xobs,
What was your experience working with the CPU vendors to open up the ROM or atleast provide a method to by pass the ROM and use an external ROM?
Given that it's a ROM and not reprogrammable, and not used after it transfers control to the user bootloader, I think it's fair to treat it more as part of the silicon than as a piece of software. It might be worth auditing for bugs in the boot assurance crypto though.
(If the hardware is malicious, it would be far simpler and less detectable to do it as a silent peripheral, possibly even a whole other processor, than in the boot ROM)