Capital Communications Consultants, Inc.

Statement Concerning Procedures Ensuring Compliance with CPNI Rules

Capital Communications Consultants, Inc. (the "Company") has established the following system to protect the

confidentiality of Customer Proprietary Network Information (CPNI) and to assure compliancer with the requirements
of the Federal Communications Commission's order, 47 C.F.R. 64.2001 Information protected by the Company includes all information defined as CPNI at Section 22:2(h) (l) of the Communications Act of 1934, as amended, 47 U.S.C. 222(h) (l) including information that relates to the quantity, technical configuration, type, destination, location, and amount of use of a telecommunications service subscribed to by a customer and made available to the Company by the customer solely by virtue of the carrier-customer relationship. Also protected is information contained in the bills pertaining to telephone exchange service or telephone toll service received by a customer. The Company may use, disclose, or permit access to CPNI without customer approval in the following instances:

1. To initiate, render, bill and collect for telecommunications services; 2. The provision of inside wiring installation, maintenance, and repair services; 3. The provision of CPE and call answering, voicemail or messaging, voice storage and retrieval services, fax
store and fonruard, and protocol conversion;

4.
5.

To market services formerly known as adjunct-to-basic services, such as, but not linnited to, speed dialing, computer-provided directory assistance, call monitoring, call tracing, call blocking, call return, repeat dialing, call tracking, call waiting, caller l.D call fonivarding and certain centrex features; and To protect the rights or property of the Company, or to protect users of those services and other carriers from fraudulent, abusive, or unlawful use of, or subscription to, such services.

The Company does not use or disclose CPNI in any manner requiring customer approval, inoluding, but not limited to the use of CPNI for marketing or the provision of CPNI to a third party except as indicated above, The Company

doesn't allow third party use of CPNI, except in cases where required by law. The Company does not use, disclose, or permit access to CPNI to identify or track customers who contact competing local service providers. When The Company receives or obtains proprietary information from another carrier for purposes of providing a telecommunications service, it shall use such information only for such purpose, and shall not use such information for itr; own marketing efforts,
The Company does not provide Call Detail lnformation (CDl) to inbound callers. CDI includers any information that pertains to the transmission of specific telephone calls, including, for outbound calls, the number called, and the time, location, or duration of any call and, for inbound calls, the number from which the call was placed, and the time, location, or duration of any call. The Company many instead provide CDI to a Customer at their request by sending to their address of record that has been on file with The Company for at least 30 days, or by calling back the Customer at their telephone number of record. Online accounts are protected by sending a randomly generated password to the email address of record at the time the account is created. The password is not expected to consist of any readily available biographical information or account information, nor will it consist of raasily guessed units,

such as consecutive or repeated numbers or letters.

Although The Company does not have offices that provide in-person customer service, if suc'h an occurrence should arise the customer will be required to provide a valid photo lD matching the customer's account information. Customers receive immediate notification whenever a password, online account or address, phone number or email
address of record is created or amended. This notification may be carried out by carrier originated voicemail to the

telephone number of record, or through the mail by address of record. The notification does not include any account information, including the changed information.
The Company will notify the appropriate government entities of any breach of CPNI protocol, Customers are notified upon completion of law enforcement procedures. The Company maintains records of any breaches and the resulting notifications to government entities and customers for a minimum of two years. Records include, if applicable, date of discovery and notification, detailed description of the CPNI that was the subject of the breach, and the

circumstance of the breach.

The Company maintains records of all customer complaints related to their handling of CPNI. The records are maintained for a minimum of two years,

All Company employees have sufficient training as to when they are authorized to release or use CPNI. Employees understand, further, that any violation of these rules will result in disciplinary action which could include dismissal and possible criminal prosecution.
The Company does not utilize CPNI for marketing purposes; however, to assure compliance, sales personnel must

get supervisory approval in outbound marketing situations. The Company maintains records; of sales and marketing campaigns for a minimum of one year. Records include a description of each campaign, and what products or
services were offered as a paft of the campaign.

The Company will have an authorized corporate officer of The Company, as an agent of such company; sign a compliance certificate on an annual basis stating that the officer has personal knowledge thart The Company has established operating procedures that are adequate to ensure its compliance with FCC's CPNI rules. The certificate for each year will be filed with the FCC Enforcement Bureau in EB Docket No. 06-36 by Man:h 1 of the subsequent year, and will be accompanied by a summary or copy of this policy that explains how operating procedures ensure that The Company is in compliance with the FCC's CPNI rules. In addition, the filing must include an explanation of any actions taken against data brokers and a summary of all customer complaints received in the past year concerning the unauthorized release of CPNI, Confidential portions of these submissions shall be redacted from the public version of the filing and provided only to the FCC.