We had a thread about the TSYS application but not for First Data.

Unlike with TSYS I don't see anything here that leaps out as problematic in the 
to-be-signed certificates but I do think the moral hazard problem is larger 
here than with TSYS and anyway bears revisiting.

First Data say they told their customers about a fixed deadline at the end of 
June. Many customers ignored/ missed this deadline, so First Data announced a 
new one, large numbers of customers (300 000 or 25%) also missed this deadline. 
First Data want new SHA-1 certificates in order to continue servicing these 
customers anyway.

I haven't much confidence that First Data's customers will be upgraded for the 
new deadline implied by the SHA-1 exception. That means we're going to be here 
again in 2017, and also we're going to hear that Firefox can't disable SHA-1 
because it will break all these "temporary" exceptions.

I looked at the public communications from First Data (e.g. from 12 months ago) 
and I was disappointed. These are not effective calls to action. Every First 
Data customer who got these communications should have come away understanding 
if they needed to do anything, and if so with a clear idea what they could do. 
Instead these messages are vague, and mostly try to push all the work onto 
VARs, even though First Data admits their customers may not know who their VAR 
is, if they even have one. First Data sites today don't put this _vital_ 
information about SHA-1 deprecation front and centre, there's no sign anything 
is wrong at all unless you look for it.

The communications also load all the onus to act onto customers who are worst 
affected, a customer with a serious problem is expected to reach out to a 
specific contact point, receive new documentation, act on the documentation and 
so on. This is the opposite way around from an approach that's actually going 
to succeed. _First Data was within its rights to act this way, but shouldn't 
feign surprise that instead many customers did nothing_.


"FD believes that these businesses, which by their nature are not technically 
sophisticated, should not be put to experience an extended business disruption 
that would result from the inability to extend SHA-1 certificates for the 
period requested."

They're First Data's customers, not ours. First Data made all the bad decisions 
that lead here, not us. This "guilt" approach isn't good, and I don't want to 
keep seeing this from SHA-1 exception applicants. If First Data really believes 
it's important that their customers shouldn't be disrupted, the work to be done 
lay with First Data, not with everybody else who managed their transition 
properly in plenty of time.
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