Annual 47 C.F.R. 64.2009(e) CPNI Certification EB oc!

et 06"#6

Marlene H. Dortch, Secretary Federal Communications Commission Office of the Secretary 445 12th Street, SW Washin ton, DC 2!554
"nnual #4.2!!$%e& C'() Certification for 2!14 co*erin the +rior calendar year 2!1,. Date filed- 2.12.14 (ame of com+any co*ered /y this certification- 0rafton 1on Distance Form 4$$ Filer )D- 2!1,#4 (ame of si natory- Carolyn Susan "rnold 3itle of si natory- Cor+orate Secretary ), Carolyn Susan "rnold, certify that ) am an officer of the com+any named a/o*e, and actin as an a ent of the com+any, that ) ha*e +ersonal 4no5led e that the com+any has esta/lished o+eratin +rocedures that are ade6uate to ensure com+liance 5ith the Commission7s C'() rules. See 48 C.F.9. : #4.2!!1 et seq. "ttached to this certification is an accom+anyin statement e;+lainin ho5 the com+any7s +rocedures ensure that the com+any is in com+liance 5ith the re6uirements %includin those mandatin the ado+tion of C'() +rocedures, trainin , record4ee+in , and su+er*isory re*ie5& set forth in section #4.2!!1 et seq. of the Commission7s rules. 3he com+any has not ta4en any actions %i.e. +roceedin s instituted or +etitions filed /y a com+any at either state commissions, the court system, or at the Commission a ainst data /ro4ers& a ainst data /ro4ers in the +ast year. 3he com+any has not recei*ed any customer com+laints in the +ast year concernin the unauthori<ed release of C'(). 3he com+any re+resents and 5arrants that the a/o*e certification is consistent 5ith 48. C.F.9. : 1.18 5hich re6uires truthful and accurate statements to the Commission. 3he com+any also ac4no5led es that false statements and misre+resentations to the Commission are +unisha/le under 3itle 12 of the =.S. Code and may su/>ect it to enforcement action.

???????????????????????????????????? Carolyn Susan "rnold Cor+orate Secretary 0rafton 1on Distance '. O. @o; 122 0rafton, )llinois #2!,8A #12.82#.,,11 susanaB tec.net "ttachment- "ccom+anyin Statement e;+lainin C'() +rocedures

Certification Statement
Fe/ruary 12, 2!14 0rafton 1on Distance C'() O+eratin 'rocedures 0rafton 1on Distance has +ro*ided trainin to e;istin em+loyees and 5ill +ro*ide trainin to all ne5 em+loyees on the +ro+er us and disclosure of %C'()&. 9ecords of the trainin material and documentation of the attendance is 4e+t on file. "ny em+loyee7s noncom+liance C'() +olicies 5ill /e re+orted and a++ro+riate disci+linary ste+s ta4en. C'() notification letters 5ere sent to all customers e;+lainin 5hat C'() is and as4in customer to call office to set u+ a +ass5ord and challen e 6uestion. When customer calls, no C'() information is released 5ithout a +ass5ord. When a customer comes in.store, a *alid +hoto )D is re6uired /efore releasin C'() information. When customer7s C'()7s data re6uested /y +hone or in +erson, em+loyees *erify /y +rocedures noted in their C'() trainin manual. "fter a chan e or re6uest of C'() data has occurred, the customer is notified /y mail to address of record a notification of chan e and a lo is made in the /illin system. "ll ne5 customers are as4ed to esta/lish security information for C'(). 3he customer is also i*en the letter descri/in C'(). 0rafton 1on Distance /illin com+any is also com+liant 5ith the C'() re ulations. )n the +ast year, no action ta4en a ainst data /ro4ers and no customer com+laints recei*ed concernin unauthori<ed release of C'().