Section 3.0 sentence 2 and 3 should be moved to the end of the section where one talks about usage in the context of S/MIME.
Or, a better separation of the definition of this attribut and its usage in an S/MIME context should be made.
I am not sure whether I support not including BCCs. This should go into a security consideration section. The problem is similar of what happens in standard bcc: processing. It is up to the sending system to create separate messages which may for example include one bcc: header for each of the recipients.. similar for S/MIME envelopes for BCCs, ...
Anyway, a possible and cost intensive solution is to have separate copies with bccs, signed individually, etc. why should one exclude this.