2) According to this tutorial: https://gbatemp.net/threads/tutorial-converting-3ds-to-cia-for-dummies.373722/
This file you have to make must contains 7.X Nintendo keys leaked by GovanifY.
I told you infact CIA = piracy cause you use LEAKED Nintendo keys (so copyrighted content) but probably you cannot understand what someone is trying to tell you.
Not that I don't understand you, I just don't think you're correct.