Ballot 7 – Parent Subsidiary
Ballot 7 – Parent Subsidiary (Passed Unanimously)
Motion
Tony Berman has made the following motion, and Peri Drucker and Bruce Morton have endorsed it:
Motion begins
The Guidelines should be amended by the following erratum.
Erratum begins
Section 16 (a) (1)
Add: “or a Parent/Subsidiary Company”.
The revised section shall read:
“(a) Address of Applicant’s Place of Business
(1) Verification Requirements To verify Applicant’s physical existence and
business presence, the CA MUST verify that the physical address provided by
Applicant is an address where Applicant or a Parent/Subsidiary Company conducts business operations (e.g., not a mail drop or P.O. box), and is the address of Applicant’s Place of Business.”
Section 16 (a) (2) (A) (1)
Add: “or a Parent/Subsidiary Company“.
The revised section now reads:
(2) Acceptable Methods of Verification To verify the address of Applicant’s
Place of Business:
(A) For Applicants whose Place of Business is in the same country as
Applicant’s Jurisdiction of Incorporation or Registration:
(1) For Applicants listed at the same Place of Business address in the
current version of either at least one (1) Qualified Independent
Information Source or a Qualified Governmental Tax Information
Source, the CA MUST confirm that Applicant’s address as listed in the
EV Certificate Request is a valid business address for Applicant or a Parent/Subsidiary Company by reference to such Qualified Independent Information Sources or a Qualified Governmental Tax Information Source, and MAY rely on Applicant’s representation that such address is its Place of Business;
Section 16 (a) (2) (A) (2)
Add: “or a Parent/Subsidiary Company’s”.
The revised section shall read:
“For Applicants who are not listed at the same Place of Business address in the current version of either at least one (1) Qualified Independent Information Source or a Qualified Governmental Tax Information Source, the CA MUST confirm that the address provided by Applicant in the EV Certificate Request is in fact Applicant’s or a Parent/Subsidiary Company’s business address, by obtaining documentation of a site visit to the business address which MUST be performed by a reliable individual or firm. The documentation of the site visit MUST:
(a) Verify that Applicant’s business is located at the exact address stated in the EV Certificate Request (e.g., via permanent signage, employee confirmation, etc.);
(b) Identify the type of facility (e.g., office in a commercial building, private residence, storefront, etc.) and whether it appears to be a permanent business location;
(c) Indicate whether there is a permanent sign (that cannot be moved) that identifies Applicant;
(d) Indicate whether there is evidence that Applicant is conducting ongoing business activities at the site (e.g., that it is not just a mail drop, P.O. box, etc.); and
(e) Include one or more photos of (i) the exterior of the site (showing signage indicating Applicant’s name, if present, and showing the street address if possible), and (ii) the interior reception area or workspace.
Section 16 (a) (2) (A) (3)
Add: “or a Parent/Subsidiary Company”.
The revised section shall read:
“(3) For all Applicants, the CA MAY alternatively rely on a Verified Legal
Opinion or a Verified Accountant Letter that indicates the address of
Applicant’s or a Parent/Subsidiary Company’s Place of Business and that business operations are conducted there.”
Definitions
Delete “Wholly owns” add “owns a majority of”.
Parent Company: A parent company is defined as a company that owns a majority of the Subsidiary Company and this can be verified by referencing a QIIS or from financial statement supplied by a registered Chartered Professional Accountant (CPA) or equivalent outside of the USA.
Subsidiary Company:
Delete “Wholly owned” add “majority owned”.
The new definition shall read:
“A subsidiary company is defined as a company that is majority owned by Applicant as verified by referencing a QIIS or from financial statement supplied by a registered Chartered Professional Accountant (CPA) or equivalent outside of the USA.”