I agree with Jeremy.

Ryan Hurst

On Thu, Feb 9, 2023 at 10:28 AM 'Jeremy Rowley' via
[email protected] <[email protected]> wrote:

> Which CAs are even publicly traded at this point – Google, Amazon,
> Entrust?  Plus, do government CAs qualify as having independently and
> publicly available audited financial statements? What about services like
> Let’s Encrypt? They publish a report on their finances but I think that
> report is written by Let’s Encrypt, not independent auditors?  I’d venture
> most of the CAs in the root program don’t meet both the independent and
> publicly available statements.
>
>
>
> I don’t like this requirement because it means only small subsidiaries of
> very large organizations can be a CA.
>
>
>
>
>
> *From:* [email protected] <[email protected]> *On
> Behalf Of *Matthew Hardeman
> *Sent:* Thursday, February 9, 2023 11:11 AM
> *To:* Kathleen Wilson <[email protected]>
> *Cc:* [email protected]
> *Subject:* Re: DRAFT: Root Inclusion Considerations
>
>
>
> As a rule, you tend to have to be a pretty significant business operation
> to have accounts / financial statements that are "independently audited or
> examined."
>
>
>
> Even many small businesses have their financials and tax accounting
> reviewed and prepared by accounting professionals.  But that's different
> from a formal assertion of "independently audited or examined."
>
>
>
> In the US, publicly traded corporations would be.  But many private
> entities would not.  It can add a significant time investment and
> significant expenditure to go that extra step and get an assertion from the
> accountant that the financials represented in the report do materially
> reflect the state of the business.
>
>
>
> Without expressing a particular opinion on the matter, I believe that you
> should contemplate whether any risk mitigation value of imposing such
> burdens outweighs the costs to the CA / prospective CA.
>
>
>
> On Thu, Feb 9, 2023 at 11:54 AM Kathleen Wilson <[email protected]>
> wrote:
>
> Would it be reasonable to add the following as a Concerning Behavior?
>
>
>
> - The CA does not publish annual accounts or financial statements that
> have been independently audited or examined.
>
>
>
> This has been suggested to me via email, but I am not versed in this area.
>
>
>
> Thanks,
>
> Kathleen
>
>
>
>
>
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