###### 3.2.2.2.10.1 Verified Legal Opinion 1. **Verification Requirements**: Before relying on a legal opinion submitted to the CA, the CA MUST verify that such legal opinion meets the following requirements: 1. **Status of Author**: The CA MUST verify that the legal opinion is authored by an independent legal practitioner retained by and representing the Applicant (or an in-house legal practitioner employed by the Applicant) (Legal Practitioner) who is either: 1. A lawyer (or solicitor, barrister, advocate, or equivalent) licensed to practice law in the country of the Applicant's Jurisdiction of Incorporation or Registration or any jurisdiction where the Applicant maintains an office or physical facility, or 2. A Latin Notary who is currently commissioned or licensed to practice in the country of the Applicant's Jurisdiction of Incorporation or Registration or any jurisdiction where the Applicant maintains an office or physical facility (and that such jurisdiction recognizes the role of the Latin Notary); 2. **Basis of Opinion**: The CA MUST verify that the Legal Practitioner is acting on behalf of the Applicant and that the conclusions of the Verified Legal Opinion are based on the Legal Practitioner's stated familiarity with the relevant facts and the exercise of the Legal Practitioner's professional judgment and expertise; 3. **Authenticity**: The CA MUST confirm the authenticity of the Verified Legal Opinion. 2. **Acceptable Methods of Verification**: Acceptable methods of establishing the foregoing requirements for a Verified Legal Opinion are: 1. **Status of Author**: The CA MUST verify the professional status of the author of the legal opinion by directly contacting the authority responsible for registering or licensing such Legal Practitioner(s) in the applicable jurisdiction; 2. **Basis of Opinion**: The text of the legal opinion MUST make it clear that the Legal Practitioner is acting on behalf of the Applicant and that the conclusions of the legal opinion are based on the Legal Practitioner's stated familiarity with the relevant facts and the exercise of the practitioner's professional judgment and expertise. The legal opinion MAY also include disclaimers and other limitations customary in the Legal Practitioner's jurisdiction, provided that the scope of the disclaimed responsibility is not so great as to eliminate any substantial risk (financial, professional, and/or reputational) to the Legal Practitioner, should the legal opinion prove to be erroneous. An acceptable form of legal opinion is attached as [Appendix B](#appendix-b---sample-attorney-opinions-confirming-specified-information); 3. **Authenticity**: To confirm the authenticity of the legal opinion, the CA MUST make a telephone call or send a copy of the legal opinion back to the Legal Practitioner at the address, phone number, facsimile, or (if available) e-mail address for the Legal Practitioner listed with the authority responsible for registering or licensing such Legal Practitioner, and obtain confirmation from the Legal Practitioner or the Legal Practitioner's assistant that the legal opinion is authentic. If a phone number is not available from the licensing authority, the CA MAY use the number listed for the Legal Practitioner in records provided by the applicable phone company, QGIS, or QIIS. In circumstances where the opinion is digitally signed, in a manner that confirms the authenticity of the document and the identity of the signer, as verified by the CA in Section 3.2.2.2.10.1 (2)(i), no further verification of authenticity is required.

###### 3.2.2.2.10.2 Verified Accountant Letter 1. **Verification Requirements**: Before relying on an accountant letter submitted to the CA, the CA MUST verify that such accountant letter meets the following requirements: 1. **Status of Author**: The CA MUST verify that the accountant letter is authored by an Accounting Practitioner retained or employed by the Applicant and licensed within the country of the Applicant's Jurisdiction of Incorporation, Jurisdiction of Registration, or country where the Applicant maintains an office or physical facility. Verification of license MUST be through the member organization or regulatory organization in the Accounting Practitioner's country or jurisdiction that is appropriate to contact when verifying an accountant's license to practice in that country or jurisdiction. Such country or jurisdiction must have an accounting standards body that maintains full membership status with the International Federation of Accountants. 2. **Basis of Opinion**: The CA MUST verify that the Accounting Practitioner is acting on behalf of the Applicant and that the conclusions of the Verified Accountant Letter are based on the Accounting Practitioner's stated familiarity with the relevant facts and the exercise of the Accounting Practitioner's professional judgment and expertise; 3. **Authenticity**: The CA MUST confirm the authenticity of the Verified Accountant Letter. 2. **Acceptable Methods of Verification**: Acceptable methods of establishing the foregoing requirements for a Verified Accountant Letter are listed here. 1. **Status of Author**: The CA MUST verify the professional status of the author of the accountant letter by directly contacting the authority responsible for registering or licensing such Accounting Practitioners in the applicable jurisdiction. 2. **Basis of Opinion**: The text of the Verified Accountant Letter MUST make clear that the Accounting Practitioner is acting on behalf of the Applicant and that the information in the letter is based on the Accounting Practitioner's stated familiarity with the relevant facts and the exercise of the practitioner's professional judgment and expertise. The Verified Accountant Letter MAY also include disclaimers and other limitations customary in the Accounting Practitioner's jurisdiction, provided that the scope of the disclaimed responsibility is not so great as to eliminate any substantial risk (financial, professional, and/or reputational) to the Accounting Practitioner, should the Verified Accountant Letter prove to be erroneous. Acceptable forms of Verified Accountant Letter are attached as [Appendix C](#appendix-c---sample-accountant-letters-confirming-specified-information). 3. **Authenticity**: To confirm the authenticity of the accountant's opinion, the CA MUST make a telephone call or send a copy of the Verified Accountant Letter back to the Accounting Practitioner at the address, phone number, facsimile, or (if available) e-mail address for the Accounting Practitioner listed with the authority responsible for registering or licensing such Accounting Practitioners and obtain confirmation from the Accounting Practitioner or the Accounting Practitioner's assistant that the accountant letter is authentic. If a phone number is not available from the licensing authority, the CA MAY use the number listed for the Accountant in records provided by the applicable phone company, QGIS, or QIIS. In circumstances where the opinion is digitally signed, in a manner that confirms the authenticity of the document and the identity of the signer, as verified by the CA in Section 3.2.2.2.10.2 (2)(i), no further verification of authenticity is required.

###### 3.2.2.2.10.3 Face-to-Face Validation 1. **Verification Requirements**: Before relying on face-to-face vetting documents submitted to the CA, the CA MUST verify that the Third-Party Validator meets the following requirements: 1. **Qualification of Third-Party Validator**: The CA MUST independently verify that the Third-Party Validator is a legally-qualified Latin Notary or Notary (or legal equivalent in the Applicant's jurisdiction), Lawyer, or Accountant in the jurisdiction of the individual's residency; 2. **Document Chain of Custody**: The CA MUST verify that the Third-Party Validator viewed the Vetting Documents in a face-to-face meeting with the individual being validated; 3. **Verification of Attestation**: If the Third-Party Validator is not a Latin Notary, then the CA MUST confirm the authenticity of the attestation and vetting documents. 2. **Acceptable Methods of Verification**: Acceptable methods of establishing the foregoing requirements for vetting documents are: 1. **Qualification of Third-Party Validator**: The CA MUST verify the professional status of the Third-Party Validator by directly contacting the authority responsible for registering or licensing such Third-Party Validators in the applicable jurisdiction; 2. **Document Chain of Custody**: The Third-Party Validator MUST submit a statement to the CA which attests that they obtained the Vetting Documents submitted to the CA for the individual during a face-to-face meeting with the individual; 3. **Verification of Attestation**: If the Third-Party Validator is not a Latin Notary, then the CA MUST confirm the authenticity of the vetting documents received from the Third-Party Validator. The CA MUST make a telephone call to the Third-Party Validator and obtain confirmation from them or their assistant that they performed the face-to-face validation. The CA MAY rely upon self-reported information obtained from the Third-Party Validator for the sole purpose of performing this verification process. In circumstances where the attestation is digitally signed, in a manner that confirms the authenticity of the documents, and the identity of the signer as verified by the CA in section 3.2.2.2.10.3 (1)(i), no further verification of authenticity is required.

###### 3.2.2.2.10.4 Independent Confirmation From Applicant An Independent Confirmation from the Applicant is a confirmation of a particular fact (e.g., confirmation of the employee or agency status of a Contract Signer or Certificate Approver, confirmation of the EV Authority of a Certificate Approver, etc.) that is: 1. Received by the CA from a Confirming Person (someone other than the person who is the subject of the inquiry) that has the appropriate authority to confirm such a fact, and who represents that he/she has confirmed such fact; 2. Received by the CA in a manner that authenticates and verifies the source of the confirmation; and 3. Binding on the Applicant. An Independent Confirmation from the Applicant MAY be obtained via the following procedure: 1. **Confirmation Request**: The CA MUST initiate a Confirmation Request via an appropriate out-of-band communication, requesting verification or confirmation of the particular fact at issue as follows: 1. **Addressee**: The Confirmation Request MUST be directed to: 1. A position within the Applicant's organization that qualifies as a Confirming Person (e.g., Secretary, President, CEO, CFO, COO, CIO, CSO, Director, etc.) and is identified by name and title in a current QGIS, QIIS, QTIS, Verified Legal Opinion, Verified Accountant Letter, or by contacting the Applicant using a Verified Method of Communication; or 2. The Applicant's Registered Agent or Registered Office in the Jurisdiction of Incorporation as listed in the official records of the Incorporating Agency, with instructions that it be forwarded to an appropriate Confirming Person; or 3. A named individual verified to be in the direct line of management above the Contract Signer or Certificate Approver by contacting the Applicant's Human Resources Department by phone or mail (at the phone number or address for the Applicant's Place of Business, verified in accordance with these Guidelines). 2. **Means of Communication**: The Confirmation Request MUST be directed to the Confirming Person in a manner reasonably likely to reach such person. The following options are acceptable: 1. By paper mail addressed to the Confirming Person at: 1. The address of the Applicant's Place of Business as verified by the CA in accordance with these Guidelines, or 2. The business address for such Confirming Person specified in a current QGIS, QTIS, QIIS, Verified Professional Letter, or 3. The address of the Applicant's Registered Agent or Registered Office listed in the official records of the Jurisdiction of Incorporation, or 2. By e-mail addressed to the Confirming Person at the business e-mail address for such person listed in a current QGIS, QTIS, QIIS, Verified Legal Opinion, or Verified Accountant Letter; or 3. By telephone call to the Confirming Person, where such person is contacted by calling the main phone number of the Applicant's Place of Business (verified in accordance with these Guidelines) and asking to speak to such person, and a person taking the call identifies him- or herself as such person; or 4. By facsimile to the Confirming Person at the Place of Business. The facsimile number must be listed in a current QGIS, QTIS, QIIS, Verified Legal Opinion, or Verified Accountant Letter. The cover page must be clearly addressed to the Confirming Person. 2. **Confirmation Response**: The CA MUST receive a response to the Confirmation Request from a Confirming Person that confirms the particular fact at issue. Such response MAY be provided to the CA by telephone, by e-mail, or by paper mail, so long as the CA can reliably verify that it was provided by a Confirming Person in response to the Confirmation Request. 3. The CA MAY rely on a verified Confirming Person to confirm their own contact information: email address, telephone number, and facsimile number. The CA MAY rely on this verified contact information for future correspondence with the Confirming Person if: 1. The domain of the e-mail address is owned by the Applicant and is the Confirming Person's own e-mail address and not a group e-mail alias; 2. The Confirming Person's telephone/fax number is verified by the CA to be a telephone number that is part of the organization's telephone system, and is not the personal phone number for the person.