> On 4 Dec 2017, at 12:51 pm, Kirk Hall <[email protected]> wrote:
> 
> Geoff, a few quick responses to your points below:
> 
> 1. I think you are proposing the CA confirm the address information by 
> sending (mail, delivery) a confirmation message with a shared secret to the 
> customer, and requiring a response back using the shared secret.  I think 
> that's a good idea - it might get problematic for a big company (for Apple, 
> we might have to mail to you at 1 Infinity Loop - how long would it take for 
> you to receive it?).

No—this section is verification of ‘Applicant’s Physical Existence’, so this 
would be (i)(2), a site visit confirming such things as permanent signage.  The 
ability to receive mail is not what that section is trying to check; drop 
boxes, PO boxes, and such are not good enough.

> 2.  We can also require a Face-to-Face requirement to discourage potential 
> fraudsters, maybe limited to companies less than 1 year old (less than 6 
> months old?) and with net worth (as reported in a third party business data 
> source) of less than $1 million (?) - financial estimates like that are made 
> by the third party data source, and are not self-reported.  Maybe we also 
> should limit the mailing address confirmation the same way - only require for 
> companies that are less than 1 year old (6 months old?) and with new worth 
> (as reported in a third party business data source) of less than $1 million.  

Again, I’m not sure what a face-to-face would be verifying.  This isn’t about 
existence of the person, it’s about the business.

> 3.  Geoff, while it's true that third party data sources will start with 
> self-reported data (like name and address), the rest of the data they use is 
> typically compiled by the third party data source, not just from 
> self-reported data or copied from public government data bases.

Yes… but we don’t require any of that other data, just the name and address.

>  Remember, the main customers of Hoover's and D&B are using the data to make 
> major credit decisions, not just to confirm addresses or incorporation 
> status, and the third party data sources use their own data (including credit 
> reporting from vendors who work with the subject company) and their own 
> anti-fraud algorithms to avoid broadcasting false data.  

Well, maybe we could require an actual credit check, then?  Or at least 
existence of a bank account?  Banks are required to do their own verification 
so I’d think the existence of a bank account with that address should count for 
something.  But a bank usually won’t release the physical address, only the 
mailing address…

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