[cabfpub] [EXTERNAL] EV 11.2.1 Private Organization registration number or date

[Kirk Hall]

My feeling is we should modify to SHOULD and also require the CA to make a notation in the vetting file if the jurisdiction does not provide that information.  (Different question, but I'm assuming you can determine the registration is still active, right?)

I also think that a CA can't do the impossible, so if that jurisdiction simply does not have a registration number or date, you should record that and go ahead and issue.  When we drafted this section, we assumed the info would always be available (as I recall, New York has no registration number but has a date), and we wanted to collect the info just to show the CA had done the work.  But if the data is not available, I don't think the EV cert should be denied so long as you get proof the registration exists and document that to the file.

From: Public [mailto:public-bounces at cabforum.org] On Behalf Of Rich Smith via Public
Sent: Thursday, August 31, 2017 8:30 AM
To: 'CA/Browser Forum Public Discussion List' <public at cabforum.org>
Subject: [EXTERNAL][cabfpub] EV 11.2.1 Private Organization registration number or date

EVG 11.2.1 (1)(c) states:
(C) Registration Number: Obtain the specific Registration Number assigned to the Applicant by the Incorporating or Registration Agency in the Applicant's Jurisdiction of Incorporation or Registration. Where the Incorporating or Registration Agency does not assign a Registration Number, the CA SHALL obtain the Applicant's date of Incorporation or Registration.

What if the Registration Agency simply does not publish, and will not provide either registration number or date?  In the case I'm looking at they have legal name, registered address and phone number.  There is no registration number nor date published and they will not provide either one even when our agents call in and ask for the information.

If the only answer at this time is, "Then we can't issue an EV cert," which is the direction I'm leaning, then I'd like to discuss/propose changing "CA SHALL" in the above to "CA SHOULD".

Feedback would be much appreciated, especially from those who might be willing to endorse such a ballot or those who might be strongly opposed to such a ballot.  If anyone has a sound argument that we actually can issue an EV under the current wording, I'd love to hear that as well.

Thanks,
Rich Smith
Senior Compliance Manager
Comodo
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