I believe I posted that a bit ago, but yes. Our last request needed to be accompanied by a beautiful spreadsheet of transaction numbers, which have to line up just right to that individuals' IPs...ARIN has been giving the run around to a bunch of VPS providers requesting IP allocations in recent months, making processes take weeks to complete, requesting full client information for all allocations (not just most recent -- not to mention the fact they wanted address, phone numbers, emails instead of just names). I've know of one provider who ARIN requested individual transaction information.
For those providers that don't have an NDA on file with ARIN, I highly suggest you get one in sooner rather than later.