Today I noticed the following ComSign response to question 6 [1] in
Mozilla's November 2017 CA Communication:

We are in the process of perfecting our CAA system. As far as I know we do
> not have a devoted mailbox for problem reporting in the root program, the
> mail for that should be mine – ya...@comda.co.il
>

<ya...@comda.co.il>
This first implies that ComSign is not yet performing CAA checking as
required by the BRs effective 8-Sept 2017.

While the BRs do not require problem reports to be accepted via email, they
do require CAs to "publicly disclose the instructions through a readily
accessible online means". The ComSign CPS includes two email addresses:
supp...@comsign.co.il and customer_servi...@comsign.co.il. How has ComSign
met this requirement?

I will leave the discussion period open until ComSign has responded to
these concerns.

- Wayne

[1] https://ccadb-public.secure.force.com/mozillacommunications/
CACommResponsesOnlyReport?CommunicationId=a051J00003mogw7&QuestionId=
Q00042,Q00048

On Tue, Jan 16, 2018 at 2:05 PM, Wayne Thayer via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> To recap, we've established that this root was first BR audited on
> 26-April 2015 and has received clean period-of-time audits over the next
> two years. ComSign has disclosed 36 certificates issued by this root prior
> to the BR point-in-time audit, of which one remains unexpired. This does
> not meet the requirements of BR section 8.1 both because the point-in-time
> readiness assessment was not completed prior to issuing a publicly-trusted
> certificate, and because the first period-of-time audit was not completed
> within 90 days of issuing a publicly-trusted certificate. Mozilla policy,
> however, does not require a root to have maintained BR compliance over its
> entire lifetime to be included in the program. ComSign's current annual
> WebTrust for CAs and BR audits are enough to meet Mozilla's requirements.
>
> The questions I raised have been addressed to my satisfaction. If anyone
> has further concerns, please raise them this week so that we can complete
> the public discussion period for this inclusion request.
>
> - Wayne
>
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