The by attribute should contain the archiving entity. For regular users the archiving entity is the user account itself. Meaning the bare jid of the user. Compare that to the mam disco feature which is also announced at the bare jid of the user (see discovery in the MAM xep). The mam query is also made to the bare jid (which can be omitted by leaving the to attribute)
I can clean this up in the text. But in general you are right the mam xep could be a little more explicit about this. However I'm under the impression that we came to some kind of consent in the past that the account and not the server hosts the mam archive.
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