STATEMENT OF FCC CPNI RULE COMPLIANCE This statement serves to explain how ComSouth Teleservices, Inc.

(the Company), FCC Form 4 Filer I! "#$$$%, is complyin& with Fe'eral Communications Commission (FCC) rules relate' to the privacy o( customer in(ormation. The type o( in(ormation (or which customer privacy is protecte' )y the FCC*s rules is calle' customer proprietary networ+ in(ormation (C,-I). The FCC*s rules restrictin& telecommunications company use o( C,-I are containe' at ,art .4, Su)part / o( the FCC*s rules (40 C.F.1. 2 .4.%###3%#$$). 1. Duty to Protect CPNI

4e reco&ni5e our 'uty to protect customer C,-I. 4e may not 'isclose C,-I to unauthori5e' persons, nor may we use C,-I in certain ways without consent (rom our customers. 6e(ore we can provi'e customers with their own C,-I, we must authenticate the customer. 4e reco&ni5e that there are a (ew cases in which we can 'isclose C,-I without (irst o)tainin& customer approval7 $) 8'ministrative use7 4e may use C,-I to initiate, ren'er, )ill an' collect (or communications services. %) ,rotection o( carrier an' thir' parties7 4e may use C,-I to protect the interests o( our company, such as to prevent (rau' or ille&al use o( our systems an' networ+. 9mployees are noti(ie' o( the steps to ta+e, i( any, in these sorts o( situations. :) 8s re;uire' )y law7 4e may 'isclose C,-I i( we are re;uire' to )y law, such as throu&h le&al process (su)poenas) or in response to re;uests )y law en(orcement. 9mployees are noti(ie' o( any steps they must ta+e in these situations. 2. Our Use of CPNI in Mar etin!

The Company 'oes not use C,-I (or mar+etin& purposes except in the (ollowin& circumstances7 $) to mar+et services to our existin& customers within the cate&ories o( service to which the customer alrea'y su)scri)es< %) to mar+et a'=unct3to3)asic services< an' :) to provi'e C,9 an' call answerin&, voice mail or messa&in&, voice stora&e an' retrieval services, (ax store an' (orwar', an' protocol conversion. For mar+etin& purposes (or which use o( C,-I woul' otherwise re;uire permission (rom the Customers, the Company uses only Customer )illin& name an' a''ress an'>or telephone num)er without any se&re&ation or re(inement )ase' on C,-I. ?n in)oun' an' a'ministrative calls, however, the Company may utili5e C,-I in its sales $

an' mar+etin& e((orts )y (irst re;uestin& permission to 'o so pursuant to 2.4.%##"((). In those cases, the Company reco&ni5es that permission to use C,-I en's when the call terminates an' the Customer is (ully in(orme' that he may re(use the permission. 4e re&ularly review our mar+etin& practices to 'etermine when, how an' i( C,-I is use' within the Company to insure that we remain in compliance with the FCC*s C,-I re&ulations an' with our policy as 'escri)e' here in. In the unli+ely event that Company 'eci'es to mo'i(y its policies (or use o( C,-I, it will insure that its new policy (ully complies with FCC C,-I rules inclu'in&, )ut not limite' to, trac+in& an' Customer notice provisions containe' in 2.4.%##"3%## . ". Aut#entication Prior to Disc$osure of CPNI

4e un'erstan' that we are re;uire' to 'etermine that any re;uest (or C,-I will not )e release' without authenticatin& the authority o( the re;uestor to receive such in(ormation. 4e un'erstan' that when a customer calls, we may not release C,-I until we have authenticate' the release o( the in(ormation to the re;uestor in one o( the (ollowin& ways7 $) 6y callin& the customer )ac+ at the telephone num)er associate' with the communications service< %) 6y mailin& the in(ormation to the a''ress o( recor'< :) 6y releasin& it in person (ollowin& authentication via a vali' &overnment3 issue' photo i'enti(ication at our o((ice< 4) For those customers who have chosen to 'o so, over the phone (ollowin& the 'isclosure o( a passwor'. %. E&'$oyee Issues

8ll o( our employees were traine' re&ar'in& the company*s C,-I policies prior to the e((ective 'ate o( the most recent C,-I re&ulations, !ecem)er ", %##0. To maintain compliance with FCC rules a(ter !ecem)er ", %##0, the Company esta)lishe' proce'ures an' traine' employees havin& access to, or occasion to use customer 'ata, to i'enti(y what customer in(ormation is C,-I consistent with the 'e(inition o( C,-I un'er the FCC*s revise' C,-I rules. The Company has implemente' a trainin& proce'ure (or all new hires an' contractors re&ar'in& the Company*s practices re&ar'in& C,-I. In a''ition, the Company has in place an express 'isciplinary process to a''ress any unauthori5e' use o( C,-I where the circumstances in'icate authori5ation is re;uire' un'er the FCC*s C,-I rules.

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Notifications to Custo&ers

4e provi'e a C,-I privacy policy to all customers annually. This policy inclu'es our 'uty to protect their C,-I an' a statement that we 'o not 'isclose C,-I to any thir' parties or use C,-I without their express permission to 'o so. 4e also in(orm them o( our re;uirements (or authenticatin& them prior to 'isclosin& C,-I to them in any way. 4e noti(y customers when chan&es have )een ma'e to passwor's, customer responses to )ac+3up means o( authentication (i( implemente'), a''resses o( recor' an' authori5e' users )y mailin& a noti(ication to the account a''ress o( recor'. The notice 'oes not contain in(ormation re&ar'in& the chan&es. ). Recor*+,ee'in! 4e maintain the (ollowin& recor's in our (iles (or at least two years7 $) 1ecor's relatin& to the annual mailin& o( the customer C,-I privacy policy< %) 9mployee 'isciplinary recor's, i( applica)le< an' :) I( applica)le7 i) recor's o( 'iscovere' C,-I )reaches< ii) noti(ications to law en(orcement re&ar'in& )reaches< an' iii) any responses (rom law en(orcement re&ar'in& those )reaches. -. Unaut#ori.e* Disc$osure Of CPNI

4e un'erstan' that we must report C,-I )reaches to law en(orcement no later than seven (0) )usiness 'ays a(ter 'eterminin& the )reach has occurre', )y sen'in& electronic noti(ication throu&h the lin+ at http7>>www.(cc.&ov>e)>C,-I> to the central reportin& (acility, which will then noti(y the /nite' States Secret Service (/SSS) an' the Fe'eral 6ureau o( Investi&ation (F6I). 4e un'erstan' that we may not noti(y customers or the pu)lic o( the )reach earlier than seven (0) 'ays a(ter we have noti(ie' law en(orcement throu&h the central reportin& (acility. I( we wish to noti(y customers or the pu)lic imme'iately, where we (eel that there is an extraor'inarily ur&ent nee' to noti(y to avoi' imme'iate an' irrepara)le harm, we in(orm law en(orcement o( our 'esire to noti(y an' comply with law en(orcement*s 'irections. !urin& the course o( the year, we compile in(ormation re&ar'in& pretexter attempts to &ain improper access to C,-I, inclu'in& any )reaches or attempte' )reaches. 4e inclu'e this in(ormation in our annual C,-I compliance certi(ication (ile' with the FCC.