Fannie Mae Public Key Infrastructure Certificate Policy (CP) Version: Publication Date: Jan 23, 2018
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1 Fannie Mae Public Key Infrastructure Certificate Policy (CP) Version: Publication Date: Jan 23, Fannie Mae. Trademarks of Fannie Mae of 46
2 Change History The following Change History log contains a record of changes made to this document: Published / Revised Version # Author (optional) Section / Nature of Change 03 Jan Fecteau, Louie Initial Draft 01 Nov Fecteau, Louie Many changes 15 Nov Fecteau, Louie Font and Text 1/24/ FM Legal 1/27/ Fecteau, Louie Font and Text 3/06/ FM Internal Legal with external council Font and text 3/16/ Fannie Mae Legal Section 9 and other references re. certain provisions of the Fannie Mae Software Subscription Agreement governing liability etc. vis-à-vis Subscribers and Relying Parties 3/19/ Fecteau, Louie Various wording clarifications 4/13/ Fecteau, Louie FM Legal final approval of language 4/23/ Fecteau, Louie Added CRL URLs, and Request URL 7/10/ Fecteau, Louie Added Vulnerability Assessment Language (5.4.8) 2018 Fannie Mae of 46
3 Table of Contents Fannie Mae Public Key Infrastructure... 1 Certificate Policy (CP)... 1 Version: Publication Date: [TBD]... 1 Change History Introduction Overview Identification PKI Participants Certification Authorities Registration Authorities (RA/SAS) Subscribers Designated Certificate Holders Relying Parties Other Participants Certificate Usage Appropriate Certificate Uses Assurance Levels Basic Assurance Factors in Determining Usage Prohibited Certificate Uses Policy Administration Organization Responsibilities for this Certificate Policy Contact Information Person Determining CPS Suitability for the Policy CP Approval Procedures Definitions and Acronyms List of Definitions List of Acronyms Publication and Repository Responsibilities Repositories Publication of Certification Information Time or Frequency of Publication Access Controls on Repositories Identification and Authentication Naming Fannie Mae of 46
4 Types of Names Need for Names to be Meaningful Anonymity or Pseudonymity of Subscribers Rules for Interpreting Various Name Forms Uniqueness of Names Recognition, Authentication and Role of Trademarks Initial Identity Validation Method to Prove Possession of Private Key Authentication of an Organization Identity Authentication of an Individual Identity Applicants for Basic Assurance Certificates Authentication of Devices Non-verified Subscriber Information Validation of Authority Criteria for Interoperation Identification and Authentication for Rekey Requests Automated Routine Re-Key Manual Re-Key Requests Identification and Authentication for Re-key after Revocation Identification and Authentication for Revocation Requests Certificate Life-Cycle Operational Requirements Certificate Application Who Can Submit a Certificate Application CA Certificates Cross-Certification Certificate Application User Certificates Device Certificates Enrollment Process and Responsibilities Certificate Application Processing Performing Identification and Authentication Functions Approval or Rejection of Certificate Applications Certificate Issuance CA Actions During Certificate Issuance Notification to Subscriber by the CA of Issuance of Certificate Certificate Acceptance Conduct Constituting Certificate Acceptance Publication of the Certificate by the CA Notification of Certificate Issuance by the CA to Other Entities Fannie Mae of 46
5 4.5. Key Pair and Certificate Usage Subscriber Private Key and Certificate Usage Relying Party Public Key and Certificate Usage Certificate Renewal Circumstance for Certificate Renewal Who May Request Renewal Processing Certificate Renewal Requests Notification of New Certificate Issuance to Subscriber Conduct Constituting Acceptance of a Renewal Certificate Publication of the Renewal Certificate by the CA Notification of Certificate Issuance by the CA to Other Entities Certificate Re-Key Circumstance for Certificate Re-key Who May Request Certification of a New Public Key Processing Certificate Re-keying Requests Notification of New Certificate Issuance to Subscriber Conduct Constituting Acceptance of a Re-keyed Certificate Publication of the Re-keyed Certificate by the CA Notification of Certificate Issuance by the CA to Other Entities Certificate Modification Circumstance for Certificate Modification Who May Request Certificate Modification Processing Certificate Modification Requests Notification of New Certificate Issuance to Subscriber Conduct Constituting Acceptance of Modified Certificate Publication of the Modified Certificate by the CA Notification of Certificate Issuance by the CA to Other Entities Certificate Revocation and Suspension Circumstances for Revocation Who Can Request Revocation Procedure for Revocation Request Revocation Request Grace Period Time within which CA Must Process the Revocation Request Revocation Checking Requirement for Relying Parties CRL Issuance Frequency Maximum Latency for CRLs On-line Revocation/Status Checking Availability On-line Revocation Checking Requirements Fannie Mae of 46
6 Other Forms of Revocation Advertisements Available Special Requirements re: Key Compromise Circumstances for Suspension Who Can Request Suspension Procedure for Suspension Request Limits on Suspension Period Certificate Status Services Operational Characteristics Service Availability Optional Features End of Subscription Key Escrow and Recovery Key Escrow and Recovery Policy and Practices Session Key Encapsulation and Recovery Policy and Practices Management, Operational and Physical Controls Physical Security Controls Site Location and Construction Physical Access Electrical Power Water Exposures Fire Prevention and Protection Media Storage Waste Disposal Off-Site Backup Procedural Controls for the CA Trusted Roles Separation of Roles Number of Persons Required Per Task Identification and Authentication for Each Role Roles Requiring Separation of Duties Personnel Controls Background, Qualifications, Experience, and Security Clearance Requirements Background Check Procedures Training Requirements Retraining Frequency and Requirements Job Rotation Frequency and Sequence Sanctions for Unauthorized Actions Contracting Personnel Requirements Fannie Mae of 46
7 Documentation Supplied to Personnel Audit Logging Procedures Event Capture Criteria Frequency of Processing Data Retention Period for Security Audit Data Protection of Security Audit Data Security Audit Data Backup Procedures Security Audit Collection System (Internal vs. External) Notification to Event-Causing Subject Vulnerability Assessments Records Archival Types of Records Archived Retention Period for Archive Protection of Archive Archive Backup Procedures Requirements for Time-Stamping of Records Archive Collection System (Internal or External) Procedures to Obtain and Verify Archive Information Key Changeover Compromise and Disaster Recovery Incident and Compromise Handling Procedures Computing Resources, Software, and/or Data are Corrupted Entity Private Key Compromise Procedures Business Continuity Capabilities after a Disaster CA Termination Technical Security Controls Key Pair Generation Key Pair Generation Subscriber Key Pair Generation Key Delivery to Subscriber CA Public Key Delivery to Relying Parties Key Sizes Public Key Parameters Generation and Quality Checking Key Usage Purposes Private Key Protection Standards for Cryptographic Module Private Key Multi-Person Control Private Key Escrow Fannie Mae of 46
8 Private Key Backup Private Key Archival Private Key Transfer into or from a Cryptographic Module Private Key Storage on Cryptographic Module Method of Activating Private Key Method of Deactivating Private Key Method of Destroying Private Key Cryptographic Module Rating Other Aspects of Key-Pair Management Public Key Archival Usage Periods for the Public and Private Keys Activation Data Activation Data Generation and Installation Activation Data Protection Other Aspects of Activation Data Computer Security Controls Specific Computer Security Technical Requirements Computer Security Rating Life-Cycle Technical Controls System Development Controls Security Management Controls Life Cycle Security Controls Network Security Controls Time-Stamping Certificate, CRL, and OCSP Profiles Certificate Profile Version Numbers Certificate Extensions Algorithm Object Identifiers Name Forms Name Constraints Certificate Policy Object Identifier Usage of Policy Constraints Extension Policy Qualifiers Syntax and Semantics Processing Semantics for the Critical Certificate Policy Extension CRL Profile Version Numbers CRL Entry Extensions Fannie Mae of 46
9 7.3. OCSP Profile Version number(s) OCSP Extensions Compliance Audit and Other Assessment Frequency or Circumstances of Assessment Identity/Qualifications of Assessor Assessor s Relationship to Assessed Entity Topics Covered By Assessment Actions Taken as a Result of Deficiency Communication of Results Other Business and Legal Matters Fees Certificate Issuance or Renewal Fees Certificate Access Fees Revocation or Status Information Access Fees Fees for Other Services Refund Policy Financial Responsibility Insurance Coverage Other Assets Insurance or Warranty Coverage for End-Entities Confidentiality of Business Information Scope of Confidential Information Information not within the Scope of Confidential Information Responsibility to Protect Confidential Information Privacy of Personal Information Privacy Plan Information Treated as Private Information not Deemed Private Responsibility to Protect Private Information Notice and Consent to Use Private Information Disclosure Pursuant to Judicial or Administrative Process Other Information Disclosure Circumstances Intellectual Property Rights Representations and Warranties CA Representations and Warranties RA Representations and Warranties Subscriber Representations and Warranties Fannie Mae of 46
10 Relying Party Representations and Warranties Representations and Warranties of Other Participants Disclaimers of Warranties Limitations of Liability Severability of Provisions, Survival, Merger, and Notice Indemnities Term and Termination Term Termination Effect of Termination and Survival Individual Notices and Communications with Participants Amendments Procedure for Amendment Notification Mechanism and Period Circumstances under Which OID Must be Changed Dispute Resolution Provisions Governing Law Compliance with Applicable Law Miscellaneous Provisions Entire Agreement Assignment Severability Enforcement (Attorneys Fees and Waiver of Rights) Force Majeure Other Provisions Fannie Mae of 46
11 1. Introduction 1.1. Overview This Fannie Mae Public Key Infrastructure (PKI) Certificate Policy (CP) ( Fannie Mae KPI CP, or, CP ) describes the protocols governing the issuance of digital certificates by the Fannie Mae Certification Authority (CA) and their use by Subscribers and Relying Parties. This CP is applicable to all entities that have relationships with the Fannie Mae PKI, including Subscribers, Relying Parties, Registration Authorities (RAs), and Fannie Mae (CA) Vendors. This CP provides those entities with a clear statement of the roles and responsibilities of the Fannie Mae CA and those of each entity dealing with the Fannie Mae CA. This CP consists of policy statements that outline the principles and requirements that govern the Fannie Mae PKI. A CP specifies what requirements will be implemented, while a corresponding Certification Practice Statement (CPS) describes how those requirements are met for a specific CA. This CP is therefore not designed to detail the processes and procedures that are involved in the management and governance of the Fannie Mae PKI; this information is detailed in the Fannie Mae Public Key Infrastructure Certification Practice Statement (Fannie Mae PKI CPS). Pursuant to the IETF RFC 3647 CP/CPS framework, this CP is divided into nine parts that cover the security controls and practices and procedures for the PKI. To preserve the outline specified by RFC 3647, section headings that do not apply have the statement Not applicable or "" This CP is only one of several documents that govern the PKI. Other important documents include the CPS, Registration Authority agreements, Enterprise Service agreements, End Entity Agreements, other customer agreements, privacy policies, and memoranda. Fannie Mae may publish additional certificate policies or certificate practice statements as necessary to describe other product and service offerings. These supplemental policies and statements are available to applicable users or Relying Parties Identification This document shall be known as the Fannie Mae Public Key Infrastructure Certificate Policy (or Fannie Mae PKI CP or this CP ) PKI Participants Certification Authorities The Fannie Mae PKI is comprised of a single Root CA. The Root CA is an on-line CA from which certificates are issued to Fannie Mae users and IT Systems for authentication, devices, and applications, document signing, as well as Fannie Mae business partner(s), and Fannie Mae CA Vendor(s). Where necessary, this CP distinguishes the different users and roles accessing the CA functions. Where this distinction is not required, the term Certification Authority is used to refer to the total CA entity, including the hardware, software, personnel, processes, and its operations. The Fannie Mae Production CA and all associated Intermediate CAs will have the following name: CN = Fannie Mae Root CA O = Fannie Mae C = US 2018 Fannie Mae of 46
12 Registration Authorities (RA/SAS) The Registration Authorities (RAs) collect and verify each Trusted User or End Entity s identity and information to be entered into the End Entity s public key certificate. While the RAs initiate the process to cause the CA to issue Certificates, they do not sign or issue Certificates. The RAs shall perform their functions in accordance with the approved Fannie Mae PKI CPS. The RAs shall be responsible for: Maintaining control over the registration process Maintaining the identification and authentication process The RAs shall only perform the functionality delegated by the CA per the CPS Subscribers A Subscriber is the entity whose name appears as the subject in a certificate, and who is approved by Fannie Mae to hold that certificate Designated Certificate Holders Relying Parties Under the Fannie Mae PKI, a Relying Party is the entity that relies on the validity of the binding connection of the Subscriber's name to a Public Key. The Relying Party shall be responsible for deciding whether or how to check the validity of the Certificate by checking the appropriate Certificate status information. A Relying Party may use information in the Certificate (such as Certificate policy identifiers) to determine the suitability of the Certificate for a particular use Other Participants Participant PKI Policy Authority (PA) Role Fannie Mae will fulfill the PA role. The PA is the custodian of the Fannie Mae PKI CP and CPS and is responsible for PKI policy administration including the approval of policy changes. Support Services Fannie Mae PKI Customer Contract Officer Support Services shall be performed by Fannie Mae Information Security in conjunction with Fannie Mae CA Vendor(s) under their contract with Fannie Mae to support the Fannie Mae PKI. Fannie Mae is responsible for designating a Contract Officer(s) responsible for performing key functions regarding the overall operation of the Fannie Mae PKI. These functions include processing CA application and lifecycle management for any Local Registration Authorities (LRAs), submitting change requests for any modifications to the Certificate contents and submitting change requests for any modifications to the security policies enforced through the Fannie Mae PKI Fannie Mae of 46
13 1.4. Certificate Usage Appropriate Certificate Uses All Certificates issued by the Fannie Mae Enterprise Certificate Service (ECS), through the Fannie Mae CMA, are to be used by IT systems and Subscribers for the sole purpose of conducting business with or for Fannie Mae. All uses of Certificates must be in accordance with this CP Assurance Levels This CP specifies one security requirement: Basic Assurance Certificates issued under this CP are not intended to protect classified information. There is only one level of assurance and it is defined as follows: Assurance Level Basic Acceptable Use This level provides a basic level of assurance relevant to environments where there are risks and consequences of data compromise not considered to be of major significance. This may include access to private or other confidential information where the likelihood of malicious access is not high. It is assumed at this security level that users are not likely to be malicious Basic Assurance At Basic Assurance there is confidence that an asserted identity is accurate Factors in Determining Usage This is pre-determined by Fannie Mae for: Transmission Layer Security User and Device Identity and Authentication Code and Document Digital Signature (Integrity) Virtual Private Network (VPN) Services Data Encryption Prohibited Certificate Uses In general terms, applications for which Fannie Mae PKI issued digital certificates are prohibited are those where: Business activities are conducted, other than for Fannie Mae or Fannie Mae sponsored Business Partners or third parties; Usage contravenes this CP and other governing Fannie Mae policies; or Usage contravenes relevant law Policy Administration Organization Responsibilities for this Certificate Policy Fannie Mae shall be the custodian of this CP and responsible for its maintenance and publication Fannie Mae of 46
14 Contact Information Questions regarding this CP shall be directed to: Fannie Mae Policy Authority (PA) Chief Information Security Officer 3900 Wisconsin Avenue NW, Washington DC Person Determining CPS Suitability for the Policy The Fannie Mae Policy Authority (PA) shall approve the Fannie Mae PKI Certification Practice Statement CP Approval Procedures Fannie Mae Information Security will present this document to Fannie Mae {CISO/CIO?} once per year for review / approval. The PA may propose amendments to this CP, or any part thereof, at any time at his/her discretion. All policy changes under consideration shall be disseminated to interested parties (e.g., Fannie Mae stakeholders). All interested parties shall provide their comments to the originating PA or their delegate, in a fashion to be prescribed by the originating PA. Distribution of potential policy changes to a Relying Party, a Subscriber or an End Entities is not the responsibility of the PA. The PA will make a reasonable effort to ensure that such information about adopted changes is accessible to those communities through normal distribution channels (such as placement on the website mentioned in Section 2.2 below). Fannie Mae CA Vendor(s) shall determine if a CPS sets out, in a satisfactory manner, how the CA will implement the requirements of this CP, and recommend approval when appropriate to the PA originating the proposed change. The PA shall approve the Certification Practice Statement and any amendments thereto. Updates to this CP must be approved by Fannie Mae and implemented, as applicable, by Fannie Mae CA Vendor(s) Definitions and Acronyms List of Definitions Authority Revocation List: A list of revoked Certification Authority cross-certificates and root certificates. Activation Data*: Data values, other than Keys, that are required to operate cryptographic modules and that need to be protected (e.g., a PIN, a passphrase, or a manually-held Key share). CA Certificate: A Certificate for one CA's Public Key issued by another CA. CA Private Signing Key: The Private Key corresponding to a Public Key listed in a CA Certificate and is used to sign Fannie Mae PKI certificates. CA Private Primary Key: The Private Key used to sign CA Certificates. CA Vendor: Service supplier retained by a business to provide technical and support services in connection with a PKI. Certificate: A computer-based record or electronic message that identifies the issuing Certificate Authority, the name or identity of the Subscriber, contains the Public Key of the Subscriber, lists a validity period, is digitally signed by a Certification Authority, and has meaning given in this Certificate Policy and applicable standards. A Certificate includes not only the actual information contained within, but also all documents expressly referenced or incorporated into the Certificate. Certificate Revocation List (CRL): A list of Certificates revoked prior to the expiration of their Validity Periods Certification Authority (CA): An entity that creates, issues, manages and revokes Certificates 2018 Fannie Mae of 46
15 Certificate Policy*: The set of rules that indicates the applicability of a Certificate to a particular community and/or class of application with common security requirements. For example, a particular CP might indicate applicability of a type of Certificate to the authentication of parties engaging in business-to-business transactions for the trading of goods or services within a given price range. Certification Practice Statement (CPS)*: A statement of the practices that a Certification Authority employs in issuing, managing, revoking, and renewing or Re-Keying Certificates. Crypto-module: Either software, a device, or a utility that generates Key Pairs, stores cryptographic information, and/or performs cryptographic functions. Digital Signature, Digitally Sign: The transformation of an electronic record by one person using a Private Key and Public Key Cryptography so that another person having the transformed record and the corresponding Public Key can accurately determine whether the transformation was created using the Private Key that corresponds to the Public Key and whether the record has been altered since the transformation was made. Distinguished Name (DN): The unique identifier for a Subscriber so that s/he can be located in a directory based on the ITU/CCITT X.500 (e.g. the DN for a Subscriber might contain the following attributes: common name (cn), address (mail), Organization name (o), Organizational unit (ou), locality (l), state (st) and country (c)). End Entity: A Subscriber and/or authorized Relying Party. Enterprise Service Agreement: An agreement between a business (namely Fannie Mae under this CP) and a Vendor or Supplier (namely a Fannie Mae CA Vendor under this CP) retained by a business to provide support services in connection with a CA PKI. Enterprise Service Agreement includes related Service Orders and Service Requests approved by the CA Vendor. Fannie Mae CA Vendor: CA Vendor retained by Fannie Mae in support of the Fannie Mae PKI. Fannie Mae PKI Certificate: A Certificate issued pursuant to this CP. Issue Certificates, Issuance: The act performed by a CA in creating a Certificate listing with the CA as Issuer, and notifying the Applicant of the contents and that the Certificate is ready and available for Acceptance. Issuing Certification Authority (Issuing CA)*: In the context of a particular Certificate, the issuing CA is the CA that issued the Certificate (see also Subject Certification Authority). Key Generation: The process of creating a Key Pair. Key Pair: Two mathematically related Keys (a Private Key and the corresponding Public Key), with the following properties: one Key of the key pair can encrypt a communication only capable of decryption by the other Key; and deriving or discovering one Key from the other Key is computationally infeasible, assuming likely circumstances including the availability of text encrypted by either of the Keys. Lightweight Directory Access Protocol (LDAP): A client-server protocol used for accessing X500 directory services over a computer network. No Stipulation: No condition or requirement that is specified or demanded as part of a subject area. Object Identifier (OID): The unique alphanumeric/numeric identifier registered under the ISO registration standard to reference a specific object or object class. In the PKS established by this CP, they are used to uniquely identify Certificates issued under this CP and the cryptographic algorithms supported. Online Certificate Status Protocol (OCSP): A protocol that is used to provide real-time validation of a Certificate s status. An OCSP responder is used to respond to Certificate status requests and can issue one of 2018 Fannie Mae of 46
16 three responses: Valid, Invalid, and Unknown. An OCSP responder replies to Certificate status requests on the basis of CRLs (Certificate Revocation Lists) provided to it by certification authorities. Operational Period: A Certificate s actual term of validity, beginning with the start of the Validity Period and ending with the earlier of: The end of the Validity Period disclosed in the Certificate, or The revocation date of the Certificate. PKI Sponsor: Formal business leader of an organization that requests, receives, and maintains certificates for IT use within their area of responsibility. Private Key: The sensitive Key in the Key Pair protected by the Subscriber and kept secret. The Private Key creates Digital Signatures or decrypts data previously encrypted using the corresponding Public Key. Public Key: The non-sensitive Key in the Key Pair disclosed by the Subscriber holding the corresponding Private Key. The Public Key verifies Digital Signatures created using the corresponding Private Key, or encrypts data meant for decryption with the corresponding Private Key. Public Key Cryptography: A type of cryptography also knows as asymmetric cryptography. This cryptography uses a Key Pair rather than a single Key to secure the authentication and/or confidentiality of data. Public Key Infrastructure (PKI): The architecture, technology, practices, and procedures that support operation of a security system employing Certificates and Public Key Cryptography. Public Key Service (PKS): This is identical with Public Key Infrastructure, with the word Service used to emphasis on leveraging the environment to service Fannie Mae customers. Registration Authority (RA): An individual or organization responsible for verifying the identity of a Subscriber or, in the case of another Business Unit, a Designated Certificate Holder. Registration System. People, process and technology used in the validation of requests for certificates. Relying Party*: A recipient of a Certificate who acts in reliance on that Certificate and/or any digital signatures verified using that Certificate. Repository: An online system maintained by an Issuing CA for storing and retrieving Certificates and other information relevant to Certificates, including information relating to Certificate validity or revocation. Revoke (a Certificate): To invalidate a Certificate permanently from a specific time onward. Revocation includes listing the Certificate in a set of revoked Certificates or other directory or database of revoked Certificates (e.g. inclusion in a CRL). The system also prevents users from accessing revoked Certificates once connected to the central infrastructure. Request For Comments (RFC): Document series used as the primary means for communicating information about the Internet. Some RFCs are designated by Internet Architecture Board as Internet standards. Secure Personal Security Environment (SPSE): A secure storage area containing information such as Private Keys and related Certificates. The storage area is encrypted and protected using cryptography. The form of storage may vary from files to tamper-resistant cryptographic tokens Signing Key Pair: Is a Private Key and a Public Key used for creating and validating a Digital Signature. Subject Certification Authority: In the context of a particular CA-Certificate, the subject CA is the CA whose Public Key is certified in the Certificate (see also Issuing certification authority) Fannie Mae of 46
17 Subject Name: The specific field in a Certificate containing the Distinguished Name (DN) for the Subscriber. Subscriber: A subject of a Certificate who is issued a Certificate. End Entity Agreement: An agreement between a CA (namely Fannie Mae under this CP) and a Subscriber or a Relying Party that establishes the right and responsibilities of the parties regarding the issuance and management of Certificates. For purposes of this CP, the end Entity Agreement shall consist of (i) the Software Subscription Agreement governing Subscriber s or the Relying Party s use of Fannie Mae Licensed Applications (as defined in the Software Subscription Agreement) in support of the transactions and operationally implementing the PKI set forth in this CP, and (ii) this CP. Token: A Crypto-module consisting of a hardware object (e.g., a smart card ), often with memory and a microchip. Trusted Role: A role whose execution requires adherence to a policy and procedures to prevent the introduction of security problems. The functions of Trusted Roles form the basis of trust for the entire PKS. Validity Period: The intended term of validity of a Certificate, beginning with the date of Issuance ( Valid From or Activation date), and ending with the earlier of two dates: the expiration date indicated in the Certificate ( Valid To or Expiry date) or the revocation date asserted in the revocation list specified as the CRL Distribution Point within the certificate. x.500: A series of computer networking standards covering electronic directory services. These services include Directory Access Protocol (DAP), Directory System Protocol (DSP), Directory Information Shadowing Protocol (DISP), and Directory Operational Bindings Management Protocol (DOP). x.509: An International Telecommunication Union Telecommunication Standardization Sector (ITU-T) standard for Public Key Infrastructure which specifies standard formats for public key certificates and certification path validation. *As defined in the standard for Certificate Policies (RFC 3647) CA CP CPS CRL DN ECS FIPS LDAP LRA OID PA PKI PKS List of Acronyms Certification Authority Certificate Policy Certification Practice Statement Certificate Revocation List Distinguished Name Enterprise Certificate Service Federal Information Processing Standard Lightweight Directory Application Protocol Local Registration Authority Object Identifier Policy Authority Public Key Infrastructure, also known as PKS Public Key Services, also known as PKI 2018 Fannie Mae of 46
18 RA RDN RFC TA URL US Registration Authority Relative Distinguished Name Request for Comment Trusted Agent Uniform Resource Locator United States 2. Publication and Repository Responsibilities 2.1. Repositories Fannie Mae CA shall publish both CA data (CA Certificate, CRLs, and policies) and subscriber certificates to the Fannie Mae CRLs. Where used, the term Repository shall refer to this directory, including all required components for certificate and CRL publication. Relying Parties shall be able to access Fannie Mae CA CRLs published on the Repository. These CRLs shall be available 24x7 under normal conditions. FM CRL URL: Symantec CRL URL Publication of Certification Information This Fannie Mae PKI CP is published at the website specified in the Fannie Mae PKI CPS. Business Partners and relying third parties are entitled to obtain a copy of the Fannie Mae PKI CP by visiting the specified website or by contacting their Fannie Mae Business Partner point of contact and requesting a copy. By default, the Fannie Mae CPS will not be distributed to external entities. Exceptions will require approval from the Fannie Mae PA. Distribution of the Fannie Mae PKI CPS to Fannie Mae employees shall be limited to employees that have a business need and shall be distributed in a manner that requires the identification and authentication of the Fannie Mae employee Time or Frequency of Publication This Fannie Mae PKI CP and any subsequent changes thereto shall be made publicly available within 30 days of approval. Publication requirements for CRLs are provided in Sections of this Fannie Mae PKI CP Access Controls on Repositories The CA shall protect information not intended for public dissemination or modification. CA certificates and CRLs site information shall be available through the Fannie Mae ECS site. The CPS documents shall detail what information in the Fannie Mae ECS site is to be exempt from automatic availability and to whom, and under what conditions, the restricted information may be made available. 3. Identification and Authentication 3.1. Naming Types of Names All CAs operating under this policy shall generate, sign, and process certificates that contain an X.501 Distinguished Name (DN) that clearly and distinguishingly identifies the issuer and the subject of the certificate Fannie Mae of 46
19 Need for Names to be Meaningful The identity certificates issued pursuant to this CP are meaningful only if the names that appear in the certificates can be understood and used by Relying Parties. Names used in the certificates must identify the person or object to which they are assigned in a meaningful way. When DNs are used, it is preferable that the common name represents the Subscriber in a way that is easily understandable for humans. For people, this will typically be a legal name. For equipment, this may be a model name and serial number, or an application process (e.g., Organization X Gateway or Organization Y Certificate Authority) Anonymity or Pseudonymity of Subscribers The Fannie Mae PKI does not support the use of pseudonyms in subscriber common names Rules for Interpreting Various Name Forms Name forms shall comply with RFC 2822 and X.500 standards for name forms Uniqueness of Names Name uniqueness across the PKI shall be enforced. The directory will be managed in such a way as to ensure that no two individuals are assigned the same DN and, therefore, the same electronic identity. The CA shall document in its CPS: What name forms shall be used How the CAs and RAs will allocate names within the Subscriber community to guarantee name uniqueness among current and past Subscribers Recognition, Authentication and Role of Trademarks Where permitted or required, the use of a trademark is reserved to the holder of that trademark Initial Identity Validation Certificate applicants must communicate application requests for certificates to an authorized Fannie Mae Registration Authority (RA) via a trustworthy process. Authority hardware and software may communicate authorizations to issue Certificates directly to the supporting CA electronically, provided all communication is secure Method to Prove Possession of Private Key The Fannie Mae Certificate Management Authority (Fannie Mae CMA) must obtain acknowledgment of receipt from the Subscriber of shipment or must revoke any Certificates issued to that Subscriber. When the Fannie Mae CMA delivers keys to Subscribers, they must accomplish delivery in a way that ensures that they provide the correct activation data to the correct people. The Fannie Mae CMA shall maintain a Subscriber receipt validation record. When any mechanism that includes a shared secret (e.g., a password or PIN) is used, the mechanism shall ensure that the applicant and the Fannie Mae CMA are the only recipients of this shared secret. In cases where the Subscriber causes the system to generate keys (e.g., remote emergency renewal), the Subscriber is required to prove possession of the Private Key that corresponds to the Public Key in the Certificate request to the Fannie Mae CMA Authentication of an Organization Identity A Fannie Mae CA may issue Certificates directly in the name of an organization rather than an individual for those functions and applications performed on behalf of the organization. The Fannie Mae CMA must authenticate the identity of any organization that appears as a component of a subject name appearing in a Certificate issued by the CA before processing the Certificate application. Any organization requesting a Certificate must have a PKI Sponsor to accept the 2018 Fannie Mae of 46
20 obligations of the organization. This section pertains only to the authentication and naming of an organization as the subject in a Certificate. Requests for Certificates in the name of an organization or group shall include the necessary identifying data of the PKI Sponsor, the group or organization name, address, and documentation of the existence of the organization. This information will include but is not limited to the following: Organization identification and authorization Contact information to enable the Fannie Mae CMA to communicate with the PKI Sponsor as required The Fannie Mae CMA shall verify this information, in addition to the authenticity and authorization of the requesting PKI Sponsor, authenticate the validity of any authorizations to be asserted in the Certificate, and verify the source and integrity of the data collected to an assurance level commensurate with the Certificate assurance level requested. The CPS will specify acceptable measures for authenticating both the organization and PKI Sponsor s identity and authorizations. The Fannie Mae CMA shall also include his or her own identity information and authentication declaration as outlined in Section The PKI Sponsor shall present information sufficient for registration at the level of assurance requested, for both himself or herself and the non-human Entity (i.e., organization or group) requesting a Certificate, and shall authenticate this information in person as prescribed in Section Authentication of an Individual Identity Personnel filling Fannie Mae trusted roles shall be authenticated according to the stipulations for a Basic Assurance certificate. All Individual Identity certificates shall only be issued to human Subscribers Applicants for Basic Assurance Certificates Applicants requesting a Basic Assurance Certificate must be validated and approved by Fannie Mae CMA before Certificates can be issued Authentication of Devices Some computing and communications devices (routers, firewalls, servers, etc.) and software applications will be named as Certificate subjects. In such cases, the device must have a human sponsor. These Certificates shall be issued only to devices under the issuing entity s control (i.e., require registration and validation that meets Fannie Mae requirements, as well as requiring re-validation prior to being re-issued). In the case a human sponsor is changed, the new sponsor shall review the status of each device under his/her sponsorship to ensure it is still authorized to receive Certificates. The CPS shall describe procedures to ensure that Certificate accountability is maintained. The sponsor is responsible for providing the following registration information: Equipment identification (e.g., serial number) or service name (e.g., DNS name) or unique software application name Equipment or software application public keys Equipment or software application authorizations and attributes (if any are to be included in the certificate) Contact information to enable the Fannie Mae CA or RA to communicate with the sponsor when required The registration information shall be verified to an assurance level commensurate with the certificate assurance level being requested Fannie Mae of 46
21 Non-verified Subscriber Information Information that is not verified shall not be included in Certificates Validation of Authority Whenever a Fannie Mae employee, partner, or customer submits a Certificate application, Fannie Mae shall be responsible for performing a verification of authority to ensure that the individual is authorized to obtain a Certificate Criteria for Interoperation 3.3. Identification and Authentication for Rekey Requests Re-keying a Certificate means that the Fannie Mae CMA creates a new Certificate that has the same characteristics and level as the old one, except that the new Certificate has a new, different Public Key (corresponding to a new, different Private Key) and a different serial number and possibly different validity period. Subscribers must periodically obtain new keys and re-establish identity as defined in Section 3.2. The Fannie Mae PKI CA may re-key Subscribers based on electronically authenticated Subscriber requests. Subscribers must stop using Private Keys before the Public Key expires. Confidential Private Keys do not have a lifetime so Subscribers may use these keys at any time to decrypt information. For device certificates, identity may be established through the use of the device s current signature key or the signature key of the device s human sponsor, except that identity shall be established through the initial registration process at least once every nine years from the time of initial registration Automated Routine Re-Key Re-keying a Certificate means that the Fannie Mae CMA creates a new Certificate that has the same characteristics and level as the old one, except that the new Certificate has a new, different Public Key (corresponding to a new, different Private Key) and a different serial number and possibly different validity period. Subscribers must periodically obtain new keys and re-establish identity as defined in Section 3.2. The Fannie Mae PKI CA may re-key Subscribers based on electronically authenticated Subscriber requests. Subscribers must stop using private keys before the public key expires. Private Signing Keys do not have a lifetime so Subscribers may use these keys at any time to validate identity information. As of the date of this Fannie Mae PKI CP, no Subscribers will be issued individual keys for data encryption. For device Certificates, identity may be established through the use of the device s current signature key or the signature key of the device s human sponsor, except that identity shall be established through the initial registration process at least once every three years from the time of initial registration. Fannie Mae Certificates are issues at a Basic Assurance level, where such keys have a maximum lifetime of three years. If Fannie Mae implements the capability of associating authorizations with a Certificate, including any conveyed or implied by the subject s Distinguished Name (DN), the Subscriber and/or the Subscriber s organization shall notify the appropriate CAs of the withdrawal of authorization. The CPS shall document the mechanisms used to notify the appropriate CAs of this action. In such instances, withdrawal of authorization may result in revocation of the old Certificate and, if necessary, the issuance of a new Certificate with a different Public Key and the appropriate associated authorizations Fannie Mae of 46
22 Manual Re-Key Requests Identification and Authentication for Re-key after Revocation For all levels of assurance, Subscribers requesting Certificates after revocation, other than during a renewal or update action, must meet initial identity authentication and registration requirements, as indicated in Section 3.2 to obtain a new Certificate Identification and Authentication for Revocation Requests Requests for Certificate revocation will be submitted and reviewed through Fannie Mae s approved process. The Fannie Mae CMA may authenticate requests to revoke a Certificate using signatures generated with that Certificate s associated Private Key, regardless of whether or not the Private Key has been compromised. 4. Certificate Life-Cycle Operational Requirements 4.1. Certificate Application Subscribers shall be limited to those individuals filling Trusted Roles within the PKI and the employees, contractors, business partners and affiliates of Fannie Mae. Application for Certificates issued under this CP must be submitted by Fannie Mae or Fannie Mae contracted staff. The Fannie Mae CA operating under this CP shall establish and document the Certificate application and enrollment process in its CPS Who Can Submit a Certificate Application CA Certificates The Fannie Mae CA will not issue Certificates to any CA external to the Fannie Mae environment Cross-Certification Certificate Application Within Fannie Mae, only the Fannie Mae Chief Information Security Officer shall apply for cross certification with any external PKI/CA. Only the Fannie Mae CA shall cross certify with external CAs. A Certification Practices Statement, written to the format of the Internet X.509 Public Key Infrastructure Certificate Policy and Certification Practices Framework (RFC 3647) shall accompany all such requests. Entities applying for cross certification are responsible for providing accurate information on their certificate applications. The Fannie Mae CMA shall authenticate, and protect from modification, communications among PKI authorities supporting the Certificate application and issuance process User Certificates Authorized Fannie Mae employees as well as Fannie Mae managed service providers and contractors approved by Fannie Mae are permitted to apply for a Subscriber Certificate. Personnel that are approved by Fannie Mae to serve in a Fannie Mae PKI Trusted Role, are permitted to apply for a Trusted User Certificate (Security Officer, etc.) Fannie Mae of 46
23 Device Certificates An application for a device Certificate shall be submitted by the sponsor of the device as outline in section Enrollment Process and Responsibilities Subscriber enrollment will be processed using the Self-Administration Service (SAS). Creation of Trusted Roles will be processed via the Registration Authority (RA). The Fannie Mae CMA shall verify the accuracy of Certificate application information, using procedures as specified in the applicable CPS, before issuing Certificates Certificate Application Processing The following steps are required when processing a Certificate application from a potential Subscriber: Establish authorization to receive a Certificate Establish and record identity of the Subscriber Provide a point of contact for verification of any roles or authorizations requested These steps may be performed in any order that is convenient for the RA and applicants, as long as it does not defeat security controls, and all steps must be completed before Certificate issuance Performing Identification and Authentication Functions The applicant and the Fannie Mae CMA must perform the steps outlined in the applicable CPS when an applicant applies for a Certificate. The Fannie Mae CMA and Subscribers may perform these steps in any order that is convenient and that does not defeat security controls; however, they must complete all steps before Certificate issuance. The Fannie Mae CMA shall authenticate and protect from modification all communications supporting the Certificate application and issuance process using mechanisms commensurate with the protection requirements of the data to be encrypted. The Fannie Mae CMA shall protect from unauthorized disclosure, any electronic transmission of this data (i.e., encryption) commensurate with the protection requirements of the data Approval or Rejection of Certificate Applications The approval or rejection of Certificate applications shall be at the discretion of Fannie Mae. The Time to Process Certificate Applications. Certificate applications are processed in accordance with the Fannie Mae on boarding processes Certificate Issuance Subscribers will utilize the Self-Administration Server (SAS) to authenticate using their Fannie Mae ID, Fannie Mae ID password, and validation questions and answers. Upon receipt of a valid request, the Fannie Mae CA issues the Certificate in the form of key pairs (encryption and/or verification) for that Subscriber s Certificate, which can be manually recovered in case of corruption or reimaged workstation via the FM ECS Key Recovery Process. MyServices link Search for SSL Cert for Web or App Server Upon manual recovery, only the verification Private Key is updated with new lifetime. Encryption Certificates will only be updated upon expiration and creation of a new Certificate. The Fannie Mae CA binds the identity information in the Certificate application with the Subscribers keys during the Certificate issuance process Fannie Mae of 46
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