[cabfpub] EV 11.2.1 Private Organization registration number or date

[Geoff Keating]

> On 31 Aug 2017, at 2:42 pm, Kirk Hall via Public <public at cabforum.org> wrote:
> 
> Geoff – clearly this applicant will now be denied, but I have to disagree with one of your underlying assumptions below - “there is no way to uniquely identify the entity”.  Rich Smith of Comodo indicated that the applicant’s corporate registration had been confirmed with the government authority – perhaps based on address or some other identifying factor.  Again, when we drafted the EVGL (I think I drafted this particular section), we assumed there would be a registration number or date of registration in all records (we were wrong), but even without that, a CA would have the ability to confirm proper corporate registration tied to the applicant’s unique identity so that identity would be confirmed.

Even assuming that there isn’t the possibility of two simultaneous registrations of different entities with the same name (hopefully the government authority prevents this), one question is whether, in future, this entity could dissolve, and a new distinct entity could be created with the same name at the same address.  I don’t know what kind of entity we’re talking about, so I don’t know how easy this would be.  In some cases, for example partnerships in the US, this happens routinely and frequently.

> I think we should amend EVGL 11.2.1 (1)(c) to allow some other method for recording the confirmation of proper corporate registration.  Since Rich knows the facts if this case, I’ll leave it to him to come up with any amending language.

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