> The hardware used for each of the issuers is in the attached file. These HSMs are FIPS 140-2 Level 3 compliant.
A FIPS HSM does not forbid one to import keys into it.
The Root CA must sign requests after authentication, but a "manual" approval is also accepted if done with the appropriate oversight with witnesses (clearly not the case here).
You trust the magic black box far more than I do.
My big fear about HSM is that they are inscrutable by design. There is no way to verify they are working as advertised. Plus side, all sorts of fancy hardware to protect your keys. Down side, all sorts of fancy hardware that obscures flaws in the implementation.
They had one job, and they blew it. The system is based on trust and they've lost it.
I'm going to remove their roots from all my stuff in any case.