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NEWBROOK INVESTMENT ENTERPRISES LLC

SIMPLY MANAGED SOLUTIONS

Annual 47 C.F.R. § 64.2009(e) CPNI Certification


EB Docket 06-36

Accompanying Statement Explaining CPNI Procedures

What is Customer Proprietary Network Information?

CPNI is defined by the Telecommunications Act as the information that relates to the quantity, technical
configuration, type, destination, and amount of use of a telecommunications service subscribed to by any
customer of a telecommunications carrier, that is made available to the carrier by the customer solely by virtue
of the customer-carrier relationship, and is contained in the bills pertaining to telephone exchange service or
telephone toll service received by a customer of a carrier. CPNI does not include subscriber list information

What is the Company’s Policy Regarding CPNI?

Simply Managed Solutions (the Company) has established operating procedures that ensure
compliance with the Federal Communication Commission’s (the Commission) rules and regulations
regarding the protection of CPNI as stated in 47 C.F.R. Ch. 1 § 64.2005.

Under rules established by these operating procedures:

 The Company educates and trains its employees, including its sales agents, regarding the
appropriate use of CPNI.
 The Company disciplines employees who violate the CPNI procedures established by the
Company.
 The Company does not allow for the release of CPNI to any third-party agency nor does it
allow any third-party agency access to CPNI except as specifically stated below.
 The company requires management approval prior to the use of CPNI in any marketing
campaign, and the Company maintains a record of the sales and marketing campaigns that
use a customer’s CPNI.
 The Company will disclose CPNI to the customer or to any person designated by the customer
only upon an affirmative written request from the customer and then only in writing.
 The Company will provide a customer’s phone records or other CPNI to a law enforcement
agency in accordance with applicable legal requirements.
 The Company maintains strict security over the files in which any stored password is
maintained and ensures that only authorized employees have access to these secure files.

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