Annual 47 C.F.R. 64.

2009(e) CPNI Certification

EB Docket 06-36
Annual 64.2009(e) CPNI Certification for December 31, 2015
Date filed: 02/10/2016
Name of company covered by this certification: Cytel, Inc.
Form 499 Filer ID: 829210
Name of signatory: Cristina Perry
Title of signatory: President
I, Cristina Perry, certify that I am an officer of the company named above, and acting as an agent
of the company, that I have personal knowledge that the company has established operating procedures
that are adequate to ensure compliance with the Commission's CPNI rules. See 47 C.F.R. 64.2001 et
seq.
Attached to this certification is an accompanying statement explaining how the company's
procedures ensure that the company is in compliance with the requirements (including those mandating the
adoption of CPNI procedures, training, recordkeeping, and supervisory review) set forth in section 64.2001
et seq. of the Commission's rules. See Statement.
The company has not taken any actions (i.e., proceedings instituted or petitions filed by a
company at either state commissions, the court system, or at the Commission against data brokers) against
data brokers in the past year.
The company has not received any customer complaints in the past year concerning the
unauthorized release of CPNI.
The company represents and warrants that the above certification is consistent with 47 C.F.R.
1.17, which requires truthful and accurate statements to the Commission. The company also
acknowledges that false statements and misrepresentations to the Commission are punishable under
Title 18 of the U.S. Code and may subject it to enforcement action.
Signed
Attachments:

Accompanying statement explaining CPNI procedures

Cytel, Inc. 2700 W. Atlantic Boulevard Suite 237 Pompano Beach, FL 33069
Phone: 954-968-1198 Fax: 954-968-1237

EB Docket No. 06-36 Statement

Cytel, Inc. ("Cytel") is a non facilities-based reseller of residential 1+ long distance carrier. Cytel's
underlying carrier is Qwest Communications aka CenturyLink. As a long distance reseller, Cytel, Inc. does
not have access to CPNI records of its customers, which are obtained and maintained by the customer's
Local Exchange Carrier; i.e., opt-in/opt-out preferences, CPNI permissions, etc. However, Cytel does
conduct an annual review to assure the companys operating procedures are in compliance with all FCC
CPNI standards and regulations.
In addition, all Cytel customer bills are rendered through the LECs via the companys billing
aggregator, BSG Services, which receives and processes calling files from Cytel, adds location-appropriate
taxes, and then forwards the billing information to the customers' Local Exchange Carriers for inclusion on
the customers' local telephone bill. As a result, Cytel does not have access to the actual customer bills of
its customers, nor does the company have access to the customers call detail information.
Cytel, Inc. does not sell any other services or any type of equipment, and the company's records
are maintained on its self-contained server which is not accessible to any third party.
In summary, Cytel has no reason to access a customer's CPNI as it does not provide or market
additional service offerings to customers, nor does it have joint venture partners or independent contractors
to whom it would disclose CPNI. The company has no access to customers' opt-in/opt-out records,
obtained and maintained by the LEC, or actual customer bills, on which CPNI is included.