Thanks Eric.

I would also like to point out that WEBTRUST PRINCIPLES AND CRITERIA FOR 
was updated in February 2018, 
( requires 
passwords to be changed every 3 months.  Hopefully webTrust will adjust to the 
NIST guidelines also.



With kind regards,

Patrick Tronnier
Principal Security Architect &
Sr. Director of Quality Assurance & Customer Support
Phone: 763.201.2000
Direct Line: 763.201.2052
Open Access Technology International, Inc.
3660 Technology Drive NE, Minneapolis, MN

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From: Eric Mill []
Sent: Thursday, May 17, 2018 10:43 AM
To: Geoff Keating <>; CA/Browser Forum Public Discussion List 
Cc: Patrick Tronnier <>
Subject: Re: [cabfpub] Ballot 221 v3: Two-Factor Authentication and Password 

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FedRAMP has published guidance about the new NIST password/identity guidelines:

They note that the formal baseline is still not updated, but encourage folks to 
follow NIST's new guidance regardless:

NOTE: At the time of this document’s publication, FedRAMP Moderate and High 
controls IA-5 (g)
and IA-5 (1) (a,d) are known to be more restrictive than the new password 
requirements in 800-
63B, AAL2 and AAL3 respectively. FedRAMP recommends Agency AOs accept 
compliance with
NIST’s guidance that is most up-to-date and consistent with current cyber 
security threats. This
may be done using an implementation status of “Alternative Implementation.”

I also confirmed with the FedRAMP program that the baseline is expected to be 
updated to match NIST's SP 800-63, and thus avoid the need for any special 
acceptance. But the point is that FedRAMP is not an obstacle to dropping 
password rotation -- they are expecting service providers to follow NIST's 
guidance and drop it.

-- Eric

On Tue, May 15, 2018 at 6:48 PM, Geoff Keating via Public 
<<>> wrote:

> On May 15, 2018, at 8:37 AM, Patrick Tronnier via Public 
> <<>> wrote:
> I want to make it clear that OATI agrees with the minimum 2 year password 
> period as the more secure route. It is FedRAMP and other standards which 
> don’t. J

I've been looking at FedRAMP, because I was surprised they'd be putting out 
guidelines that conflict with NIST guidelines, and I can't find this 
requirement; for the 'high security controls' 
 it does require you have a minimum and maximum password lifetime in 
IA-05(1)(d), but it says the actual limits are organization-defined, so you can 
ask the organization to set the maximum lifetime to, say, 3 years.

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