Statement of CPNI Procedures and Compliance

Use of CPNI BVU Authority (BVUA) does not use or permit access to CPNI to market any ser ices outside of t!e total ser ice approac! as specified in "# C$% &'"()**+( If BVUA elects to use CPNI in a manner t!at does re,uire customer appro al- it .ill follo. t!e applica/le rules set fort! in "# C$% Su/part U- includin0 t!e institution of operational procedures to ensure t!at notification is pro ided and customer appro al is o/tained /efore CPNI is used or disclosed( PROTECTION OF CPNI BVUA !as put into place processes to safe0uard its customers1 CPNI2call detail information from improper use or disclosure /y employees3 and to disco er and protect a0ainst attempts /y t!ird parties to 0ain unaut!ori4ed access to customer CPNI( BVUA !as a CPNI manual t!at co ers disciplinary action and as part of t!e CPNI procedures employees si0n a document t!at ackno.led0es potential disciplinary action( $or e5ample an e5cerpt states6 Violation by Company employees and agents of such CPNI requirements will lead to prompt disciplinary action (up to and including remedial training, reprimands, unfavorable performance reviews, probation, and termination), depending upon the circumstances of the violation (including the severity of the violation, whether the violation was a first time or repeat violation, whether appropriate guidance was sought or received from the CPNI Compliance fficer(s), and the e!tent to which the violation was or was not deliberate or malicious)" IF COMPANY USES CPNI: BVUA ensures t!at all access to CPNI /e appro ed /y a super isor .it! kno.led0e of t!e $CC7s CPNI re,uirements( BVUA !as instituted trainin0 procedures and a correspondin0 disciplinary process to ensure t!at its personnel understand and comply .it! restrictions re0ardin0 t!e use and disclosure of- and access to- CPNI( All out/ound marketin0 situations must /e appro ed /y t!e Compliance 8fficer and after appro al t!e effort is documented( 9!e Compliance 8fficer .ill maintain a record of eac! out:/ound marketin0 acti ity or campai0n- includin06 a( a description of t!e campai0n3 /( t!e specific CPNI t!at .as used in t!e campai0n3 c( t!e date and purpose of t!e campai0n6 d( t!e name and relations!ip of any t!ird party to .!ic! CPNI .as disclosed or pro ided- or .!ic! .as allo.ed to access CPNI3 and e( .!at products and ser ices .ere offered as part of t!e campai0n(

DISCLOSURE OF CALL DETAIL OVER PHONE BVUA !as instituted aut!entication procedures to safe0uard t!e disclosure of call detail o er t!e telep!one( BVUA1s aut!entication procedures do not re,uire t!e use of readily a aila/le /io0rap!ical information or account information as defined /y t!e $CC( BVUA procedures allo. t!at pass.ords can /e desi0ned in a manner t!at is pri ately si0nificant and memora/le to t!e customer (e"g"- pirates;<#;- ;=>'alamo- ?/eatles")( @o.e er- pass.ords may N89 /e /ased upon readily o/taina/le /io0rap!ical information (e"g"- t!e customer1s name- mot!er1s maiden name- social security num/er or date of /irt!) or account information ( e"g"- t!e customer1s telep!one num/er- address- account num/er- or amount of last /ill)( All customers are re,uired to esta/lis! a pass.ord .it!out t!e use of readily a aila/le /io0rap!ical information or account information if t!ey .ant to recei e call detail o er t!e telep!one( If t!e appropriate pass.ord is not pro ided- BVUA does not disclose call detail o er t!e telep!one( BVUA !as esta/lis!ed /ack:up aut!entication procedures for lost or stolen pass.ords t!at do not prompt t!e customer for readily a aila/le /io0rap!ical information or account information( Company1s /ack:up aut!entication procedure operates as follo.s (e5cerpt from t!e Company1s CPNI manual)6 b" #he Company will establish a password (and a bac$%up customer authentication method if the customer loses or forgets his or her password) for each new customer at the time that the customer initiates service" c" #he Company will establish a new or replacement password (and a bac$%up customer authentication method if the customer loses or forgets his or her password) for e!isting customers desiring a password pursuant to the following procedure" #he Company may periodically announce on its website, in its newsletter and&or in its billing materials that customers must have a password for security and privacy purposes in order to call the Company and obtain their call detail information over the telephone" #he Company announcements will inform customers that they may obtain an initial or replacement password' (i) if they come in person to the Company(s business office, produce a driver(s license, passport or other government%issued identification verifying their identity, and correctly answer certain questions regarding their service and address) or (ii) if they call a specified Company telephone number from their *telephone number of record+ (see definition above) and then wait at that number until a Company employee calls them bac$ and obtains correct answers to certain questions regarding their service and address) or (iii) if they as$ the Company to send a randomly%generated Personal Identification Number (*PIN+) to their *telephone number of record+ (see definition above) by voice, voicemail or te!t message or mail it to their *address of record+ (see definition above), and then call the Company bac$ and provide the correct PIN" d" #he Company(s *bac$%up customer authentication method+ will consist of a *shared secret+ combination of two pre%selected questions by the Company

and two pre%selected answers by the customer regarding two non%public aspects of the customer(s life that would not be $nown by a prete!ter, hac$er or other unauthori,ed entity" -or e!ample, such *shared secret+ questions and answers might relate to the customer(s favorite .oliday, color, song, boo$, movie, food, or sports team, or in what city were you born (unless such characteristic are a matter of public record or $nown by a significant number of people)" If the customer claims to have lost or forgotten his or her password, but can correctly provide the pre%selected answers to the two pre% selected *shared secret+ questions, the requested call detail information can be given to the customer over the telephone during the customer%initiated call" Company !as put into place procedures to notify customers .!ene er a pass.ordcustomer response to a /ack:up means of aut!entication for lost or for0otten pass.ordsonline account- or address of record is created or c!an0ed .it!out re ealin0 t!e c!an0ed information or sendin0 t!e notification to t!e ne. account information( 9!e notice may /e pro ided /y6 (i) a Company call or oicemail to t!e customer1s telep!one num/er of record3 (ii) a Company te5t messa0e to t!e customer1s telep!one num/er of record3 or (iii) a .ritten notice mailed to t!e customer1s address of record (to t!e customer1s prior address of record if t!e c!an0e includes a c!an0e in t!e customer1s address of record)( DISCLOSURE OF CPNI ONLINE BVUA !as instituted aut!entication procedures to safe0uard t!e disclosure of CPNI on: line( BVUA1s aut!entication procedures do not re,uire t!e use of readily a aila/le /io0rap!ical information or account information as defined /y t!e $CC( Customers may !a e access to t!eir /illin0 ia internet access to our secure ser er( Customer must esta/lis! a User IA and Pass.ord /y enterin0 a + di0it secret num/er in conBunction .it! t!eir account num/er( Unless t!e appropriate pass.ord is pro ided- BVUA does not allo. on:line access to CPNI( BVUA !as esta/lis!ed /ack:up aut!entication procedures for lost or stolen pass.ords t!at do not prompt t!e customer for readily a aila/le /io0rap!ical information or account information( See a/o e e5cerpt from BVUA1s CPNI manual( Company !as put into place procedures to notify customers .!ene er a pass.ordcustomer response to a /ack:up means of aut!entication for lost or for0otten pass.ordsonline account- or address of record is created or c!an0ed .it!out re ealin0 t!e c!an0ed information or sendin0 t!e notification to t!e ne. account information( 9!e notice may /e pro ided /y6 (i) a Company call or oicemail to t!e customer1s telep!one num/er of record3 (ii) a Company te5t messa0e to t!e customer1s telep!one num/er of record3 or (iii) a .ritten notice mailed to t!e customer1s address of record (to t!e customer1s prior address of record if t!e c!an0e includes a c!an0e in t!e customer1s address of record)( DISCLOSURE OF CPNI AT RETAIL LOCATIONS Company discloses CPNI at its retail locations only if t!e customer !as presented a alid p!oto IA matc!in0 !is2!er account information(

NOTIFICATION TO LA ENFORCEMENT Company !as in place procedures to notify la. enforcement in t!e e ent of a /reac! of customers1 CPNI and to ensure t!at customers are not notified of t!e /reac! /efore t!e time period set fort! in t!e $CC1s rules- or- if applica/le- .!en so aut!ori4ed /y la. enforcement( BVUA maintains records of all /reac!es disco ered and notifications made to t!e USSS and t!e $BI- and to customers( ACTIONS A!AINST DATA BRO"ERS Company !as not taken any actions a0ainst data /rokers in t!e last year( CUSTOMER COMPLAINTS ABOUT CPNI BREACHES Company did not recei e any customer complaints a/out t!e unaut!ori4ed release of CPNI or t!e unaut!ori4ed disclosure of CPNI in calendar year )*;>( INFORMATION ABOUT PRETE#TERS Company !as de eloped t!e follo.in0 information .it! respect to t!e processes prete5ters are usin0 to attempt to access CPNI and is takin0 t!e follo.in0 steps to protect CPNI( BVUA !as stated t!e follo.in0 in its CPNI manual6 In some unfortunate instances, prete!ters have obtained CPNI from telephone company representatives who have cooperated for friendship, financial or other reasons" #he Company will ta$e any and all disciplinary, termination and&or remedial actions permitted by applicable federal and state employment law against any Company representative that is reasonably suspected to have cooperated $nowingly and intentionally with a prete!ter" Prete!ters may use a variety of tactics to try to fool telephone company representatives in order to get unauthori,ed and unlawful access to CPNI" /ome of these tactics involve moc$ anger and bullying) others entail pleading and playing upon normal human emotions"