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200 N Ozark Girard K5 55143 520 124 8235 Fax: 520 124 4099

The Company represents and warrants that the above certificate is consistent with 47C F R 1 17 which requires truthful and accurate statements to the Commission The Companyalso acknowledges that false statements and misrepresentations to the Commission arepunishable under Title 18 of the U S Code and may subject it to enforcement action

i g n e ~ ~ ~Attachments: Attachment A Accompanying Statement Explaining CPNI ProceduresAttachment B Explanation of Actions Taken Against Data BrokersAttachment C Summary of Customer Complaints

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2 2ll2l N Ozark Girard K5 55143 520 124 8235 Fax: 5212ll24.412lggI f new, additional or extended approvals are necessary, the CPNI Compliance Officer willdetermine whether the Company's "Opt-Out CPNI Notice" or "Opt-In CPNI Notice" must beused with respect to various proposed out-bound marketing activities.10. The CPNI Compliance Officer will maintain a record of each out-bound marketingactivity or campaign, including: (i) a description o the campaign; (ii) the specific CPNI thatwas used in the campaign; (iii) the date and purpose of the campaign: and (iv) what productsand services were offered as part of the campaign. This record shall be maintained for aminimum o one year.11 The Company's employees and billing agents may use CPNI to initiate, render, bill andcollect for telecommunications services. The Company may obtain information from new orexisting customers that may cons itute CPNI as part of applications or requests for new,additional or modified services, and its employees and agents may use such customerinformation (without further customer approval) to initiate and provide the services.Likewise, the Company' s employees and billing agents may use customer service and callingrecords (without customer approval): (a) to bill customers for services rendered to them; (b)to investigate and resolve disputes with customers regarding their bills; and (c) to pursuelegal, arbitration, or other processes to collect late or unpaid bills from customers.12 . The Company' s employees and agents may use CPNI without customer approval toprotect the Company's rights or property, and to protect users and other carriers fromfraudulent, abusive or illegal use o (or subscription to) the telecommunications service fromwhich the CPNI is derived.Because allegations and investigations of fraud, abuse and illegal use constitute verysensitive matters, any access, use, disclosure or distribution o CPNI pursuant to this Sectionmust be expressly approved in advance and in writing by the Company ' s CPNI ComplianceOfficer.13 The Company' s employees, agents, independent contractors and joint venture partnersmay OT use CPNI to identify or track customers who have made calls to, or received callsfrom, competing carriers. Nor may the Company's employees, agents, independentcontractors or joint venture partners use or disclose CPNI for personal reasons or profit.14. Company policy mandates that files containing CPNI be maintained in a secure mannersuch that they cannot be used, accessed, disclosed or distributed by unauthorized individualsor in an unauthorized manner.15. Paper files containing CPNI are kept in secure areas, and may not be used , removed, orcopied in an unauthorized manner.

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200 N Ozark Girard K5 55143 5 2 0 124 8235 Fax: 520.124.409920. The Company must provide an initial notice to law enforcement and a subsequent noticeto the customer i a security breach results in the disclosure o the customer's CPNI to a thirdparty without the customer' s authorization.

a As soon as practicable (and in no event more than seven (7) days) after the Companydiscovers that a person (without authorization or exceeding authorization) hasintentionally gained access to, used or disclosed CPNI, the Company must provideelectronic notification o such breach to the United States Secret Service and to theFederal Bureau of Investigation via a central reporting facility accessed through a linkmaintained by the FCC at http://www.fcc.gov/eb/cpni.21. The Company will provide customers with access to CPNI at its retail locations if thecustomer presents a valid photo ID and the valid photo ID matches the name on the account.22. The Company takes reasonable measures to discover and protect against activity that isindicative o pretexting including requiring Company employees, agents, independentcontractors and joint venture partners to notify the CPNI Compliance Officer immediately byvoice, voicemail or email of: (a) any suspicious or unusual call requesting a customer' s calldetail information or other CPNI (including a call where the caller furnishes an incorrectpassword or incorrect answer to one or both o the shared secret question-answercombinations); (b) any suspicious or unusual attempt by an individual to change a customer ' spassword or account information (including providing inadequate or inappropriateidentification or incorrect address or record, telephone number o record or othersignificant service information); (e) any and all discovered instances where access to theCompany's electronic files or databases containing passwords or CPNI was denied due to theprovision o incorrect logins and/or passwords; and (d) any complaint by a customer ofunauthorized or inappropriate use or disclosure o his or her CPNI. The CPNI ComplianceOfficer will request further information in writing, and investigate or supervise theinvestigation of, any incident or group o incidents that reasonably appear to entailpretexting.

IV. CPNI Compliance OfficerIn addition to the specific matters required to be reviewed and approved by the Company ' sCPNI Compliance Officer, employees and agents, independent contractors and joint venturepartners are strongly encouraged to bring any and all other questions, issues or uncertaintiesregarding the use, disclosure, or access to CPNI to the attention o the Company' s CPNICompliance Officer for appropriate investigation, review and guidance. The extent to whicha particular employee or agent brought a CPNI matter to the attention o the CPNICompliance Officer and received appropriate guidance is a material consideration in anydisciplinary action brought against the employee or agent for impermissible use, disclosureor access to CPNI.

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2 N Ozark Girard K5 55143 520.124.8235 fax: 52 .124.40ggAttachment BCRAW-KAN TELEPHONE COOPERATIVE, INC.

STATEMENT OF ACTIONS TAKEN AGAINST DATA BROKERSA During Calendar Year 2013, the Company has instituted the following proceeding, or filed the following petitions, against data brokers before the Federal CommunicationsCommission:

NONEB. During Calendar Year 2013, the Company has instituted the following proceeding, or filedthe following petitions, against data brokers before the Kansas Corporation Commission, theMissouri Public Service Commission and the Oklahoma Corporate Commission:

NONEC. During Calendar Year 2013, the Company has instituted the following proceeding, or filedthe following petitions, against data brokers before the following federal or state courts:

NONE

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R. Wilbert General Man crwilbert@cYour Community Technology Partner

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