According to 
https://docs.google.com/document/d/1S3u0-_YACA7m-3LPpjE-t4WCh2cww_SQFh2C9DJeXHA/edit?tab=t.0
 the "Subordinate CA Owner" field means:

"This is the Subordinate CA's name as it appears in the provided audit 
statements. CA Owners are to leave it blank if BOTH control of the private key 
AND domain/IP/email validation activities are performed by the organization 
listed in the audit statement of the parent certificate."

First, "if" should be "if and only if". Otherwise, a CA is free to leave it 
blank even if a different organization controls the private key, which I don't 
think is the intent.

Second, is this Google Doc considered part of the CCADB Policy?  If not, the 
above passage should be added to the CCADB Policy so that CAs are actually 
required to follow it.

Finally, is there any automated enforcement (e.g. Audit Letter Validation) to 
ensure that CAs are populating this field (or leaving it blank) correctly?

Regards,
Andrew

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