbH
    >
    > Simrockstr. 4b
    > 53619 Rheinbreitbach
    >
    > Tel.:  +49 2224 969500
    > Fax:   +49 2224 97691059
    > Email: jo@opteamax.de
    >
    > HRB: 23144, Amtsgericht Montabaur
    > Geschäftsführer: Jens Ott
    > Umsatzsteuer-ID.: DE264133989
    >


    --
    ----------
    Best regards,
    Alexey Bulgakov
    Tel.: +7 (926)690-87-29