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OF THE STATE OF SOUTH DAKOTA. LA q --. - --.- j i. * :*? , —, -- -. ... -. . . -- ---- --. - -- ---. .- — 8 0 !2da& $ LFP Ibadan r, q- * 3 pr't : !-;: -& $& J :$ IN THE MATTER OF THE REVIEW OF
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Acting Chief Financial Officer and Accounting Control Officer (ACO) (William V. McCray and William P. Hart), provides the following response in response to the requests made by the FCC for information regarding whether West's operating subsidiaries, West-Bancorp and West-Com, are in compliance with provisions contained in the Communications Act. Based on the foregoing, West Corporation believes that this information is insufficient to warrant further scrutiny by the Federal Communications Commission and does not intend to provide further guidance or comments on the matters raised in the request for information. West Corporation has sent a copy of the Company's response to the FCC to its auditors, the SEC, the state securities commissions, and to the state comptroller of the appropriate governmental unit. A copy of said response has been submitted with the documents to which this memorandum relates pursuant to Item 601(d) of Regulation S-K i n ' The West Corporation of Iowa, a corporation organized in the state of Iowa, was formed in February 1971. At the time, the corporation had its principal corporate headquarters in Cedar Falls, Iowa, but has since consolidated its business and assets by acquiring, through an equity investment of West's, a number of operations throughout the state of Iowa. The Delaware corporation has no board of directors. The business of West consists primarily of a private telephone company, as well as a variety of other services. It offers telephone services in the State of Iowa, including local, long distance and access lines. The corporation is also engaged in the maintenance and operation of a small cell service company in the city of Iowa City which offers long distance telephone service. Through its wholly owned subsidiary, West-Com, West provides a link-up program to assist local business and home bound telephone customers in reaching local telephone exchange points. In 1986, West entered into a 20-year, 40 million long-term lease agreement for the lease of one of its facilities, which it leases from Cedar Falls Telephone, to serve as a connection point for connections from long distance services. In September 1987, West acquired Cedar Falls from the Cedar Falls Telephone Company, its former owner, as a result of an exchange offered by West. In 1988, West entered into a two-year contract to serve as a connection point for local area exchange service in the State of Iowa. West will also provide a local service point for Iowa City telephone exchanges to connect long distance customers to the regional exchange service for that community.

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