This comment is likely going to be viewed as being in poor taste...

Wasn't it a lack of regulation that managed to put the US and the rest
of the world into this economic semi-meltdown that we're in?  Wasn't
it untrustworthy auditing (from Arthur Anderson) that led to the
implementation of Sarbanes-Oxley and such?

-Kyle H

On Mon, Dec 29, 2008 at 1:23 PM, Eddy Nigg <eddy_n...@startcom.org> wrote:
> On 12/29/2008 08:04 PM, Frank Hecker:
>>
>> When we created the policy I was well aware of the existence of RAs and
>> of the possibility that CAs might outsource functions like domain
>> validtion to RAs. Whether or not this is clear from the policy (and I
>> guess it's not, since you and others are asking about this), my
>> intention was certainly that the activities of RAs were considered to be
>> encompassed within the overall activities of CAs, and that the policy's
>> requirement for CAs to validate domains left open the possibility that
>> this might be done by RAs acting as agents of CAs.
>
> Incidentally we've not long ago agreed that we'll have to look at the
> various RAs scenarios more closely in the future. There is a similarity
> between externally controlled sub CAs, RAs and apparently also "Resellers",
> where resellers actually act as RAs (according to Comodo's CPS).
>
> As in the case of various other issues listed in the "Problematic Practices"
> pages [1], RAs will have to be defined more clearly as well. Something which
> was supposed to be obvious apparently isn't.
>
> As such, there are many common practices in this industry which are not up
> to today's requirements and/or the race to the bottom require clear
> regulation, something which previously maybe wasn't required. My insistence
> on detecting, declaring and defining them previously always had the goal to
> prevent possible damage and with it make PKI and digital certificates
> irrelevant for the Internet. Therefore, common practice by CAs never must be
> the criteria for sound and responsible requirements.
>
>> So, to repeat, I don't think the key issue here is whether CAs should or
>> should not be allowed to delegate domain validation to RAs. The question
>> (e.g., as in the case of Comodo and Certstar) is rather whether
>> particular RAs are doing this properly, and if it's not done properly,
>> whether the failures on the part of RAs represent isolated incidents or
>> whether they indicate a systemic failure of the CA to properly oversee
>> its RAs.
>
> It's the inconvenience to have to confirm an email ping or other automated
> control verification by the subscriber which leads some CAs to circumvent it
> with "agreement by checkbox" validation. This results in an undue risk
> (being it just by human error and not intend or negligence) and unfair
> competition as well. I'd never outsource domain name validation to such
> identities like RAs and Resellers, not even for intermediate CAs. RAs may
> perform identity or organization validation sometimes more efficient than
> the CA due to local proximity, however technical requirements such as domain
> or email have no justification to be outsourced. Otherwise also physical and
> local controls and requirements will have to be added to the RA
> infrastructure, which makes it even more complicated.
>
> [1] http://wiki.mozilla.org/CA:Problematic_Practices
>
> --
> Regards
>
> Signer: Eddy Nigg, StartCom Ltd.
> Jabber: start...@startcom.org
> Blog:   https://blog.startcom.org
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>
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