Hi Alex, 
1. Problem statement
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Policy Proposal prop-116-v006: Prohibit to transfer IPv4 addresses in 
the final /8 block reached consensus at the APNIC 44 AMM on 14 Sep 
2017. Since that APNIC has stopped all the IPv4 transfers from 103/8 
block if the delegation date is less than 5 years.

However, some of the 103/8 ranges were delegated before 14 Sep 2017. 
Those resources should not be subjected to 5 years restriction. The 
community was not aware of the restriction when they received those 
resources, some of the resources have been transferred or planning to 
transfer. 
ftp://ftp.apnic.net/apnic/docs/membership-agreement.txt
5    General
------------

5.1    APNIC Documents
The Member agrees that:
(a) The APNIC Documents may be amended from time to time in
accordance with the Document Review Policy; 
(b) Any such amendments are binding upon the Member;
(c) APNIC Documents as they exist from time to time form an integral part of and apply fully to this agreement; and
     
If APNIC is not allow those transfers to be registered, 
there will be underground transfers. 
You mean leasing? or resource holder gives away access to myapnic account along with resources? because there is no such thing as underground transfer. 
This will cause incorrect APNIC Whois data.
 I appreciate your intentions.
--
Best Wishes,

Aftab A. Siddiqui