[cabfpub] Verification of Legal Existence Ballot

Jeremy Rowley jeremy.rowley at digicert.com
Thu May 14 10:44:00 MST 2015

Thanks Ryan,

The definition of a Verified Legal Opinion and Verified Accountant Letter requires verification under 11.11.1 or 11.11.2 of the EV Guidelines, meaning the verification process for the letter is built into the definition itself.

For government entities, the working group decided that if we were permitting Private Organizations and Business Entities to use accountant letters, then government entities should be permitted to do so as well. The inclusion of accountants was intentional.


From: Ryan Sleevi [mailto:sleevi at google.com]
Sent: Thursday, May 14, 2015 11:31 AM
To: Jeremy Rowley
Cc: public at cabforum.org
Subject: Re: [cabfpub] Verification of Legal Existence Ballot

Thanks Jeremy for circulating this.

I've tried to respond inline below - I hope this doesn't screw up archive formatting.

On Thu, May 14, 2015 at 8:50 AM, Jeremy Rowley <jeremy.rowley at digicert.com<mailto:jeremy.rowley at digicert.com>> wrote:

(2) Government Entity Subjects: Unless verified under subsection (6), all items listed in Section 11.2.1(2) MUST either be verified directly with, or obtained directly from, one of the following: (i) a Qualified Government Information Source in the political subdivision in which such Government Entity operates; (ii) a superior governing Government Entity in the same political subdivision as the Applicant (e.g. a Secretary of State may verify the legal existence of a specific State Department), or (iii) from a judge that is an active member of the federal, state or local judiciary within that political subdivision, or (iv) an attorney representing the Government Entity.

This modification does seem to lead to a weaker, more lax requirement compared to the existing language. That is, with the new definition of Verified Professional Letter, the Accountant or Legal Opinion may be from an entity different than the Government Entity (or so it seems).

I didn't see where this requirement was preserved, and perhaps it's there in intent, but not letter.

This also changes the set of acceptable documents from being a "Verified Legal Opinion" to *also* accepting a Verified Accountant Letter for this validation. Is that intentional? What are the implications here of adding another means to verify for government entity subjects?

(B) Obtaining an Independent Confirmation From the Applicant (as described in Section 11.10.4), or a Verified Professional Letter Verified Legal Opinion (as described in Section 11.10.1), or a Verified Accountant Letter (as described in Section 11.10.2) verifying that the Contract Signer and/or the Certificate Approver, as applicable, is either an employee or has otherwise been appointed as an agent of the Applicant.

This change (and related) all strike mention of Sections 11.10.1/11.10.2, and the new definitional introduction of Verified Professional Letter doesn't strictly establish that the Verified Legal Opinion / Verified Accountant Letter must comply with the requirements.

This is arguably a pedantic distinction, since it should be "obvious" that Sections 11.10.1/11.10.2 apply, but it's worth highlighting that it is a semantic change. (Yes, a number of other sections referred to Verified Legal Opinion/Verified Accountant Letter w/o referring to the section cross-reference, but now we have *nothing* that cross-references, if this ballot goes forward)

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