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And you don't even (necessarily) need to wipe the device.
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That depends on if they were on a BES or not. If the BB's have a policy on them and they are on a different BES that is not in your BESMgmt database then they should be wiped. BES 4.0 and up has a hash key used to check the policy and if they don't match the Enterprise Activation will crap out on the Waiting for policy stage.
But you are right, if they are personal devices and were never on a BES they don't need to be wiped.
Just my .02
