On Fri, April 24, 2015 6:34 am, Moudrick M. Dadashov wrote:
>  Kathleen, wouldn't be it easier to apply the transferred CA the same
>  requirements as to any other? That means the new CA must have its
>  operations audited under its ***fully completed transfer*** operations.
>
>  The root and all associated intermediates must pass audit against
>  ***then applicable*** requirements only after having the CP/CPS clearly
>  disclosing the details/nature of the transfer.

When you say "the same requirements as any other" - are there
fundamentally any differences here than a CA cross-signing a new root
certificate?

Are there fundamentally ay differences here than a CA signing a new
unconstrained intermediate?

I think that is truly the crux of the question, and frankly, I don't think
there is. We have two standards for "organizations capable of causing
certificate issuance"

- Those who apply to Mozilla and wish to be single-handedly responsible
for their destiny.
- Those who find another CA who will sign their certificate, and thus
avoid Mozilla review.

In exchange for not having to do the Mozilla process (or any other root
processes), they lose their independence. For example, their "partner CA"
may decide a year later to charge them 10X what they originally stated,
and there's nothing the CA can do, other than accept their "partner CAs"
extortion (er, contract renegotiation based on changing business
conditions). No business likes having that sword hanging over their head,
but at the same time, it's "nice" to not have to rely on the unreliable
Mozilla community to do a timely review.

Similarly, the "partner CA" takes on risk that by allowing the CA to avoid
Mozilla review, the CA may botch things, and that will cause the "partner
CA" to suffer.

So it's a set of trade-offs, but it's unquestionably a double standard.

J don't see having the double standards as necessarily a bad thing either
- it recognizes the business realities, such that no organization likes to
wait on 30 different root stores and 30 different timeframes before they
can conduct business. On the Mozilla side, being volunteer driven, the
timelines vary wildly, and the thoroughness of review varies wildly. I
think in recent months, we've all become more attune to the thoroughness,
but I know I personally still greatly struggle with the timeliness.
Kathleen's the one consistent performer through all of this, which is
necessary, but not sufficient.

This is the long-winded way of saying I think Kathleen's proposals make
perfect sense. I don't think it introduces any new risks to the community
that are not inherently there, while offering a sensible path forward that
recognizes the tradeoffs.

As the community and process approves, and things like "disclosed sub-CA"
becomes some thing maintained automatically by CAs, we'll be in a better
place to align the two processes. Then, if someone wants to start a CA,
they can either block on the community review (new CA) or the community
can rely on an external party (the "partner CA") to do the initial review,
knowing their financially incentivized to do it 'right', and then the
community can review "after the fact" and take appropriate action.

In either event, full transparency is there, and full review is possible
at any time, so I don't think there's any harm Kathleen's proposal. At
best, for those nervous about the "community review" phase, we could just
tack on an added "Oh, and you have to tell moz.dev.security.policy after
you did this, rather than just updating your URL with the disclosure", and
we can go on our merry way at our leisure.

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