[cabf_validation] Government Entities and section 11.1.3

[Ryan Sleevi]

On Thu, Sep 24, 2020 at 2:07 PM Daniela Hood via Validation <
validation at cabforum.org> wrote:

> Hello All,
>
>
>
> The team brought up something about the implementation of ballot SC30,
> that I wanted to get some clarifications.
>
> I have asked a similar question before and Ryan was kind enough to answer,
> but the way it is written still causing multiple interpretations.
>
>
>
> “Effective as of 1 October 2020, prior to the use of an Incorporating
> Agency or Registration Agency to fulfill these verification requirements,
> the CA MUST publicly disclose Agency Information about the Incorporating
> Agency or Registration Agency.”
>
>
>
> 1-Some members of the team read that this does not affect sub section 6
> Professional Opinion Letters.
>
>
>
> 2-Others read that, it does affect because on the letter it discloses the
> jurisdiction.
>

#2 is correct.

That is, Verified Professional Letters (11.2.2 (6)) used to establish the
information required by 11.2.2 (1) still requires disclosure of the
Incorporating Agency or Registration Agency used by the Verified
Professional Letter.

That is, while a Verified Professional Letter allows the CA to not have to
directly verify with the Incorporating or Registration Agency, the issuer
of the Verified Professional Letter is still required to perform that task,
and required to provide supporting documentation to that effect (e.g.
"certificate of registration, articles of incorporation, operating
agreement, statute, or regulatory act" all have, in some way, a scoping of
the jurisdiction information and tied to such an Agency, at least with
respect to Private Organizations or Business Entity Subjects)

Put differently, the goal for disclosure is the set of sources in
11.2.1(1)(A)/(C) and 11.2.1(3)(A)/(C), as these use Incorporating /
Registration Agencies. 11.2.2 describes methods of validating that
information, but at the core, the information required by 11.2.1 still has
to be obtained, and that's what is being disclosed here, regardless of how
11.2.2 validated it.


> When I asked this previously, Ryan clarified that for Business Entities
> second option would be true, however the same is not applicable for
> Government Entities.
>
>
>
> My goal it is to make sure we are all on the same page here and that the
> section 11.1.3 of the EV Guidelines does not pertain to Government Entities.
>
> If that is the case, I would also suggest the addition of clarification
> language, so people that are in the industry but do not participate in this
> forum, are also aware of the intent of this section.
>

>
> Any thoughts, suggestions?
>

I guess I'm not sure the relationship between Verified Professional Letters
and Government Entities here, in the context of 11.1.3, since it only
discusses Incorporating Agency / Registration Agency.
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