Supplemental Information in Response to Selection Committee's

Supplemental Information in Response to Selection Committee’s July 27th Request RELOCATION PAYMENT CLEARINGHOUSE Expanding Flexible Use of the 3.7 to 4.2 GHz Band, GN Docket No. 18-122 July 29, 2020

Submitted By: CohnReznick LLP 7501 Wisconsin Avenue Frank Banda, CPA, CFE, CGMA, PMP Suite 400E Managing Partner – Public Sector Bethesda, MD 20814 [email protected] | 301-280-1856

July 29, 2020

Dear Relocation Payment Clearinghouse Selection Committee, The CohnReznick Team is pleased to have been unanimously selected by the Committee to serve as the Relocation Payment Clearinghouse (the Clearinghouse). We have enclosed the following information to assist you with your communication of your selection to the Commission.

1. Expertise and Ability to Fulfill the Requirements of the Report and Order and RFP We have enclosed a description of our Expertise and Ability to Fulfill the Requirements of Relocation Payment Clearinghouse criteria stated in the Report and Order and the Request for Proposal.

2. Neutrality and Independence • We have enclosed our Independence and Neutrality Exhibit. • We have enclosed the Certifications of Independence and No Financial Interest of each of the CohnReznick Team members. • We have enclosed a list of all entities that fall within the scope of “the Clearinghouse, or its officers, directors, employees, and/or contractors.”

3. Forecast of Fees and Expenses • CohnReznick LLP will establish a limited liability company (LLC) to serve as the Relocation Payment Clearinghouse entity. The LLC will subcontract with all of the team members of the CohnReznick LLP Team. The LLC will not have any employees, so there are no salaries and benefits to report. The team members will charge hourly rates on a time and material basis. The CohnReznick LLP Team proposed rates that are discounted for this project. Please note that our hourly rates are confidential and commercially-sensitive information; however, we will gladly provide them to Commission staff upon request. • Enclosed is our Forecast of Annual Cost to perform the work.

Additionally, we confirm our willingness to enter into contracts with the Electing Satellite Operators, and post-auction, with 3.7 GHz Service licensees (overlay licensees) in lieu of a form contract, that would provide at a minimum for the following:

• The Clearinghouse shall at all times function in accordance with the Commission’s rules, the C-Band Order, and the policies adopted thereunder;

• The Clearinghouse shall maintain substantially the same level of expertise and experience among its personnel and subcontractors as set forth in its response (and any amendments) to the RFP;

• The Clearinghouse shall promptly pay reasonable reimbursement requests for equipment and expenses that are necessary for the Transition under the rules and policies adopted pursuant to the C-Band Order and, conversely, the Clearinghouse shall not pay reimbursement requests that are either unreasonable or unnecessary for the Transition under the rules and policies adopted pursuant to the C-Band Order;

• The Clearinghouse shall operate in a neutral and independent manner and shall maintain internal controls to ensure that it has no conflicts of interest on the part of the organization or its officers, directors, employees, contractors, or significant subcontractors, as described in the C-Band Order;

• The Clearinghouse shall use best practices to prevent fraud, waste, and abuse both in its handling of funds and to protect against improper payments to itself, its subcontractors, and entities filing reimbursement requests; and

• The Clearinghouse shall have in place and maintain robust privacy and data security best practices in its operations, as described in the C-Band Order.

Thank you again for selecting the CohnReznick Team for this important national program. Please contact me if the Selection Committee has additional questions or concerns. Sincerely,

Frank Banda, CPA, PMP, CGMA, CFE Managing Partner – Public Sector, CohnReznick LLP [email protected] | (240) 461-7002

Attachment 1: Expertise and Ability to Fulfill the Requirements of the Report and Order and RFP

Expertise and Ability to Fulfill the Requirements of the Report and Order and RFP

RELOCATION PAYMENT CLEARINGHOUSE

Expanding Flexible Use of the 3.7 to 4.2 GHz Band, GN Docket No. 18-122

Submitted By:

CohnReznick LLP 7501 Wisconsin Avenue Frank Banda, CPA, CFE, CGMA, PMP Suite 400E Managing Partner – Public Sector Bethesda, MD 20814 [email protected] | 301-280-1856

Table of Contents

1.0 EXECUTIVE SUMMARY 2

2.0 GENERAL INFORMATION 6

2.1 NAME AND DESCRIPTION 6 2.2 CONTACT PERSON 9

3.0 NEUTRALITY AND INDEPENDENCE 11

3.1 IMPARTIALITY, CONFLICTS OF INTEREST DETERMINATION, AND CONTINUOUS CONFLICT MONITORING 11 3.2 TRANSPARENCY – FAIR AND TRANSPARENT OPERATIONS 11

4.0 FINANCIAL, ACCOUNTING, AUDITING, AND INDUSTRY EXPERTISE 14

4.1 COMMUNICATIONS INDUSTRY EXPERIENCE 14 4.2 FINANCIAL, ACCOUNTING, AND AUDITING EXPERTISE 30 4.3 FUNDS MANAGEMENTS; COLLECTION AND DISTRIBUTION OF PAYMENTS 33 4.4 C-BAND RELOCATION KNOWLEDGE 35 4.5 KEY PERSONNEL 39 4.6 COST DISPUTE RESOLUTION 42

5.0 BEST PRACTICES AND OPERATIONAL STANDARDS 45

5.1 FINANCIAL SOLVENCY 45 5.2 FEES AND EXPENSES 46 5.3 ACCOUNTING METHODS 46 5.4 PROTECTION AGAINST IMPROPER PAYMENTS; PREVENTION OF FRAUD, WASTE, AND ABUSE 46 5.5 PERFORMANCE GOALS AND METRICS 48 5.6 ENTERPRISE RISK MANAGEMENT EXPERIENCE 49 5.7 GAO GREEN BOOK PROCEDURES 53

6.0 PRIVACY AND DATA SECURITY 55

6.1 CONFIDENTIALITY, PRIVACY, AND DATA SECURITY 55 6.2 FEDERAL PRIVACY AND INFORMATION SECURITY REQUIREMENTS 56

7.0 OTHER INFORMATION 59

7.1 OPERATIONAL TIMELINE 59 7.2 NOTIFICATION OF OVERLAY LICENSEES 59 7.3 INCUMBENT EARTH STATION COST CALCULATIONS AND LUMP SUM PAYMENTS 60

Executive Summary

1.0 Executive Summary We are pleased to present our Expertise and Ability to Fulfill the Requirements of the Report and Order and RFP to serve as the Relocation Payment Clearinghouse (Clearinghouse). We have assembled a multi-disciplinary team to serve as the Clearinghouse, led by CohnReznick LLP (CohnReznick), one of the nation’s largest certified public accounting firms, and subcontractors Squire Patton Boggs (US) LLP (Squire Patton Boggs or SPB), a global law firm, Intellicom Technologies, Inc. (Intellicom), experts in satellite and communications, and David Reed, Ph.D (Dr. Reed), an expert on cable and broadband technologies. Our team’s diverse areas of expertise converge to form the holistic solution to meet the requirements of the upcoming transition and spectrum reconfiguration process for the 3.7-4.2 GHz Band (C-band Relocation). There is no other team that has the experience offered by our team. CohnReznick and Squire Patton Boggs worked together for over a decade on the 800 MHz band reconfiguration program (800 MHz Reconfiguration), one similar in nature to the C-band Relocation. WHY CHOOSE US? CohnReznick, Squire Patton Boggs, Intellicom, and Dr. Reed (collectively the Team) know the complexity of issues involved in the C-band Relocation. Together we are uniquely qualified to fulfill the duties of the Clearinghouse. We have created a group that can address the chief concerns of C-band Relocation stakeholders and that can move quickly to accomplish tasks in a fair and independent manner satisfactory to all parties. We know these issues, and equally important, we have We are Uniquely worked together in previous engagements so that there will be no learning curve to Qualified to Fulfill develop and implement the Clearinghouse. We also know well the Federal the Duties of the Communications Commission (FCC or Commission) and its staff, rules, procedures, Clearinghouse and processes. We understand the industry and the specific requirements of all C-band stakeholders.

OUR TEAM As this document will demonstrate, our Team more than fulfills each of the four selection criteria identified by the Clearinghouse Selection Committee in its Request for Proposal (RFP): Neutrality and Independence; Financial, Accounting, Auditing, and Industry Expertise; Best Practices and Operational Standards; and Privacy and Data Security. The members of our Team have managed complex spectrum reconfiguration and financial clearinghouse programs. We are experts in satellite and earth station construction and operation, cable and broadcast technologies, and content distribution. We have long-term experience in managing such potentially large-scale, multi-layered projects subject to critical but aggressive deadlines. Our Team members are experts in navigating through complex regulatory matters. CohnReznick is a world- class financial management organization with deep experience in large-scale programs. CohnReznick served as the independent auditor for the 800 MHz Reconfiguration, enhancing its expertise and knowledge of spectrum reconfiguration programs. The 800 MHz Transition Administrator (Transition Administrator), which is now completing the final stages of the 800 MHz Reconfiguration, has served in many ways as a model for the Commission’s formulation of the Clearinghouse and Relocation Coordinator. Each spectrum reconfiguration

2 program is unique, however, and we are keenly aware of the measures being utilized to streamline the C-band Relocation, including the Cost Catalog and lump sum payments. CohnReznick’s team will be led by Frank Banda, who also led its efforts in the 800 MHz Reconfiguration. Squire Patton Boggs has served as part of the Transition Administrator, having been selected by a committee of public and private sector experts, since its inception. Squire Patton Boggs’s team is led by Robert Kelly, who has served as General Counsel of the Transition Administrator for the entirety of its existence. Among other matters, Squire Patton Boggs constructed and managed an Alternative Dispute Resolution (ADR) program for the 800 MHz Reconfiguration that successfully resolved almost 5,000 disputes. The firm maintains a trained and talented group of mediators with spectrum rebanding experience that is not available at any other organization. Intellicom has extensive experience in satellite and terrestrial communications systems, digital television and audio broadcast systems and operations, and associated technical and financial project planning. Intellicom assisted numerous telecommunications entities with requirements definition, architecture design, project planning, procurement, regulatory consulting, and implementation of satellite and terrestrial based networks and broadcasting systems. This expertise will be help us address any claims reimbursement issues that may arise. David Reed, Ph.D. will serve as our Team’s broadband and cable technologies subject matter expert. He has served as the Executive VP and Chief Strategy Officer of Cable Television Laboratories for nearly 20 years. He is a subject matter expert in developing and evaluating engineering models for telecommunications and data communications services for business models and regulatory compliance. We will utilize Coupa, a Business Spend Management tool. It will allow incumbent space stations and earth stations to submit reimbursement claims through a secure portal and have visibility into the status of their approval and payment. In addition, our banking solution will be provided by Truist (formerly BB&T and SunTrust), one of the nation’s largest and most stable banks. Coupa will provide the claims reimbursement and payment platforms that will help make the reimbursement process a smooth and secure one. We will use a suite of Microsoft D365 tools to manage the operations of the Clearinghouse, including the estimating and forecasting of reimbursement claims and billing the overlay licensees for their share. In addition, we will use Microsoft PowerBi to report program performance, including key performance metrics of the Clearinghouse. CohnReznick and Squire Patton Boggs formed our Team over a year ago looking toward fulfilling the need for assistance with a potential C-band Relocation. Intellicom joined our team in January 2020, well before adoption by the FCC of its Report and Order and Order of Proposed Modification (Report and We Formed Our Order) released on March 3, 2020 regarding the C-band Relocation. Since then, we Team Over a have been working together to combine our respective areas of expertise into a strong, Year Ago cohesive multi-disciplinary team to meet the multi-disciplinary challenges of this major spectrum realignment. The product of those efforts is reflected in the highly detailed Proposal that we are presenting today. We are ready to start operations on day one.

OUR PROPOSAL

 Prevent and Detect Fraud,  Promote Accountability  Mitigate Risk  Ensure Quality and Compliance Waste, & Abuse

 Identify and Remove  Reduce  Foster Implementation of Best Practices  Ensure the Right People are Bottlenecks Backlogs Across Operations Performing the Right Tasks

Our Proposal meets all of the requirements identified in the RFP. We are prepared to commence operations as the Clearinghouse in a fair, fast, and efficient manner. We are independent and have no financial interests with program stakeholders in accordance with FCC requirements. All team members have certified their compliance with these requirements. We will utilize and make public an Independence Management Plan and Code of

Conduct throughout the program to ensure that we avoid any appearance of conflicts in the provision of our services. The Clearinghouse must be fair—impartiality is central to the RFP and all C-band Relocation stakeholders. No stakeholder’s best interest would be served by a program plagued by inconsistent processes, and contentious and prolonged litigation. The Clearinghouse’s processes must be imbued with consistency and transparency. Our Team has unmatched experience in serving as “special master in a judicial proceeding” while resolving disputes arising in a spectrum realignment. We have taken special care to ensure that the ADR function of the Clearinghouse is separated from other operational functions. We hope there are not many disputes in this C- band Relocation, but we are resourced and ready to handle whatever caseload may arise as our Team has proven with the 800 MHz Reconfiguration. We are also deeply experienced in designing and implementing state of the art fraud, waste, and abuse deterrence and detection measures. The Clearinghouse must be fast — delay in band reconfiguration will come at an unacceptably high price. All interests are aligned on this need; the operations of incumbent space station operators, incumbent earth station operators, content distributors, wireless carriers seeking to deploy new 5G services in the realigned band, and the nation itself demand a C-band Relocation that meets or beats the accelerated schedule. We recognize that there is no room for delay and the process we have designed reflects that urgency. The Clearinghouse must be efficient — a lack of resources will cause delay and inappropriately burden FCC and C-band stakeholder resources that can ill afford to We are Committed bear such burdens. Our resources are fully scalable, permitting us to respond to the C-band appropriately as the full scope of the Clearinghouse’s duties is refined and, if Relocation and necessary, modified by the FCC. Moreover, we believe that our Team’s ability to Staying Until “ramp-up” and “ramp-down” over the course of the aggressive schedule is a practical Completion of the necessity. In addition, as can be readily seen from our collective experience in the C-band Relocation 800 MHz Reconfiguration, our Team members are committed to the C-band Relocation and to staying until completion. Key members of CohnReznick’s and Squire Patton Boggs’s teams have worked on the 800 MHz Reconfiguration since that program’s inception. Turnover and personnel churn can be costly and cause delay. Our track record is unmatched by any other organization that has participated in such programs. Given the uncertainties regarding the scale of the C-band Relocation, such as the impact of lump sum payments on payment processing and the ADR caseload, we are proposing that our fees would be based upon the time and materials incurred by each organization. Both CohnReznick and Squire Patton Boggs have proposed hourly rates for their professionals that are heavily discounted from their standard commercial rates. The Clearinghouse must be responsive. As such, to ensure an immediate start to the Clearinghouse, we have designed a template process flow that reflects the requirements of the Report and Order. We recognize, however, that the input of C-band stakeholders, including the FCC, is essential to implementing any process. Accordingly, starting on “Day One” we plan to review our process in detail with C-band stakeholders and to continue outreach, and to be available and responsive, throughout the course of the C-band Relocation, and to make modifications where and when necessary. We must be able to capture the benefits of “lessons learned” to improve efficiency throughout the course of the program. Our Team, in short, has been built to meet all of the duties the Clearinghouse will encounter. One further challenge—that we all face now with the dramatic changes to our lives and workplaces this year during the COVID-19 pandemic—must also be overcome to ensure that the Clearinghouse can start without delay. Since most of our team has worked together for years on a comparable program, we are best suited to successfully meet that challenge. We have been planning for this for over a year and have built the cohesive and collaborative multi-disciplinary team that is needed now.

General Information

2.0 General Information 2.1 Name and Description Our Team will be led by CohnReznick with critical support from our subcontractors Squire Patton Boggs, Intellicom, and Dr. Reed. Our Team’s diverse areas of expertise converge to form the holistic solution to serve as the Clearinghouse and fulfill the requirements of the Report and Order. Our Team more than fulfills each of the selection criteria in the RFP. The members of our Team have managed complex spectrum reconfiguration and financial clearinghouse programs. We are experts in satellite and earth station construction and operation, cable and broadcast technologies, and content distribution. We have long- term experience in managing such potentially large- scale, multi-layered projects subject to critical but aggressive deadlines. CohnReznick is a national advisory, assurance, and tax firm founded in 1919. As one of the top accounting firms in the United States, CohnReznick provides forward-thinking service across nearly two dozen industries and serves businesses ranging from multigenerational family-run enterprises, to government entities, to public companies in the Fortune 1000. With more than 2,700 employees firm wide— including over 900 Certified Public Accountants (CPA) —we have the deep resources and technical acumen of a large national accounting firm without sacrificing the hands-on, entrepreneurial approach that today’s dynamic business environment demands. CohnReznick has administered, managed, and overseen nearly $40 billion of government funds over the last 15 years and audited nearly $4 billion of costs associated with the 800 MHz transition. The executive project team who performed these services for the 800 MHz project will be part of the Payment Clearinghouse team.

Squire Patton Boggs will be the General Counsel to the Clearinghouse. In addition, the firm will develop the Alternative Dispute Resolution (ADR) process and mediate any disputes. Squire Patton Boggs is an international law firm with more than 1,500 lawyers in 20 countries. The firm’s 700+ lawyers in the US practice out of 16 offices and have expertise in virtually every substantive area of law. Squire Patton Boggs has been at the heart of regulation and policy for the communications sector for 40 years, including practice at all levels of the FCC and on the complete range of terrestrial and satellite communications systems. Squire Patton Boggs has been involved in the full spectrum of regulatory, legal and policy issues, including transactional, behavioral, regulatory and litigation matters, both in the US and around the globe. Squire Patton Boggs has a renowned specialty in spectrum regulation and band realignment, including advising on reconfiguring spectrum resources to benefit from the growth of wireless consumer, enterprise and public safety services, regulation, and spectrum policy. Squire Patton Boggs’s experience covers both government mandates and advice to bidders on a range of spectrum auction types in the US, Europe, the Middle East, and Asia. It also includes the development of auction tender rules and the conduct of complex licensing procedures for the award of spectrum, as well as assisting clients with spectrum auctions and secondary market transactions for spectrum. Further, Squire Patton Boggs has been at the forefront of dispute resolution in connection with regulatory matters, including acting for both claimants and defendants in high-value, precedent-setting actions.

Founded in 2002, Intellicom provides communications systems engineering services to major manufacturers and service providers. Intellicom provides engineering analysis, design, trade studies, integration, test, certification, and qualification services. Intellicom team members bring over 35 years of experience designing fixed, airborne, maritime and ground mobile systems for commercial and government customers. Its customers have included General Dynamics, Boeing, Cobham, L3Comms, DRS, Rockwell Collins, Cubic Defense, BAE Systems, Panasonic, Intelsat, Inmarsat, Air Force, Army, Marines, Thinkom, Thales, Lockheed Martin, AvL Technologies and Viasat. Intellicom specializes in telecommunications systems engineering, regulatory and spectrum consulting, project management, and operational aspects of broadcast and two-way communications systems. Its strength is in its ability to apply highly technical skills and operational experience in a hands-on approach to problem solving and project execution. It has extensive experience in satellite and terrestrial communications systems, digital television and audio broadcast systems and operations, and associated technical and financial project planning. Intellicom assisted a number of telecommunications entities with requirements definition, architecture design, project planning, procurement, regulatory consulting, and implementation of satellite and terrestrial based networks and broadcasting systems. Dr. Reed, an expert on cable and broadband technologies, rounds out our Team’s diverse areas of expertise converge to form the holistic solution to meet the requirements of the C-band Relocation.

Enabling Platforms To successfully operate the Clearinghouse and fulfill the requirements of the C-band Relocation program, we will utilize the following third-party solutions: • Coupa Software Inc. (Coupa) for the reimbursement claims, invoice processing, and payment determinations; • Truist Bank (formerly BB&T and SunTrust) to manage and store collections and disbursements; and • Microsoft Dynamics 365 to serve as our Enterprise Resource Planning system of choice.

Coupa’s cloud-based suite of Business Spend Management (BSM) applications lets customers gain visibility and control over 100% of their operating expenses. Coupa customers get the usability, flexibility, and compliance that is needed for BSM success on a highly scalable, secure, and available cloud platform. Coupa provides solutions for procurement, invoice, expense, payments, Coupa will allow incumbent spend analysis, sourcing, contract management, contingent workforce, space station operators and and supplier management. The Coupa community now includes over incumbent earth station 1,300 customers, 5 million suppliers and $1.7 trillion in spend. By bringing operators to establish procurement and expense reporting spend under a unified platform it accounts, submit claims, and becomes simple to leverage spend for sourcing events and identify spend check on their status— which could be moved from post-approved on an expense report to pre- providing transparency into approved through procurement. claims and their payments Coupa helps businesses better manage their operating expenses. Whether they hail from the Groupon offices in Chicago, the reserves of Drillsearch in Australia, the Christian Dior retailers in France, or the clinics of Molina Healthcare – for example – Coupa is at the frontline with all of its customers, no matter their sector. Coupa’s spend management solutions address some of the biggest industry trends and the most important issues today. Coupa is helping companies of all sizes and industries to operate more efficiently, spend smarter, and deliver savings that ultimately improve the bottom line. Coupa has a truly horizontal solution that has been successfully deployed in many verticals, such as Retail, Food & Beverage, Healthcare, Healthcare, Finance, High Technology, Insurance, Real Estate, Manufacturing, Education, Hospitality and Media, etc. More than 1,300 customers that

7 are doing business in more than 49 countries use Coupa purchasing and procurement software to amplify their spend power and reduce spending costs. Coupa’s customers span many industries and sizes ranging from small non-profits to large, multinational Fortune 500 companies.

As separate financial institutions, clients have trusted BB&T and SunTrust for years as two of the most stable banks in the nation. That trust stems from more than just healthy capital levels and solid credit ratings – it is from serving their clients with honesty, transparency and integrity. Now that they have come together as Truist, that commitment is stronger than ever. They have more than 275 years of combined experience serving their clients and communities, and they will continue to provide a secure place to bank, regardless of the economic climate. TRUIST Purpose-driven and prepared

• Strong balance sheet with a solid capital position – above Federal Reserve and FDIC standards • Highly liquid with top-tier credit ratings • Guided by our purpose to inspire and build better lives and communities • Community bank-focused with local decision making • National geographic presence • Highly diversified with a full spectrum of client solutions and deep industry expertise

Established in 1975, Microsoft is a leading global technology company and the maker of Microsoft Dynamics 365, a cloud-based business applications platform that combines components of customer relationship management (CRM) and enterprise resource planning (ERP), along with productivity applications and a suite of cognitive services. Dynamics 365 was built on the industry-leading Azure cloud platform and tightly integrated with Office 365, Power BI, and the continuously evolving Microsoft Power Platform. 54% percent of Fortune 500 companies use Dynamics 365.

2.2 Contact Person The name, address, telephone number, and signature of a contact person familiar with the document.

Frank Banda, CPA, PMP, CFE, CGMA Managing Partner – Public Sector CohnReznick LLP Engagement Partner 7501 Wisconsin Avenue, 400E Bethesda, MD 2018 Office: 301-280-1856 Cell: 240-461-7002

Neutrality and Independence

3.0 Neutrality and Independence 3.1 Impartiality, Conflicts of Interest Determination, and Continuous Conflict Monitoring We are independent and have no financial interests with program stakeholders in accordance with FCC requirements. All team members have certified their compliance with these requirements. We will utilize and make public an Independence Management Plan and Code of Conduct throughout the program to ensure that we avoid any appearance of conflicts in the provision of our services. The Independence Management Plan will establish practices for the identification and mitigation of Organizational Conflicts of Interest (OCI). The primary objective of the Independence Management Plan would be to implement practices specifically to ensure that the Clearinghouse remains impartial. The Independence Management Plan would: (1) identify and properly disposition for any potential OCI that may arise, and (2) prevent the inappropriate flow of information into or out of the Clearinghouse that might otherwise serve to provide an unfair competitive advantage or bias. The Independence Management Plan will govern the conduct of all employees and consultants working as part of the Clearinghouse and these individuals will be required to sign a Code of Conduct. All Clearinghouse Team members will fully comply with applicable law, regulations, and professional standards governing OCI. 3.2 Transparency – Fair and Transparent Operations We recognize that the C-band Relocation involves many sensitive issues with far-reaching public interest and commercial ramifications. To ensure that we operate the Clearinghouse in a fair and transparent manner, we will implement an Independence Management Plan. The Independence Management Plan will define the Clearinghouse’s approach to maintaining its independence in the C-band Relocation and assure the independence of its decision-making process. The Independence Management Plan would address the Clearinghouse’s organizational and leadership structure of maintaining independence, establish procedural safeguards for ensuring compliance with all applicable provisions of law, the FCC’s rules and regulations, and ensure that its decision-making process is impartial. Independence and impartiality of the Clearinghouse is critically important to the success of the C-band Relocation program. We will therefore require each member of the Clearinghouse Team to institute a Code of Conduct to promote such independence and impartiality. The Code of Conduct would be applicable to all employees and consultants working as part of the Clearinghouse and will require each member of the Clearinghouse Team to establish internal procedures to identify, resolve, and where necessary disclose, potential conflicts of interest concerning stakeholders of the C-band Relocation. The Code of Conduct will also address the handling of sensitive information, prohibition from investments in the C-band Relocation stakeholders, prohibition from accepting gifts or entertainment with the stakeholders, and any other activities that could impair impartiality and independence. Specific transparency measures that we will implement include: Systems and Processes - During the start-up of the Clearinghouse, we will engage with the C-band stakeholders to establish cost eligibility standards that are consistent with the Report and Order and the Cost Catalog, and the systems and processes for submitting claims. We will also implement Coupa as our claims processing portal and payment solution. This system will allow incumbent space station operators and incumbent earth station operators to establish accounts, submit claims, and check on their status—providing transparency into claims and their payments. Reporting - From inception of the Clearinghouse, we will work with and advise the FCC on a mutually agreed upon schedule and format for key reporting, including quarterly progress reports. This will help in providing centralized visibility into project tasks, goals, and other details while making this information accessible to key stakeholders at every stage of the project. We anticipate that such reporting would account for all C-band

Relocation revenues and costs. This will include amounts billed, collected and receivable from overlay licensees; reimbursement claims processed and paid and payable; costs of the Clearinghouse and the Relocation Coordinator. These reports will be prepared monthly and available to the C-band stakeholders. Detailed Project Plan – We will develop a detailed project plan that describes what we are doing and when we are doing it (Detailed Project Plan). It will include all significant activities needed to accomplish major milestones and deliverables, their durations, and their due dates. The Detailed Project Plan will be updated on a monthly basis. Project Performance Dashboard – We will develop a project performance dashboard (Dashboard) that visually tracks, analyzes, and displays key performance indicators (KPI), metrics, and key data points to monitor our performance. We will use Microsoft PowerBi to produce the Dashboard that will be updated each day to show our progress. The Dashboard will include relevant performance information including: the population of incumbent space station operators and incumbent earth station operators, status of relocations, claims received, claims paid, claims turnover ratio, work in progress, ADR proceedings, and other relevant operational information. Quality Assurance - We will implement a quality assurance function. We will test our systems and processes to confirm the quality of the work and whether we are following our policies, procedures, and processes and test the quality of the decisions we are making in processing claims. Our quality assurance group will prepare reports with findings and recommendations for improvement. These reports will be made available to the C-band stakeholders.

Financial, Accounting, Auditing, and Industry Expertise

4.0 Financial, Accounting, Auditing, and Industry Expertise 4.1 Communications Industry Experience Our Team brings multi-disciplinary experience and expertise that is all encompassing with regard to the scope of the C-band Relocation. We have long-term, broad-based experience in the legal and technical aspects of the communications industry, which fully supports our qualifications to serve as the Clearinghouse.

4.1.1 800 MHz Transition Administrator Experience Our Team has participated in many large-scale government programs, representing national, state and local governments as well as private sector interests. CohnReznick and Squire Patton Boggs played integral roles in the 800 MHz Reconfiguration. Squire Patton Boggs is General Counsel to the Transition Administrator that manages the reconfiguration effort pursuant to the FCC’s 2004 Report and Order. The 800 MHz Reconfiguration affected more than 2,100 public safety and private wireless radio systems, such as those used by police, fire fighters, and emergency medical technicians. The 800 MHz licensees that have reconfigured or are in the process of reconfiguring are located in all 50 states, the District of Columbia, Puerto Rico, the US Virgin Islands, and Guam. FCC Experience Overview: The Transition Administrator was selected by a committee Client: 800 MHz Transition Administrator consisting of industry and public safety experts and charged by Role: Auditor and General Counsel the FCC with oversight of the largest spectrum reconfiguration Duration: 2005-Present program undertaken by the agency and is, as such, directly Key Responsibilities: and uniquely relevant to the qualifications for the • Program Financial Statements and GAGAS Clearinghouse. A number of the prescribed responsibilities of Audits the Clearinghouse match those performed during Squire • Program management Patton Boggs’s 15-year tenure with the Transition • Alternative Dispute Resolution Administrator. The Transition Administrator is responsible for • Special Master administrative and financial aspects of the 800 MHz • FCC Reporting Reconfiguration Program (Program) subject to the FCC’s • Reconfiguration Contract Review guidance and oversight. The Transition Administrator works • Implementation Coordination, Outreach and directly with Sprint and all licensees affected by the 800 MHz Monitoring Reconfiguration to ensure that reconfiguration is achieved with • Operating Agreements minimal disruption to licensees, particularly public safety • Frequency Management • entities. To effectively perform its duties, the Transition Management • Letter of Credit Management Administrator assembled a multi-disciplinary team that • Fraud Waste and Abuse Deterrence and included program managers, accountants, auditors, lawyers, Detection public safety subject matter experts, and frequency engineers. Program Financial Statements and GAGAS Annual Audits CohnReznick performed the annual and inception-to-date financial audits of the 800 MHz Reconfiguration Program expenditures from 2005-2017. We conducted audits in accordance with mandates imposed by the FCC, as well as the standards for financial audits conducted in accordance with Generally Accepted Government Auditing Standards (GAGAS). The 800 MHz Program expenditures encompassed the following categories of costs: 1) 800 MHz Incumbent Reconfiguration Costs; 2) Sprint Internal Relocation Costs; 3) Letter of Credit Carrying Fees; and 4) Transition Administrator Fees and Expenses. In addition to financial audit services, CohnReznick reported on the Program’s internal controls and compliance with the provisions of relevant laws, regulations, contracts, and other agreements, as required by GAGAS. Procedures included substantive tests of evidence supporting the expenditures incurred and direct confirmation of expenditures through correspondence with selected program stakeholders, creditors, and financial institutions. Additional procedures performed pertained to tests of internal controls, compliance with laws, regulations, contracts and other agreements, such as the FCC’s Report and Order Improving Public Safety Communications in the 800 MHz Band, Letter of Credit Agreements, and cost allocation methodologies.

Audit objectives, scope, and methodologies were developed using a risk $2.8 Billion Audited and control-based approach. Where the audit methodology relied on management internal controls - observation, inspection, and re- performance were the primary procedures performed to evaluate the Audited 65,000 Program-Related design and operating effectiveness of internal controls. All substantive testing was performed to determine whether the expenditures incurred were reasonable, allowable, and allocable to the Program and if Sprint ~2,800 Audit Hours/Year complied with relevant laws and regulations under the Program. Specifically, CohnReznick’s audits included the following procedures: Planning Activities • Conducted annual entrance conference meetings with the Transition Administrator and Sprint personnel to discuss the audit scope, objectives, and administrative items; • Conducted walkthroughs over the Transition Administrator’s and Sprint’s processes and internal controls to gain an understanding and develop preliminary audit procedures; • Reviewed relevant laws, regulations, contracts, and other agreements to gain an understanding of compliance requirements; • Conducted risk assessments • Evaluated the risk that fraud, waste, and/or abuse have occurred or are likely to occur; and • Finalized audit procedures and develop audit programs for each major area of testing, which accounted for 14 major audit areas. Fieldwork Activities • Performed substantive controls and compliance testing in accordance with the audit programs; • Verified physical existence of 800 MHz equipment; • Made direct confirmation of expenditures and certain other assets and liabilities by correspondence with selected program stakeholders, creditors, and financial institutions; and • Evaluated and document the audit results, findings, conclusions, and recommendations. Audit Report Activities • Conducted annual exit conference meetings with Transition Administrator and Sprint Management to present the audit results, findings, conclusions, and recommendations; • Issued Independent Auditor’s Report on the Statement of Program Expenditures in accordance with GAGAS, equating to 11 audit reports issued since 2006; and • Issued Independent Auditor’s Report on Internal Control over Financial Reporting and on Compliance with applicable laws and regulations, equating to 11 reports issued since 2006. CohnReznick successfully audited $2.8 billion – the estimated amount that Sprint would have to spend to effectively complete the reconfiguration process. We audited over 65,000 program-related payments. The annual audit hours averaged 2,800 per year, utilizing approximately five full-time employees. CohnReznick’s management team remained on the project since its inception. CohnReznick was dedicated to providing consistency and continuity of the team members assigned to the engagement, which translated into audit efficiencies and deep historical knowledge of the program. General Counsel and Alternative Dispute Resolution Squire Patton Boggs serves as General Counsel to the Transition Administrator and reports to the FCC’s Public Safety and Homeland Security Bureau (PSHSB). Squire Patton Boggs is responsible for all legal and regulatory matters associated with the approximately $4 billion spectrum reconfiguration, including the structuring and management of an ADR process that has successfully resolved approximately 5,000 reconfiguration-related disputes, many of which involved cost-recovery related issues, over the last 15 years. Squire Patton Boggs has resolved 98.74% of all cases without the need for a PSHSB decision.

As General Counsel, Squire Patton Boggs represented the Transition 15 years as General Counsel for Administrator before the FCC and prepared and reviewed all documents Transition Administrator provided to 800 MHz band licensees. In the 800 MHz Reconfiguration, Nextel (later Sprint) was obligated to negotiate with all relocating General Counsel for ~$4 Billion licensees for payment of all reasonable expenses of band Spectrum Reconfiguration reconfiguration. Licensees were entitled to receive “comparable facilities.” Both the reasonableness of licensee costs and the issue of Resolved ~5,000 Reconfiguration- comparable facilities were the subject of a large majority of the 800 MHz Related Disputes disputes. The Clearinghouse likewise is charged with the responsibility to resolve disputes with licensees regarding both costs and comparable Resolved 98.74% of all cases facilities. Much like the Report and Order, the Commission’s 800 MHz without need for a PSHSB decision Orders and rules established the overall framework and standards for ADR but delegated to the Transition Administrator the responsibility for implementing and conducting the dispute resolution process envisioned by the Commission. Key Transition Administrator responsibilities include: Program Management Squire Patton Boggs works with the Transition Administrator team members in managing this large-scale nationwide program. Squire Patton Boggs has participated in the development and on-going oversight of Transition Administrator policies and processes to ensure compliance with FCC and 800 MHz Reconfiguration requirements. These include an Independence Management Plan, Confidentiality Policy, Communications Policy, and a Records Policy, among others. Alternative Dispute Resolution Squire Patton Boggs developed a unique, flexible, and scalable ADR approach for the Program that combines elements of both mediation and arbitration. They created a foundational document for the Program styled as its “ADR Plan” that provided all stakeholders fair notice of the procedures and policies to be utilized in dispute resolution. The ADR Plan also addressed the role and responsibilities of mediators, the management and procedures governing the handling of disputes (both joint and ex parte sessions), burdens of proof, relaxed evidentiary standards, the confidentiality of disputes, the contents of the record and recommended resolution of disputes, and, above all else, due process for the parties involved. To ensure that the ADR process was scalable, Squire Patton Boggs assembled and trained a core group of mediators at the outset of the Program. The mediator training included a Mediator’s handbook and instruction on the requirements and standards prescribed by the Commission’s 800 MHz orders, other Commission rules likely to be implicated in any disputes, the systems and technologies used by licensees in the 800 MHz band, and the unique combination of mediation and arbitration in the ADR process envisioned by the Commission. Many of the mediators who participated in the 800 MHz rebanding will be available to assist in the resolution of C-band disputes.

Special Master Squire Patton Boggs serves on the Transition Administrator’s leadership advisory group responsible for providing advice regarding the Transition Administrator’s performance of its duties and obligations under the Program. The work highlights their quasi-governmental role as they serve as a Special Master in administrating the 800 MHz Reconfiguration. In this capacity, Squire Patton Boggs frequently interacts with FCC officials and staff.

FCC Reporting Squire Patton Boggs coordinates the Transition Administrator’s communications and meetings with the FCC and drafts and reviews monthly, quarterly, and annual reports.

Reconfiguration Contract Review Squire Patton Boggs’s activities have included the review of approximately 2,700 agreements between licensees and Sprint, including Planning Funding Agreements and Frequency Reconfiguration Agreements (Agreements), for compliance with Program requirements. These Agreements have a contract value in excess of $1.22 billion. In that capacity, Squire Patton  Boggs has worked with many public safety authorities throughout the US in understanding their budget and approval requirements and other relevant state laws and regulations.

Implementation Coordination, Outreach, and Monitoring Squire Patton Boggs has collaborated with the Transition Administrator Team Members in preparing and conducting 52 regional implementation-planning meetings attended by more than 700 public safety licensees, meetings that were designed to assist licensees in completing the reconfiguration of their systems in a manner that avoids disruption to public safety communications and preserves the interoperability of those systems. Squire Patton Boggs assists with Program outreach activities and regularly responds to inquiries from affected public safety licensees.

Operating Agreements The operating authority of the Transition Administrator was provided in the FCC’s Orders regarding the Program. Squire Patton Boggs is responsible for all legal and regulatory matters associated with the Transition Administrator and its operations, including drafting and negotiating the Transition Administrator’s operating agreement, all agreements among the Transition Administrator Team Members, and all agreements to which the Transition Administrator is a party.

Frequency Management Squire Patton Boggs works together with the Transition Administrator’s frequency management team in identifying frequency assignments for reconfiguring licensees, overseeing the necessary FCC licensing activity related to the addition of new, and deletion of old, frequencies, reviewing the clearing of frequencies to make available reclaimed spectrum capacity for new uses, and responding to and resolving frequency conflicts when and as they arise.

Financial Management Squire Patton Boggs participates with the Transition Administrator Team Members in the financial management of the Program. Financial management includes the implementation and on-going monitoring of a payment process to ensure that licensees are reimbursed the costs of their reconfiguration in a timely manner, as well as the review of the actual cost support documentation verifying that costs were properly incurred.

Program Financial Statements and GAGAS Annual Audits Squire Patton Boggs works closely with the finance team in the preparation, review, and issuance of the required annual Program financial statements and audits.

Letter of Credit Management Squire Patton Boggs consults with the Transition Administrator Team Members regarding the on-going management of the Letter of Credit (LOC) required of Sprint to secure the fulfillment of its programmatic financial obligations. The LOC was initially estimated at $2.5 billion.

Fraud, Waste, and Abuse Deterrence and Detection Squire Patton Boggs has crafted both outward facing and internal controls to deter and detect Program fraud, waste, and abuse. The firm reports non-frivolous allegations to the FCC and the Program auditor.

4.1.2 Communications Industry Expertise – Intellicom Introduction

Intellicom is a consulting corporation specializing in satellite and wireless telecommunications systems engineering, regulatory and spectrum consulting, project management, and operational aspects of broadcast and two-way communications systems. The company’s strength is its ability to apply highly technical skills and operational experience in a hands-on approach to problem solving and project execution. The technical team assigned to the Relocation Payment Clearinghouse (Clearinghouse) will consist of individuals providing continuous support to the Clearinghouse activities as well as industry advisors that can be called upon as needed. Intellicom’s technical experts are seasoned professionals, each with over to 30 years of professional experience, that possess telecommunications experience with satellite and terrestrial operators, manufacturers, user groups, industry associations, and universities. Intellicom has a deep bench of professionals capable of providing expert telecommunications services in support of the Clearinghouse duties. Their approach to staffing considers the skillsets required, the relevant experience, and technical knowledge to complete the tasks associated with Clearinghouse operations to ensure smooth and efficient progress. Intellicom will assign work based on the nature of the technical expertise needed and the level of experience required to successfully address any technical issue, as it becomes relevant. In addition, Intellicom is experienced in securing additional resources, as needed, and integrating Field Communications Testing them effectively into our Team.

Select examples of the extensive work performed by technical members of Intellicom, both with Intellicom and with other reputable organizations, are presented below under “Examples of Experience of Intellicom’s Technical Team.” Intellicom will provide satellite engineering experience to address all satellite communication technical issues and program nuances that may arise in processing reimbursable relocation claims. Intellicom’s satellite communications experience is extensive as they have performed projects throughout six continents. Their engineers remain up-to-date as Intellicom continuously researches spectrum management policy/law, ITU and WARC briefings, and satellite and terrestrial frequency coordination. Intellicom works directly with the customers providing design, integration, and verification services leading to superior satcom systems while reducing the overall cost of the system. The Intellicom team has experience working with satcom antennas ranging from 0.3m up to 17m. Their experience with unique implementation or integration gives us great insight to what needs to be accomplished. Intellicom has designed and deployed communication networks of all types. Past performance includes working with equipment providers, telecommunication carriers, wireless carriers, Fortune 1000 corporations, radio and television production and distribution, cable head-end operators, mobile broadcast and disaster recovery vehicle operators, marine vessels and offshore oil rig operators, VSAT operators, quick deployment and government/NATO operators and information data/internet carriers. Intellicom has developed verification and certification plans for terminals operating on the military (WGS ARSTRAT, XTAR and DISA), and commercial (Intelsat, SES, Telesat, JSAT, MEXSAT and Inmarsat) satellite systems. Intellicom’s automated processes and procedures ensure reliable and efficient results. Since 2004, Intellicom has been working directly on SATCOM-On-The-Move programs which use sub one-meter antennas. As part of our support, Intellicom has been working closely with the FCC and NTIA to obtain Mobile Earth Station approval for “non-compliant antennas” which do not meet gain requirements but are used in

systems that do meet power spectral density (PSD) limits. Through this work, Intellicom has gained insight as to the innerworkings of the FCC licensing processes. From 2015 until present, Intellicom has supported the effort to integrate, test, and verify six major gateways ranging from 9 to 16 meters. These terminals are operating at frequencies from 1 to 31 GHz. These gateways are complex; with over 100 modems and/or encoders/decoders that are combined/multiplexed and transformed to an RF carrier over fiber or coaxial transmission lines. Over the past thirty months, Intellicom has worked on a new technological approach towards using laser communications on aircraft to form a fiber network in the sky at 30,000 feet. Tests were conducted on the ground and inflight using two 767 aircraft with antennas mounted to the aircraft. Intellicom staff provided RF propagation and fade/scintillation and low-profile antenna design concepts to meet the airborne-low-temperature-high- altitude requirements. Intellicom will provide an unbiased and impartial approach. Intellicom is completely independent, has no ties to manufacturers or integrators, doesn’t sell hardware or software, and doesn’t accept “finder’s fees” or vendor commissions. The following information demonstrates the technical expertise of Intellicom with respect to satellite technology, programming and Multichannel Video Programming Distributor (MVPD) technology, broadcast technology, cable headend and MVPD distribution, satellite distribution, and earth station reception.

4.1.2.1 Satellite Technology Capabilities Intellicom’s professionals are experienced in satellite systems architecture, spectrum planning and licensing, space station design, link budgets, hub/teleports, user ground station design (large, small, ground, maritime, airborne, fixed, mobile), RF design, development, procurement and verification. The following are examples of projects and work that our engineers and technical experts completed. Examples of Experience of Intellicom’s Technical Team OneWeb: Provided RF and systems engineering in support of a low earth orbiting Ku and Ka band satellite constellation. Provided support on the PDRs and CDRs for transmission systems, interference assessment across all bands, regulatory support, and field RF analyses. Satellite Antenna Pattern Testing Iridium, Celestri, Teledesic: Provided system and space station architecture, ground station design, routing protocols, +software, development, procurement, verification. Palapa B Satellite: Designed and developed space qualified circulators and channel filters. Orbital Arc Utilization: Led INTELSAT’s effort to reduce orbital spacing of its satellites in the Indian Ocean. The models developed took into consideration off-axis earth station antenna pattern discrimination, satellite beam gain contours, relative carrier EIRP densities to earth stations of different receiving aperture, required link margins, etc. As a result of this study, INTELSAT was able to reduce the orbital spacing of its satellites in the Indian Ocean from 3 degrees to 2 degrees thereby permitting an additional satellite to be deployed in the region to meet increasing demand for telecommunications services in the region. Please note: This work was performed 10+ years ago and is not a current relationship. High Fidelity Satellite Capacity Computer Modeling: Developed and evolved INTELSAT’s STRIP modeling program which optimized transponder carrier loading. The program used actual carrier loading plans of co- frequency transponders, inter-beam isolation, TWTA non-linearity effects, transponder amplitude and group delay characteristics and adjacent satellite frequency plans (when known) to derive optimal transponder loading plans. Please note: This work was performed 10+ years ago and is not a current relationship.

International Standards Development: Participated for several years on the committees of the European Telecommunications Standards Institute (ETSI) for the development of cost effective VSAT performance standards. Earth Station Standards: Responsible for authoring internationally recognized INTELSAT IESS earth station standards. Authored a number of new C and Ku band earth station standards still in use as well as modernizing existing standards to reflect new performance requirements defined by ITU. Please note: This work was performed 10+ years ago and is not a current relationship. Earth Station Licensing: Performed licensing activities on a regular basis. Licenses cover mobile, airborne, and fixed earth station services. Intellicom’s engineers worked at Comsearch and worked on spectrum licenses for Telesat, Canada. Worldport Communications: Responsible for teleport engineering and design for Washington DC area teleport consisting of multiple large C and Ku band antennas, MCPC encoding and multiplexing, occasional use and fixed uplinking services, including rain diversity site and interconnect link. Teleport Appraisals: Performed thorough and comprehensive formal appraisals for the following teleports. These included design analysis, equipment asset estimates, business potential estimates, resale value estimates, and upkeep/maintenance/restoration costs:

• Pittsburgh International Teleport, Pittsburgh, Pennsylvania • Glenwood International Teleport, New Jersey • Cedar Hill Teleport, Dallas, Texas • GEOEYE Teleport, Norman, Oklahoma • Fisher Teleport, Vashon Island and Seattle, Washington • Broadstream Teleport, Vashon Island Washington • Washington International Teleport, Alexandria, Virginia

SPSC: From 1983 through 2001 designed and implemented 13 different teleports for Southern Pacific Satellite Company, located in the continental US and Hawaii. These facilities each included multiple large (>13 m) C and Ku band earth stations, TDMA and international video and voice access. AMSC: Responsible for initial design and sustaining engineering design of AMSC’s hub teleport in Reston Virginia, including shared tenant services and mobile satellite services, and diversity interconnect. Steele Valley: Called in to perform technical inspection for a major West Coast teleport (Steele Valley) to determine design improvements and improve reliability. GTE Corporation: Performed all engineering for 5 Teleports owned by GTE Corporation and providing voice and video services within the United States. Military WGS Earth Station Certification: Verified over 15 WGS earth stations including large (16m), small (0.5m), ground, maritime, airborne, fixed, mobile, phased array.

4.1.2.2 Programming and MVPD Technology Capabilities The capabilities of Intellicom’s professionals include development and deployment of programming and MVPD technology, including video codecs, compression, multiplexing, and modulation formats. Examples of Experience of Intellicom’s Technical Team

Digital Video Technology Development: Led the INTELSAT Technical Laboratory (the Laboratory) until 2008. The Laboratory is a world leader in evaluating and setting satellite RF channel performance requirements for the use of key digital video techniques over a satellite channel. Please note: This work was performed 10+ years ago and is not a current relationship. Video Codec Compatibility: The Laboratory was instrumental in achieving early inter-operability of MPEG2 and MPEG4 video codecs from different manufacturers by sponsoring inter-operability testing events. As a result of this work an “INTELSAT Mode” video data rate and compression was set that all codecs operating over INTELSAT needed to demonstrate inter-operability using a standard codec established by INTELSAT. This greatly facilitated the adaption of the use of these MPEG standards for transmission of video over satellites. Please note: This work was performed 10+ years ago and is not a current relationship. Video Compression Performance Over Satellite Channel: Led investigations of the effect of satellite channel impairments on the performance of video compression algorithms. Video Statistical Multiplexing: Evaluated the performance requirements for the use of statistical video multiplexing over a satellite channel. Use of Higher Order Modulation Formats: Intellicom team members evaluated the use of higher order QAM modulation techniques employed with video multiplexes to assess the potential of increasing transponder channel capacity. Furthermore, one of its technical advisors (Fred Harris) has authored many papers on this subject including a paper on “MULTIRATE ALL-DIGITAL MODEM FOR SUPPORT OF UNIVERSAL MULTIPLEX TRANSPORT LAYER FOR DIGITAL COMPRESSION.” ESPN: Assisted ESPN in the design and development of their new C-Band Teleport in Bristol, Connecticut. Provided a site payout for 20+ 9-meter transmit-receive earth stations, 1 multi-sat Torus antenna, and numerous 4-5m C and Ku-band receive only terminals. Provided civil engineer in designing the grounding systems and electrical, performed RFI measurements at C-Band and supported the frequency coordination of the site. Assisted with the earth station systems design, examined link analyses and transmission plans. Discovery: Assisted Discovery in the design and layout of their Sterling, Virginia C- Band Ku-band teleport site. Analyzed several sites in the northern Virginia area before deciding upon current location. Provided RFI measurements and resolution of interference cases. Provided earth station systems design support for five (5) 9- meter C-band earth stations. Assisted in the development of the site equipment and installation RFP and the selection of the winner. CTIA: Provided an in-depth analysis of the C-band use. Analyzed C-band transponder occupancy by type. Provided cost estimates for transmit-receive and receive-only earth stations. Examined current state of C-band filter design and cost and options for narrower and higher cut-off designs. Examined current state of video encoding and possibility of HEVC use going forward. Examined C-band transmission methods and ways to improve upon them. Performed comprehensive examination of current CONUS satellite systems and possibility and benefits to include additional satellites in unused orbital slots. Please note: This work ended in 2018 is not a current relationship. Public Broadcasting Service (PBS): Provided systems and RF engineering design for PBS for sustaining engineering of their Satellite Uplink Center in Bryn Mar, Virginia, from which all PBS programming is uplinked or relayed. Sirius XM: Supported design, deployment, and initial operations aspects for SXM’s broadcast, satellite and terrestrial repeater networks. Managed various stages of deployment and operation of SXM’s digital audio broadcast technology. Supported management of satellite teleport design, costing, and installation. Coordinated terrestrial repeater installations, maintenance and site-specific interference mitigation strategies.

4.1.2.3 Broadcast Technology Capabilities The capabilities of Intellicom’s professionals include experience with video, audio, and data broadcast services. Examples of Experience of Intellicom’s Technical Team Intellicom’s experience in digital video includes all aspects of technology, standards, and implementation issues, including:

• Assisted customers currently operating analog NTSC or PAL networks in conversion to digital compression, normally accompanied by a transmission network expansion permitted by the more efficient digital techniques. This conversion involved MPEG/ DVB systems, DTV (HDTV and SDTV) systems, or lower data rate H.320 and MPEG-4 systems. • Supported customers in choosing between MCPC or SCPC systems, including backhaul considerations. • Evaluated encoder and decoder products for specific applications. • Performed interface compatibility assessment with existing subsystems, such as storage, production, post, routing and switching. • Supported the selection of the conditional access system, subscriber management system, program guide (if required/desired) and network management system. • Resolved implementation issues such as forma t conversion, editing, and tandem encoding, as well as the need for receive terminal upgrades (such as LNBs, antenna sizes, etc.). • Prepared procurement documents such as statements of work, specifications, and test plans. • Functioned as program manager for the conversion effort at customer sites, including pre-conversion site surveys and database updates. PBS: Provided technical calculations for DBS satellite capacity and facilitated discussions with DirecTV regarding local-local service.

• Provided procurement support including the procurement of satellite resources: 8 transponders on two satellites for 8-year lease, the sale and management of transponder assets. • For broadcast operations, provided the procurement and implementation of a non-linear editing capability. • Provided operational support to the operations centers and performed operations analysis of TOC and SOC and provided recommendations for changes that would result in increased reliability and reduction in on-air discrepancies. • Developed the SOPs for the operations centers. • Implemented a DVD carousel playout system at the SOC and NET backup sites for disaster recovery of video sources. • Provided the design for the wholesale upgrade of the video sync system for broadcast operations. • Assessed low-cost IRDs for C-band frequencies. • Supported the planning of next generation distribution systems. • Engineered the DBS satellite capacity requirements and facilitated discussions with DirecTV regarding local-local service. • Served as the primary contractor for the design and installation of satellite television receive and distribution systems on Guam and American Samoa and a television relay facility in Washington State serving the Pacific islands, which they furnished, installed and turned up. Discovery: Provided numerous engineering services to Discovery including assisting in deploying cable programming network into cable head-ends nationwide.

• Interfaced cable billing systems and program trafficking system.

• Provided DTV technology assessment and next generation data services. • Key architects in the specification, design, and development of a national digital video satellite distribution system, providing pay per view programming and addressable advertising services. • Provided the specification and design of a multi-node file server-based video playback infrastructure, development several patent applications and served as the primary consultant in development and valuation of the patent portfolio. • Assisted with all RF acceptance testing at their primary and back up earth stations. Montana State PBS Network: Developed and implemented emergency plan to recover from no-notice bankruptcy of terrestrial microwave video distribution carrier, including obtaining encoding, transmission, satellite resources and receiving equipment to distribute Montana PBS signal throughout state. Developed RFP and specifications for encoding, multiplexing, and satellite uplink system and assisted with proposal evaluation and vendor selection as well as technical appraisal of available encoding platforms to meet video and data broadcast requirements. Nebraska Educational Telecommunications: Performed the needs assessment for statewide educational and broadcast television and videoconferencing network. Developed options mix of satellite/terrestrial facilities and optimized for mix of traffic. Included was a feasibility analysis of using ATM over fiber for STL. In addition, provided an assessment for an extensive statewide DS-3 distance learning network. Developed evaluated, priced, and recommended architecture for Next Generation Television Distribution System and presented our findings to the Nebraska State Legislature with excellent results. Oklahoma Educational Television Authority: Developed the RFP and assisted in transition from microwave to satellite distribution system, including procurement of satellite resources, digital video plant/equipment, and remote satellite to terrestrial translator equipment. Updated the satellite distribution system for HDTV and developed the specification and RFP documents. ESPN: Lead project and system engineering support in the feasibility studies and ultimate deployment of ESPN’s new multi-earth station teleport in Bristol, Connecticut. Provided design to allow ESPN to collocate all existing needed equipment in one location and provide for long term growth to meet all of their future needs. The facility design supported full Atlantic Ocean Region, domestic, and Pacific Ocean Region coverage using over 30 large C, Ku, and Ka band earth stations. Provided the design for the earth station layout, satellite arc clearance, RFI clearance, radiation hazard assessment, interfacility link layout, shelter layout, and earth station and shelter grounding design. California State University: Designed and developed the RFP for Broadcast Operations Center and uplink. We also designed satellite educational network for all California Community Colleges and provided the design architecture for interfacing to fiber optic terrestrial telecom, T-1 Telco, and satellite. Globo TV Network Brazil: Reviewed different digital video cable encoding manufacturers and made recommendations. TV Broadcasting Training Courses: Developed and provided classroom training in Digital Video Systems. Developed three unique course classes and have provided same to numerous customers. Association of Public Broadcasting Stations of New York (WNET et al): In conjunction with WCNY and WNET, developed RFP and specifications for new state fiber optic Wide Area Network (WAN) interconnecting its member stations for the exchange of IP encapsulated MPEG 2 digital streaming television over a new Gigabit Ethernet (GigE) backbone connecting the nine member stations of APBS. Assisted with the proposal evaluation and vendor Testing of Broadcast System selection for encoding, decoding, and network management systems for IP video distribution.

Corporation for Public Broadcasting: Designed in-building coaxial cable distribution system for television, radio and DBS programs. Dubai Internet City, Dubai, United Arab Emirates: Designed and developed the RFP for Major Television and CATV Broadcast Center. The design included the fiber optic interconnects from the Broadcast Center to the teleport facility. Our technical team also developed an RFP for procurement of a major new teleport. Alabama Public Television: Developed RFP and specifications for new video encoding, multiplexing, and satellite uplink and receive systems to distribute the state’s public television signal to eight terrestrial television transmitter sites throughout the state. BBC America: Conducted an analysis and survey of interactive data applications for enhanced television. WLAE/WYES Television Stations, New Orleans, Louisiana and WNIN Television Station, Evansville, Indiana: Project engineer. In this capacity designed, specified and sub-contracted for procurement of all equipment and services necessary to upgrade these TV stations to include a digital master control, video and audio ingest, effects, processing, multiple types of networked storage, production, format conversion and automated distribution. This included a complete analog to digital equipment conversion. Boeing Digital Xpress: Conducted extensive link analysis and recommended antenna size and transmission parameters for national business TV service using DirecTV technology. Also, evaluated the Network Management System design and alternative technologies, e.g., DVB- for digital content delivery.

4.1.2.4 Cable Headend and MVPD Distribution Capabilities Intellicom’s professionals are experienced in cable headend design and video distribution. Examples of Experience of Intellicom’s Technical Team Earth Station and Terrestrial Fiber End-To-End System Implementation: Intellicom was the principal architect of ground architecture for a classified US Government system consisting of a central hub earth station with connection to the Internet backbone using encrypted transmission over fiber optic terrestrial cables. Lindsay Electronics: Designed, developed, and verified cable TV distribution equipment – line amplifiers, splitters, system testing. Satellite Cable and Telco TV: Responsible for the design of all head ends and oversaw a team of engineers who designed these for satellite cable and telco TV operators around the world. MPEG-2, MPEG-4 codecs as silicon and thus set top boxes became available. Transition from conventional MPEG TS based solutions to integrate multiple channels into one. Design, installation, and commissioning of head end DISH service for Echostar. Design of the head ends deployed in various locations, for geo-redundancy, that provided the U-verse service from AT&T. President of MPEG industry forum, lead initiatives that created the way for MPEG-4 to become the standards-based successor to MPEG-2. At Harmonic, team designed products that enabled the transition from MPEG-2 to MPEG-4 using multiple codec capability. At Ericsson, led initiatives that brought next generation codec, HEVC to head ends around the world.

4.1.2.5 Satellite Distribution Capabilities Intellicom’s professionals are experienced with satellite distribution and video, audio, and data broadcast services. Examples of Experience of Intellicom’s Technical Team Polsat, Polish DTH Broadcast System: Designed and built a digital multi-channel video broadcast system providing over 30 channels of digital content for the largest DTH provider in Poland. The hub included a Ku-Band antenna system with a redundant RF system and a de-icing system operating over an Astra satellite. The headend baseband system included 36 digital encoders and over 44 IRD decoders. DISA Global Broadcast System (GBS): Performed systems engineering for DISA Global Broadcast system (GBS) update. The update was focused on the DVB-S2 technology integration with simultaneous upgrade of video encoding technology from MPEG2 to MPEG4 AVC. Directly involved in the video encoding efficiency evaluation, and providing inputs for RFIs and RFPs. Globecomm Systems: Designed DBS Broadcast Operations Center for India. GTE Government Systems: Proposed and evaluated different opportunities for getting involved in the DOD Global Broadcast System (government DBS). MCI: Evaluated and recommended a Conditional Access system for their new DBS SkyMCI business data broadcast service. Evaluated overall system requirements for SkyMCI service. Member Direct TV: In charge of all DBS technical and operational matters for this business TV network that uses the DirecTV satellite. CANCOM: Expert witness work involving DBS service to the Caribbean using off-air terrestrial US TV. Copyright and broadcast right related.

4.1.2.6 Earth Station Reception Capabilities Intellicom’s professionals are experienced with earth station design, development, deployment and verification for reception of single or multiple channels and distribution. Examples of Experience of Intellicom’s Technical Team See also Satellite Technology for additional experience. ESPN: Assisted ESPN in the design and development of their new C-Band Teleport in Bristol, Connecticut. Provided a site payout for 20+ 9-meter transmit-receive earth stations, 1 multi-sat Torus antenna, and numerous 4-5m C and Ku-band receive only terminals. Provided civil engineer in designing the grounding systems and electrical, performed RFI measurements at C-Band and supported the frequency coordination of the site. Assisted with the earth station systems design, examined link analyses and transmission plans.

CTIA: Provided an in-depth analysis of the C-band use. Analyzed C- band transponder occupancy by type. Provided cost estimates for transmit-receive and receive-only earth stations. Examined current state of C-band filter design and cost and options for narrower and higher cut-off designs. Examined current state of video encoding and possibility of HEVC use going forward. Examined C-band transmission methods and ways to improve upon them. Performed comprehensive examination of current CONUS satellite systems and possibility and benefits to include additional satellites in unused orbital slots. Please note: This work ended in 2018 is not a current relationship. Iridium Earth Station Testing PBS: Served as the primary contractor for design, and installation of satellite television receive and distribution systems on Guam and American Samoa and a television relay facility in Washington State serving the Pacific islands, which we furnished, installed and turned up.

4.1.2.7 Ability to Supplement the Team Intellicom can ramp up engineering support as the workload and or invoices submitted for review increase. Currently, 15 engineers are available to support this effort. If the workload were to double, Intellicom has the ability to add the resources to double the team. Intellicom had to provide this same type of effort for the Iridium project which had many subsystems that needed to be designed, built, and tested. For this project 15 engineers were assigned to different modules within the terminal and software adaptation. To further demonstrate this ability to scale, Intellicom designed an airborne wireless platform for a company named Airborne Wireless Network. This team had to develop the airborne antennas, RF, and Baseband equipment and provide demonstration support on two 767 aircraft. For another project, Intellicom worked in a town just north of Perth, Australia where they had to rotate staff members every 30 days for over four years for a multi-antenna system with a complex band system. The team was there to design the system, then test the major components and then take the complete three terminals through a full satellite certification.

4.1.3 Communications Industry Expertise – Dr. David Reed In this section, we provide information regarding the expertise on the CohnReznick team with respect to cable headend, MVPD distribution, and broadcast technologies based upon the relevant prior experience and qualifications of Dr. David P. Reed in the cable and communications industry in general, his contributions in the technology policy arena, his qualifications as a subject matter expert in technical cost modeling, and the focus of his graduate level coursework.

4.1.3.1 Experience in the Cable Television Industry and Communications Industry Dr. Reed has extensive experience in the communications industry and the cable television industry in particular. Dr. Reed worked in the cable television industry for almost two decades at Cable Television Laboratories, Inc. (CableLabs) during which time he held the senior management positions of Senior Vice President, Strategic Assessment, Chief Technical Officer, and Chief Strategy Officer. CableLabs is a global membership association made up exclusively of cable television service providers. One of Dr. Reed’s leadership roles at CableLabs was to incubate, manage, provide strategic advice, and communicate progress on industry-wide research and development (R&D) projects to CableLabs Board of Directors (which consisted of the CEOs of the largest member companies) and the senior management teams of its member companies. Dr. Reed’s CV provides a summary of many of the major R&D projects at CableLabs in which he played a role as technical contributor,

strategic advisor and/or senior executive for the project. To the knowledgeable observer of the evolution of the cable platform over the past 20 years, it is readily apparent that the overall breadth and importance of CableLabs projects have defined the end-to-end cable network architecture and infrastructure requirements of almost every key cable service and capability (e.g., digital video, broadband, VoIP, business services, wireless services, security, etc.). This includes the role of the headend node in the overall architecture. For example, the OpenCable project contained efforts to define new digital video interface and coding standards for the placement of interoperable digital video processing equipment in the headend. Likewise, the DOCSIS project established new interface specifications for routing equipment in the headend to better accommodate rapidly growing power and space requirements due in large part to the rapid growth of streaming video services. Another important role at CableLabs was Dr. Reed’s leadership of the Strategic Assessment Department in evaluating the strategic opportunities and competitive threats posed by new technologies to the cable industry. Dr. Reed oversaw the dissemination of between 50 – 100 such proprietary strategic assessments reports for the cable industry. While this work was proprietary, a general description of some these efforts can be provided to demonstrate the relevance of this work in establishing experience for the Clearinghouse effort. Useful examples in this regard include:

• Early on in the transition to digital video, CableLabs conducted market research on different video compression techniques adopted by MPEG in order to gauge consumer reaction to different compression profiles. • With the transition from analog to digital video, the industry needed an analysis of centralized and decentralized headend placement strategies based upon the costs and capabilities of digital video encoding and transport equipment (e.g., economic rationale for a Headend in The Sky approach for cable and satellite MVPDs). • Analysis of how different migration approaches for cable distribution networks from analog to digital video present a complex set of trade-offs between network capacity, placement of video processing equipment in the headend, picture quality, electronic guide capabilities, and set-top box costs. • Analysis of the migration to an “All IP” cable network platform, which includes a transition for cable operators from an MPEG-based transport approach to an IP approach which has implications for video processing and routing equipment placement in the headend, use of adaptive video streaming protocols, and fiber delivery using national backbones and content distribution network technology. • Comparative analyses of how digital video technology and IP transport can benefit each of the different MVPD platforms (cable, telco, DBS, broadcaster, wireless MMDS). Another of Dr. Reed’s roles at CableLabs that is highly relevant to the Clearinghouse was his skill at communicating complex technology-based issues to a wide range of audiences and managing meetings of senior executives within and across industries. Dr. Reed regularly briefed CableLabs’ Board of Directors and its Technical Advisory Committee (TAC - comprised of the CTOs of member companies) on highly-technical matters. Despite the large difference in areas of expertise of these two groups, he was successfully able to convey and, when necessary, gain consensus on solutions to highly-technical problems during Board and TAC meetings for the benefit of the cable industry. This experience extended beyond these groups, as it was not uncommon for Dr. Reed to present to other senior cable industry groups of Chief Marketing Officers, Chief Information Officers, or Chief Strategy Officers, or even at cross-industry meetings with consumer electronics manufacturers or Internet application providers, in order to inform and obtain input on CableLabs’ projects. In short, Dr. Reed has substantial experience providing technical information in a clear, accurate, and concise format that provides the “big picture” needed by decision makers to decide upon an option or formulate the next steps in their strategic plan. This skill set will be useful and put to task in the Technical Advisory Board for the Clearinghouse to gather input from interested parties. Based upon this set of accomplishments at CableLabs, it is clear that Dr. Reed has a deep and full understanding of the overall end-to-end cable distribution architecture, including an understanding of cable headend technology and equipment, as many of the project efforts set in motion under his leadership continue today.

4.1.3.2 Engineering Cost Model Expert Throughout his entire career, Dr. Reed has been a noted subject matter expert on the development and use of engineering cost models to assist in policy decision-making. Much of his research has relied upon the use of engineering cost models as a tool for policy makers to better understand the economic implications of different policy outcomes. Some notable public achievements in this regard include:

• Dr. Reed’s PhD thesis from Carnegie Mellon that was the first public engineering cost model, published as a book, estimating the cost of Fiber-to-the-Home networks to distribute voice, data and video services to residential consumers. This research helped establish telco/cable competitive policies such as the FCC’s Video Dialtone approach. • Dr. Reed authored an Office of Plans and Policy (OPP) Working Paper on the cost of deploying advanced cellular networks while working for the FCC.1 The Working Paper was submitted to the PCS docket for comment, and served as a pivotal contribution in support and justification of the ultimate band plan that the FCC adopted for the PCS spectrum allocation. • In 2013, Dr. Reed was asked by the FCC to review the engineering cost model they planned to use to evaluate support requests for the Connect America Fund.2 The peer review provided constructive, detailed feedback to the FCC regarding the Phase II implementation of the Connect America Cost Model that was then used to estimate the forward-looking deployment and operations costs of modern broadband networks. The report demonstrates Dr. Reed’s capability to provide expert knowledge on new technologies associated with emerging and innovative communications activities and serve as a technical authority to resolve unique and controversial problems related to telecommunications-related services.

4.1.3.3 Other Relevant Technology Policy Experience Throughout his entire career, Dr. Reed also has been a participant in several other important Technology Policy discussion topics. Some notable instances in this regard include:

• Prior experience as a Telecommunications Policy Analyst in FCC OPP as a team member to develop a spectrum band plan and design the first major auction of PCS spectrum to promote innovation, market efficiency, and entrepreneurship policy objectives. Dr. Reed served as the team’s “point person” on technical standards and preserving the policy objective of license flexibility by not including service rules to dictate a specific technical approach such as CDMA or GSM. • Dr. Reed presented to the Organisation for Economic Co-operation and Development (OECD) Working Party on Communication Infrastructures and Services Policy on “Satellite Broadband” in 2016. His talk addressed the question of what role satellite networks can have in deploying broadband services to unserved areas throughout the world by examining the emergence and implications of new Non- Geostationary-Satellite Orbit systems using low-earth orbits.3 This work demonstrated Dr. Reed’s capability to provide expert knowledge on new technologies associated with emerging and innovative communications and spectrum management activities, and providing the technical authority to resolve unique and controversial problems related to wireless telecommunication services. • Dr. Reed currently serves as Senior Fellow to the Silicon Flatirons Center for Law, Technology, and Entrepreneurship, at the University of Colorado Boulder Law School. In this role, Dr. Reed participates in the development and design of seminars and conferences for the Silicon Flatirons program which is a globally-preeminent forum for the discussion technology policy topics on spectrum management.

1 See David P. Reed. Taking It All Apart: The Cost Structure of Personal Communications Services, OPP Working Paper Series, No. 28, Office of Plans and Policy, Federal Communications Commission, November 1992. 2 See David P. Reed and Marvin Sirbu, Peer Review of the Connect America Phase II Cost Model at the request of Julie A. Veach, Chief, Wireline Competition Bureau, Federal Communications Commission. https://www.fcc.gov/general/peer- review-connect-america-phase-ii-cost-model, 2013. 3 See David P. Reed and Lauren Crean. OECD (2017), "The evolving role of satellite networks in rural and remote broadband access", OECD Digital Economy Papers, No. 264, OECD Publishing, Paris.

4.1.3.4 Relevant Teaching Experience and Qualifications Dr. Reed brings a unique and expert interdisciplinary knowledge to the technology, economics, and public policy issues that are likely to be addressed by the Clearinghouse. With 30 years of academic and industry experience in data networking, engineering economics, and the design of MVPD and broadband networks, Dr. Reed has qualifications and experience to teach several advanced courses for M.S. and PhD graduate students at the University of Colorado Boulder. These courses cover many engineering, economic, and public policy topics relevant to the Clearinghouse. As a key member of the proposed Clearinghouse team, Dr. Reed will draw upon this expertise to offer useful guidance and knowledge needed to solve the complex, interdisciplinary problems that will arise in the establishment and ongoing management of the Clearinghouse. Examples of the graduate courses and the relevant curriculum taught by Dr. Reed include:

• Principles of Internet Policy, (CYBR 4400/5400) Fall 2019 – Spring 2020 (updated curriculum of Principles of Telecommunication Policy, Spring 2013 – 2019). Course objectives include: 1) learning current research in telecommunications policies addressing key laws and regulations shaping Internet policies associated with net neutrality, broadband service availability, spectrum management for wireless services, cybersecurity, and privacy, and 2) applying an interdisciplinary policy framework to critically evaluate the efficacy of past and current policy initiatives in order to develop convincing and well- supported new policy recommendations.

• Spectrum Management (co-taught w/Dale Hatfield), (CYBR 5420) Maymester 2020. Course objectives include learning modern spectrum management techniques employed by policy makers, along with the current research, technologies and approaches in spectrum management that are shaping the emergence of critical 5G, Wi-Fi unlicensed, and fixed wireless and satellite broadband platforms.

• Data Communications, (CYBR 5010) Spring 2020. Course objectives include: 1) covering key concepts and technologies in data networks and systems, including layered architectures, network topologies, and the main components in computer networks such as routers, switches, servers, and end hosts, and 2) learning the functionalities of the different layers in the Internet protocol stack, as well as the basic concepts in the design and implementation of specific protocols in each layer, and how to use network monitoring tools to capture and troubleshoot network traffic, and gain an introduction to network programming to build network applications.

• Future of Video: Technology, Policy, and Economics, (TLEN 5380) Fall 2013 – 2015. Course objectives include: 1) understanding the core technologies, business models, and policy dilemmas that face the development and growth of the existing MVPDs (television broadcasting, cable, and satellite platforms), and 2) learning the state of development of the Internet video delivery platform including technical architecture, video coding and distribution techniques, proposed streaming business models, and policy issues.

4.1.4 Communications Industry Expertise – Supplemental Expertise Although the CohnReznick Team possesses the technical expertise necessary to fulfill the duties of the Relocation Payment Clearinghouse, we recognize that it will be important to include professionals in our team who have recently individually performed or directly supervised the types of transition work envisioned at earth stations/cable headends, particularly the replacing of IRDs, but also retuning, repointing, and filtering existing antennas, and installing new antennas, and we are willing to engage firms and individuals that possess that relevant and necessary expertise to supplement our team and complete the work.

4.2 Financial, Accounting, and Auditing Expertise 4.2.1 Financial Expertise CohnReznick’s provides financial expertise to CEOs and CFOs challenged to simultaneously drive corporate performance management, optimize the financial function, and identify and finance strategic growth initiatives. Our CFO Advisory and Business Transformation Practice helps executives prioritize these responsibilities by providing guidance by former CFOs that aligns financial and operational capability and risk management to business strategy. We help transform the financial function to actively support the strategic objectives of the company. We help executives and their teams strengthen their finance organization, reduce costs, and better manage working capital. We also help them improve performance planning and management, accelerate the financial close process, improve the quality and timeliness of financial information, and reduce accounting errors that impede effective and timely decisions. CohnReznick provides financial expertise and solutions to help executives address their business challenges at every stage of financial transformation. Whether it is assistance with preparing for an IPO, driving business transformation efforts, implementing an integrated business planning approach, or establishing lean financial processes, CohnReznick’s CFO Advisory professionals can help. The following is a summary of a case study for a large public company which acquired a mid-market entity where we were engaged by to onboard a recently acquired company that required financial management and CFO advisory services.

Case Study Background: Solution: Success: • Finance management and • Assess the initial accounting • Successful completion of accounting assessment landscape including processes, audited franchisor financial • Outsourced accounting model, staffing, IT infrastructure and statements manual dependencies related activities with operations • Captured the level of effort for • Comingled trial balances of various • Recreate multi-year GAAP key activities and identified the common ownership entities basis financial statements and root cause of constraints, • Issues with the timeliness and supporting schedules bottlenecks and delays accuracy of month-end close and • Stabilize and bring current the • Performed gap analysis and financial reporting activities financial reporting roadmap from current state to • Inefficient and manual burden of • Draft white paper accounting ideal future state recording, consolidating and policies and procedures • Transitioned company to a new reporting efforts • Purchase price allocation and outsourced solution once the • Lack of standardized and memo financial reporting was documented accounting policies and • Provided interim CFO services stabilized procedures, efforts were ad hoc • Assist in placing new CFO • Onboard replacement CFO

4.2.2 Accounting Expertise Accounting Services

CohnReznick provides clients with expertise and insight to • IPO Readiness navigate today’s challenging and complex accounting • SEC Reporting and Disclosures environment. While sound accounting practices are often • Outsourced Accounting mandated and the cornerstone to internal and external reporting • Audit Readiness needs, the complexity and pace of today’s environment demand • Technical Accounting more than technical skill. Increasingly, accounting professionals • GAAP/IFRS Compliance need to be multidimensional, strategically agile to anticipate • Accounting Standards Implementation evolving market conditions, regulatory requirements, emerging • Acquisition Accounting and Integration technologies, and the associated elements of risk. From • Financial Statement Preparation navigating complex business transactions, to treatment of new • Internal and External Financial Reporting accounting pronouncements and financial reporting, to managing • Financial Restructuring and Restatements

the day-to-day accounting function with limited resources, our accounting advisory experience has enabled our clients to make sound business decisions based on the best information available As a demonstration of our extensive and holistic accounting experience, the graphic below describes our experience providing outsourced accounting using Microsoft Dynamics.

4.2.3 Audit Expertise As a national Firm, CohnReznick performs over 15,000 audits annually. We have performed audit and consulting services for over 100 governmental entities over the past 25 years. This has provided us with the depth of knowledge, perspective, and insight into the issues that may arise during this engagement. CohnReznick has extensive experience conducting audits in accordance with the standards for financial audits contained in Government Auditing Standards (the Yellow Book) issued by the Comptroller General of the United States, the requirements of the Single Audit Act Amendments of 1996 (the Single Audit Act), and the provisions of Title 2 U. S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards (the Uniform Guidance). We have particular expertise auditing governmental and not-for-profit organizations receiving federal funds. Currently, CohnReznick performs more than 1,500 audits annually in accordance with Government Auditing Standards and 650 audits in accordance with OMB Uniform Guidance. Additionally, we audit over $4 billion in federal expenditures. As such, CohnReznick routinely participates in Quality Assurance Reviews from government oversight agencies, as well as internal and external SEC practice peer reviews. Every CohnReznick audit professional receives specialized audit training to meet the Continuing Professional Education (CPE) requirements of GAGAS. CohnReznick is experienced in conducting audits in accordance with auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards issued by the Comptroller General of the United States. In addition, we provide a full range of operational reviews, internal audit, and consulting services to government entities. Annually, we perform

financial, compliance, and performance audits in accordance with generally accepted auditing standards and guidelines set forth by: American Institute of Certified Public Accountants (AICPA), Government Accountability Office (GAO), Governmental Accounting Standards Board (GASB), and Federal Accounting Standards Advisory Board. CohnReznick prides itself on success and efficiency in audits of entities receiving government grants, awards, contracts, and other assistance.

Over 15,000 Audits Performed CohnReznick has received many accolades regarding our work in the Annually public sector. Many of our clients’ annual reports have received GFOA Certificate of Achievement for Excellence in Financial Reporting. Further, Over 1,500 GAGAS Audits due to our work in high-profile government engagements, having, for Performed Annually example, overseen more than $20 billion in federal grant funds in the aftermaths of Hurricanes Katrina, Rita, Dolly, Gustav, Ike, and Sandy, our Over $4 Billion Audited Annually previous experience has been subjected to intense public scrutiny. Our in Federal Expenditures programs and deliverables have been inspected by public officials, political appointees, State Attorneys General, Inspectors General, and the general public. Without fail, our programs and deliverables have withstood this intense amount of scrutiny time and time again. Our reports have not only withstood intense public scrutiny; they have been commended as excellent reporting examples within the Inspectors General community.

Financial Audits of Reconfiguration Expenditures – FCC CohnReznick’s significant financial audit experience includes its selection as the independent auditor of the 800 MHz Reconfiguration. In that role, CohnReznick performed the annual and inception-to-date financial audits of the 800 MHz Reconfiguration Program expenditures from 2005-2017.

Financial Audit Services Support – US Department of Energy Another notable experience of our financial audit work is the support we provide to the US Department of Energy (DOE). DOE is required to comply with statutory and regulatory audit requirements to ensure potential contractors and financial-assistance recipients, referred to as awardee(s), are capable of compliance with the terms and conditions of contracts, laws, and regulations, and financial viability. Consequently, to ensure the required audits are performed in a timely manner department-wide, DOE has a requirement for financial audit- services support.

215 92 102 176 Audits Completed Audits in Progress Work Orders to Date Resources Managed

The goal of these audits is to ensure actual proposed or billed/incurred costs funded or reimbursed by the government include only those costs that have been deemed allowable, reasonable, and allocable in accordance with appropriate cost principles and regulations. In addition, our responsibilities under this contract include providing professional audit advice on accounting and financial matters to assist in the negotiation, award, administration, repricing, and settlement of contract and financial-assistance awards and modifications. The audit scope for each project varies depending upon the assessment of the government requirements and need for audit; however, the scope may include audits of proposed/incurred costs, business systems, disclosure statements, evaluation of an awardee’s policies, procedures, controls, and actual performance, assessment of the awardees’ compliance with relevant cost principles, laws and regulations, and contractual terms and conditions, or may include only agreed-upon procedures for certain areas of proposals, business systems, or other assigned audit work.

4.3 Funds Managements; Collection and Distribution of Payments CohnReznick has significant experience managing public sector funds and performing claims agent services. Our experience includes managing both the receipt of the funds and their disbursement for claims. Our subcontractor Coupa will provide the claims processing platform and their experience is also included below. Public Sector Funds Management Since 2006, CohnReznick has administered, managed, and provided oversight of more than $40 billion of public sector funds. Our experience managing funds Administered over $40 includes: full program management and oversight of the distribution of federal Billion of Public Sector disaster recovery funds, establishing compliance and monitoring programs, Funds for MS, LA, TX, IL, developing and executing quality control and quality assurance plans, NY, and NJ since 2006 developing and implementing processes and procedures to prevent and detect fraud, waste, and abuse, developing and monitoring program performance metrics and reporting used to make program decisions and monitor progress. Funds Management – State of Mississippi To support hurricane relief assistance, CohnReznick provided program management and oversight of the distribution of federal disaster recovery funds for the State of Mississippi. We evaluated and processed over 40,000 homeowner claims and distributed over $2.5 billion with zero funds returned to the federal government at the end of the program. Over a three-year period, we implemented a full-scale disaster recovery solution through our program management approach. Within the first 75 days of the contract, we:

• Created a detailed program management approach that identified all major activities, resources needed, major milestones, and critical paths;

• Developed a grant application and applicant Program Management Approach guidebook that detailed eligibility criteria; • Developed standard operating procedures; • Align Policy • Standard Operating • Procedures • Implemented a grants management system; Public Outreach • Economic Impact • Guidebook • Established application intake centers and • Implementation • Customized Checklist application reservation system; planning • Compliance and • Hired and trained more than 300 local staff; and • Operational Monitoring of Federal, • Developed systems and controls to prevent and Production State, & Local Laws detect fraud, waste, and abuse. • Auditing • Development of Systems • Reporting to Ensure Program • Project Management Accuracy, Risk • Program Governance Management, etc. Grants Management – State of Texas • Quality Control • Data Collection Since 2013, CohnReznick has been managing the • Quality Assurance • Automated Processes FEMA Public Assistance program for the State of • Manual Exception Texas, specifically, Texas Division of Emergency Processes

Management (TDEM). Over the last seven years, we have managed and closed over 12,000 FEMA-funded grants and facilitated disbursement of nearly $3.5 billion to state and local governments and nonprofit organizations. Our work includes:

• Performing complex grant coordination, financial and programmatic compliance, technical assistance, and administrative work to respond, administer, organize, and monitor federally funded disaster grants; • Conducting applicant briefings and other outreach and training activities, ensuring grant applications are received and processed properly, and monitoring both the programmatic and financial aspects of awarded projects; • Ensuring deadlines are met, applications or other documentation are complete and correct before submission to federal authorities, and payment requests are promptly and correctly processed; • Conducting monitoring activities in accordance with the project-worksheet guidelines, verifying projects are completed within the approved scope of work, and identifying and resolving project and program related issues; • Reviewing progress reports and payment requests, and providing guidance and assistance to grant recipients on documentation requirements and resolution of project worksheet-related problems; • Performing budget monitoring and project site inspections, and documenting progress and/or completion of projects, causes for delays in project-worksheet completion from established timelines, or deviations from the scope of work to ensure procurement and contracting compliance; • Evaluating opportunities and requirements to provide technical assistance and assist local jurisdictions and state agencies in maximizing reimbursement potential; and • Ensuring compliance with federal, state and local regulations and ordinances.

2013-2017 Contracted by the Texas 2017 Texas Resolicited Public Assistance 2019 CohnReznick provides Grant Division of Emergency Management & Hazard Mitigation Contract Management & Closeout Services to • One of four vendors, to provide grant • Awarded as single vendor in March 2018, State of Texas monitoring and closeout services for post-Hurricane Harvey • 16 open Public Assistance programs Public Assistance and Hazard Mitigation • Absorbed workloads previously assigned under a “Pay for Performance” grants to three other vendors in just 1 year invoicing model • Responsible for “cradle to grave” sub- • Surpassed number of project closeouts • First contract/one-of-its-kind awarded recipient handling – compliance and processed more reimbursement in the disaster recovery industry. monitoring, project closeouts, payment requests than 2 previous years under the processing, and technical assistance. prior contract.

Claims Agent Services Expertise CohnReznick provides claims agent services both inside and outside of a court oversight process. We focus on obtaining the maximum value from assets and resolving residual financial issues and obligations. Our highly experienced professionals have successfully managed all aspects of claims processes in our roles such as Disbursing Claims Agent, Disbursing Agent, Plan Administrator, Liquidating Trustee, and Liquidating Supervisor. We have vast experience in:

• Performing claims reconciliation and prosecuting related claims objections; • Calculating creditor recoveries and respective distribution amounts; • Identifying, monitoring, and collecting of assets and amounts due the Trust; • Preparing and filing final tax returns and dissolution papers; • Establishing and maintaining a secure, web-based document management and review portal; and • Storing and transitioning essential records. CohnReznick has provided claims services in the capacities of trustee, receiver, and assignee, as well as consultant to trustees. We work closely with the parties to structure a plan that manages each critical component of a successful claims process by presenting the facts and accelerating the settlement process. Our professionals offer objectivity during the process and are accessible at all times to provide guidance and direction and to maintain communication with all necessary parties.

Select Claims Agent Service Experience CIBC World Markets Corp Irving Picard, Madoff Trustee CohnReznick is currently engaged to serve as the CohnReznick to provide services to Irving Picard in his Independent Distribution Consultants for Canadian capacity as the Trustee in the Madoff Bankruptcy case, the Imperial Holdings Inc. and CIBC World Markets Corp. largest reported Ponzi scheme in U.S. History. As part of Settlement Fund. Our role involves establishing creative the Trustee’s team in this historic and internationally and fair criteria for quantification of claims, identification of publicized case, CohnReznick’s principal role was to serve claimants, creation of claimant matrix as well as notification as a customer fund allocation accountant and consultant and distribution of claims to claimants. assisting with the accounting supervision of the payment of Continental Can Settlement Fund liquidation proceeds to the various beneficiaries. More specifically, CohnReznick performed the following: CohnReznick was retained by the Continental Can Audit of 1st Distribution – As the Trustee was preparing to Settlement Fund (the Fund) to perform various procedures make the first distribution in September 2011, we were to verify approximately $508 million in disbursements to the asked to complete an audit of each of the claims that would Fund’s 5,900 beneficiaries over the its 17-year life span. receive some form of payment as part of this first We reviewed and tested cash receipts, disbursements, and distribution. The Trustee wanted to ensure that every class member certifications to determine if approximately amount was correct and that each claimant receiving a 16,400 distributions were made in accordance with the final distribution was entitled to it. We were asked to ensure that requirements. all the required steps were completed to validate both the claim amount and the recipient of the claim.

4.4 C-Band Relocation Knowledge Familiarity with the Report and Order and Commission Rules All members of the Team have reviewed and studied the Report and Order in detail and are thoroughly familiar with the decision’s components and the applicable Commission rules, particularly as each relates to the roles and responsibilities of the Clearinghouse. Leading up to the adoption of the Report and Order, key members of the team monitored and reviewed filings in GN Docket No. 18-122, such as comments and ex parte submissions, as well as the FCC’s draft Report and Order to ensure an understanding of key issues involved in the Commission’s final considerations.

Since adoption of the Report and Order, the Team continued to review filings in GN Docket No. 18-122 and FCC releases and conducted a series of periodic discussions covering the various components of the decision and applicable Commission rules in preparation for submitting this document. These discussions have also included, where relevant, the FCC’s Public Notices, including a review and understanding of the Preliminary Cost Catalog. In familiarizing ourselves with the various requirements of the Report and Order and the FCC’s rules, our team drew on and was informed by extensive experience of key members from Squire Patton Boggs, extending back almost 40 years, with the Commission’s rules and rulemaking process, including with respect to spectrum allocation and reconfiguration proceedings and spectrum auctions. Below is an initial depiction of the Relocation Payment Clearinghouse Process as described in the Report and Order. The Team placed a special emphasis on the specific tasks and duties of the Clearinghouse and its interactions with other C-band stakeholders. We will use this workflow during our strategic planning and analysis; and assign project personnel, design and implement systems and processes. Below are the key components of the Report and Order: The Report and Order was written and adopted by the Commission due to the ever- growing demand for wireless broadband services and for radio spectrum. The FCC’s Report and Order reformed the use of the 3.7 to 4.2 GHz band by repacking existing satellite operations into the upper 200 MHz of the band and making spectrum available for flexible use. We are summarizing our understanding of the key elements of the Report and Order below.

Purpose of the Report and Order: To support the Commission’s efforts in closing the digital divide and secure U.S. leadership in the next generation of wireless services, including fifth-generation (5G) wireless and other advanced spectrum-based services by making the 3.7-3.98 GHz band available for flexible terrestrial wireless use. New rules, designed for the 3.7-3.98 GHz space were created with four key objectives: 1. To make a significant amount of spectrum available for flexible use, including 5G services; 2. To ensure that a significant amount of that spectrum is made available quickly so it can be used in upcoming 5G deployments; 3. To recover for the public a portion of the value of this public spectrum resource; and

4. To ensure the continuous and uninterrupted delivery of services currently offered in the 3.7-4.2 GHz band (C-band). Steps to Achieve the Report and Order Objectives 1. Repacking the existing satellite operations in the upper 200 MHz of the 3.7-4.2 GHz band – and reserving a 20 MHz guard band, freeing up 280 MHz for flexible use throughout the contiguous U.S. without interruption in delivery of service. 2. Conducting a public auction of flexible use license of the newly freed up 280 MHz of the spectrum, which is currently scheduled for December 8, 2020. The goal of the auction is to ensure that the public recovers a substantial portion of the value of the spectrum and raise the funds needed to relocate current incumbents of the C-band. The auction would include the 100 MHz blocks, with 20 MHz sub-blocks, to provide flexibility for interested bidders and to tailor their decisions based on the anticipated clearing costs and payment obligations associated with the amount of spectrum or geographic license area. 3. Relocating the current incumbents of the 3.7-4.2 GHz, currently occupied by the Fixed Satellite Service (FSS) and Fixed Service providers, to the 4.0-4.2 GHz spectrum and reimburse the eligible entities for the reasonable costs of relocation. 4. Establishing the relocation costs’ guidelines for submitting the estimated relocations costs by eligible incumbents, including Accelerated Relocation Payment incentives and corresponding deadlines for clearing the spectrum as well as prescribing the way to apportion payments amongst overlay licenses that won the respective spectrum space during the auction. Reimbursement submissions falling within the estimated range of costs in the cost category schedule (cost catalog) will be considered reasonable. Costs outside of the cost catalog range will need further documentation and justification. 5. Creating a two-phased approach to clearing the spectrum and aligning those efforts with the monetary incentives.

6. Establishing the criteria for selecting a neutral, 3rd party Relocation Payment Clearinghouse to manage collection of the auction proceeds and distribution of the relocation payments to the current eligible incumbents. Main duties of the Relocation Payment Clearinghouse include serving as a “watchdog over the excess transactional costs” as well as other responsibilities, further described in detail in the later sections that follow. 7. Establishing the criteria for selecting a Relocation Coordinator to ensure that all incumbent space stations are relocating in a timely manner. Main duties of the Relocation Coordinator include:

a. Coordinating the schedule for clearing the band; b. Performing engineering analysis to determine necessary earth station migration actions; c. Assigning obligations for earth station migrations and filtering; d. Coordinating with overlay licensees throughout the transition process; e. Assessing the completion of the transition in each Partial Economic Area (PEA) and determining overlay licensees' ability to commence operations; and f. Mediating scheduling disputes. 8. Reviewing and describing the logistics of the transition out of the lower 300 MHz of the C-band spectrum. We possess the requisite knowledge of all applicable guidance, laws, and regulations related to the Report and Order, the FCC’s Public Notices and other releases in GN Docket No. 18-122 related to the C-band Relocation efforts. We are experts in collecting and distributing payments; Alternative Dispute Resolution and mediation; and communications systems engineering services. Our thorough familiarity with the Report and Order, the FCC, as well as our past performance and experience with similar magnitude and scope programs, makes us uniquely qualified to successfully fulfill the role and duties of the Clearinghouse, as prescribed in the Report and Order and the RFP.

4.5 Key Personnel Our personnel bring a wide array of experience to the engagement that coalesces to form the holistic support necessary to understand the specific requirements of the C-band Relocation and to perform the services of the Clearinghouse. The majority of our personnel have performed similar services, and many have previously worked for 800 MHz Transition Administrator. We are experts in our fields and the most key personnel have decades of experience. Brief information about key personnel is below. Key Personnel CohnReznick Frank Banda, PMP, CPA, CFE, CGMA Engagement Partner Mr. Banda has over 35 years of financial management, audit, and consulting experience with specific expertise in fraud prevention and detection, audit readiness, internal controls, compliance and monitoring, and grant management and has served as a Partner for the 800 MHz Transition Administrator. He is adept at business process management improvement, program management, financial management research services, and financial reporting and has planned and implemented large-scale projects while mitigating risks. Timothy Bender, PMP, CPA Quality Assurance/Quality Control Partner Mr. Bender is a partner with CohnReznick focusing on government-related services. He has more than 27 years of experience serving federal, state, and local government clients as well as not-for-profit organizations, commercial companies, and investors. His areas of expertise include program and project management, strategic planning, policy guidance, risk management, auditing, and integrity monitoring.

Briana Levens, PMP PMO Director Ms. Levens is a Project Management Professional with 14 years of experience in project management, program implementation, and grant administration. She has served in Program and Project Management Offices for $90 million federal blanket purchase agreements, coordinating with multiple field offices and anywhere from 30-80+ staff at a given time. Additionally, Ms. Levens has exensive risk assessment and integrity monitoring experience. Lena Chapeton, CGFM, CFE, CICA, PMP Claims Reimbursement Ms. Chapeton has 13 years of government audit, project management and consulting experience. She has a strong working knowledge of the GAGAS, GAAS, U.S. GAAP, FAR, PMBOK Guide and Standards as well as various accounting systems and software. Her key areas of expertise include: government and corporate auditing; Sarbanes-Oxley (SOX) compliance; financial and business analysis/improvement and compliance; audit readiness, project management and process recommendations. Emily Alexiou, PMP Communications & Outreach Ms. Alexiou has 16 years of project management and education experience. She has served in the Project Management Office for major government contracting engagements, coordinating with field offices and dozens of staff members to successfully execute hundreds of contract audits. Daily, Ms. Alexiou develops and communicates internal and external reporting; documents and executes processes and procedures; implements document organization; and retains and manages resources, schedules, and budgets. Julie Miner, CPA, CISA, CRISC Data Management, Analytic, & Reporting Partner Ms. Miner has more than 25 years of experience in implementations, process optimization, security and controls, and SSAE 16 third party auditing standards. She leads the advisory group for CohnReznick’s largest industry and is responsible for delivering strategic or large transformative projects to Tier One organizations. Ms. Miner has overseen or been responsible for the optimization, automation or rollout of over 30 Procure to Pay initiatives to a variety of companies, including highly regulated industries.

Amanda Gibbs, CPA Financial Management – Program Controller Ms. Gibbs has more than 20 years of government and commercial audit and accounting experience. She leads projects, performs internal audit projects, such as business process analysis, due diligence, policy analysis, contract assurance, and operational/organizational risk assessments. Additionally, her experience includes budgeting and forecasting, internal controls, regulatory compliance, and financial and management reporting. Bill Hughes, CPA, CDFM Governance and Compliance– Partner, CohnReznick Mr. Hughes has over 27 years of external audit, audit readiness, remediation, internal control, financial management and risk management experience. He has significant expertise in implementing effective audit programs and robust systems of internal controls across numerous executive departments of the federal government and was a member of the Government Accountability Office (GAO) Green Book Advisory Council from 2013-2018. Squire Patton Boggs Robert B. Kelly General Counsel Mr. Kelly has served as the General Counsel of the 800 MHz Transition Administrator and will occupy a similar role with the Relocation Payment Clearinghouse. His experience and duties will include oversight of the Legal team for the Clearinghouse, including the Alternative Dispute Resolution process. He will counsel on all Clearinghouse activities, including contracting, policy and process development, confidentiality and data privacy, audit, fraud, waste and abuse deterrence and detection, independence management and stakeholder communications and outreach, among others. Robert E. Stup, Jr. Regulatory/Finance Counsel Mr. Stup focuses his practice on regulatory and transactional matters in communications. He has an in-depth understanding of state and federal regulations with impact on telecommunications providers. He has had a senior role with the Transition Administrator for over 15 years, where he advises the leadership advisory group on all finance matters and serves as the liaison and primary legal contact with the finance and audit teams. His finance and accounting background, including working as a CPA, as well as previously serving as a controller of a private company, make him uniquely qualified to advise the Clearinghouse. Steven Lederman Regulatory Counsel Mr. Lederman has 18 years of experience with communications law matters and serves as a member of the legal team of the 800 MHz Transition Administrator and as a Transition Administrator Mediator for negotiations between 800 MHz licensees and Sprint. For the Clearinghouse, he will handle regulatory compliance, tracking and reporting, including ensuring that the Clearinghouse complies with all applicable laws and regulations and the FCC’s Orders. He will be responsible for the Clearinghouse’s filings with the FCC, including quarterly progress reports, and for responding to the FCC’s requests for information. Mr. Lederman will advise on matters involving the development of policies and procedures to govern the Clearinghouse’s operations, the publication of website content and documents, and communications with program stakeholders. Joseph Markoski Alternative Dispute Resolution Mr. Markoski has over 40 years of experience representing private and public sector clients before the FCC, state regulatory commissions and national regulatory authorities outside the US. He has clients regarding matters involving: the allocation, assignment and use of radio spectrum; licensing; tariffing; interconnection; universal service; satellites; competition law and policy; and the regulation of wireline and wireless communications and other innovative service offerings. Of particular relevance, Mr. Markoski serves as Chief Mediator for the 800 MHz Transition Administrator. Paul Besozzi Alternative Dispute Resolution Mr. Besozzi concentrates his practice in the wireless, broadband and emerging technology areas. His extensive experience of more than 30 years in the telecommunications field includes regulatory, transactional, legislative and administrative litigation matters for clients ranging from wireless service and infrastructure providers to resellers of long-distance service, including cellular, personal communications services, specialized mobile radio, point-to-point microwave, advanced wireless services and other telecommunications service providers. He represented a major client in negotiating the agreements required under the 800 MHz rebanding program.

Eduardo Guzmán Alternative Dispute Resolution Mr. Guzmán represents telecommunications, media and technology (TMT) companies on regulatory and dispute resolution matters in the US and Latin America. He regularly advises carriers and providers on the implications of regulatory policy involving telecommunications and emerging technologies, and defends them in litigation, administrative, and alternative dispute resolution proceedings involving those issues. He also had experience representing Sprint in numerous mediation proceedings as part of the 800 MHz Reconfiguration.

Intellicom Paul Moller Lead SME Mr. Paul Moller has over thirty-five years of system engineering and strategy development. Experienced in voice, data and broadband network protocols. He is an expert in systems engineering, spectrum management, requirements analysis, satellite earth station design, terrestrial microwave, and wireless systems design. He is also an expert in identification and application of emerging technologies solutions. Mr. Moller has managed and built effective teams committed to organizational goals, and excelled at fostering collaboration among team members and other departments. Mr. Moller has developed strategy, schedules, and budgets, to complete projects (up to $4B) on budget and on time. Jesse Hindemith Technical SME Mr. Jesse Hindemith has over thirty years of system engineering experience and has been a management and business development leader for advancing communications technologies. He is an expert in systems engineering, requirements analysis, satellite earth station design, terrestrial microwave, and wireless systems design. He is also an expert in identification and application of emerging technologies solutions. He has full knowledge of the systems engineering process and is trusted by his clients to apply that knowledge to solve their complex problems. Mr. Hindemith is a highly-technical, hands-on engineer that is an excellent team leader and member, and provides meaningful and imaginative engineering solutions. David Reed David Reed Senior Advisor – Cable and Broadband Consultant Mr. Reed is a cable and broadband technologies expert with over 30 years in the industry and a Doctorate of Philosophy in Engineering and Public Policy. Mr. Reed has written for dozens of technical and scholarly publications and frequently presents at conferences such as the IEE Global Communications Conference. Mr. Reed currently consults on cable and broadband technologies, business models, and competitive assessments and is a Scholar in Residence for Technology, Cybersecurity, and Policy at the University of Colorado at Boulder.

4.6 Cost Dispute Resolution Prior Experience Resolving Such Disputes Our ADR team has directly relevant and current expertise serving “in a function similar to a special master in a judicial proceeding” in connection with implementing and managing an Alternative Dispute Resolution program for a spectrum reconfiguration. Our experience includes the successful resolution of almost 5,000 disputes, many of which involved determining “whether a particular expense is reimbursable in light of the Commission’s expressly stated goal[s].”

As General Counsel to the Transition Administrator, our ADR team has 15 years as General Counsel for been responsible for resolving disputes that have arisen between Sprint Transition Administrator and 800 MHz licensees during the course of the 800 MHz Reconfiguration. Among other matters, these disputes have involved the General Counsel for ~$4 Billion reasonableness of a licensee’s claimed relocation costs, as well as the Spectrum Reconfiguration comparability of the licensee’s facilities pre- and post-rebanding, consistent with the standards established by the FCC. We have also Resolved ~5,000 Reconfiguration- resolved disputes regarding the scheduling of reconfiguration and other Related Disputes tasks necessary to complete the program. Resolved 98.74% of all cases During the course of the 800 MHz Reconfiguration, 4,954 matters were without need for a PSHSB decision referred to ADR. Of these, 97.8% (4,845) were successfully mediated without the need to call upon FCC resources. Of the remaining matters (109) that were referred to the Public Safety and Homeland Security Bureau for further review, 46 were resolved (usually on the basis of our recommended resolution) without the need for the PSHSB to issue a decision. The PSHSB resolved 62 of the remaining disputes (again usually on the basis of our recommended resolution) and one is currently pending before the PSHSB. Much like the Report and Order, the FCC’s 800 MHz Orders and rules established the overall framework and standards for dispute resolution but delegated to the Transition Administrator the responsibility for implementing and conducting the dispute resolution process envisioned by the Commission. To achieve the FCC’s objectives, we developed a unique, flexible, and scalable ADR program for the 800 MHz program that combines elements of both mediation and arbitration. Fundamental to any successful ADR program is establishing credibility with program stakeholders. This requires scrupulous adherence to due process, as well as consistency and fairness in administration. To this end, Squire Patton Boggs created a foundational document for the 800 MHz program styled as an “ADR Plan” that provided all stakeholders with fair notice of the procedures, policies and standards to be utilized in dispute resolution. The ADR Plan also addressed: the role and responsibilities of mediators; the management and procedures governing the handling of disputes (both joint and ex parte sessions); burdens of proof; relaxed evidentiary standards; the confidentiality of disputes; the contents of the record and recommended resolution of disputes forwarded to the Commission for further review; and, above all else, due process for the parties involved. With rare exceptions, the ADR proceedings were conducted by teleconference. The 800 MHz ADR Plan is a “living” document that has been amended and evolved as the FCC streamlined various requirements for the 800 MHz rebanding program and as stakeholders gained experience with the rebanding process. In addition, we created standard forms and templates for both mediators and the parties to simplify and reduce the costs of ADR. To manage the ADR process and provide the Commission with on-demand reports, Squire Patton Boggs created and maintained an electronic 800 MHz-specific case management system at our expense. To ensure that the ADR process was scalable, Squire Patton Boggs assembled and trained a core group of mediators at the outset of the program. We refreshed and repeated training for our mediators throughout the course of the program and created a “Mediator’s Handbook” summarizing key rules of procedure, processes and FCC guidance. The mediator training included instruction on the requirements and standards prescribed by the

Commission’s 800 MHz Orders, other Commission rules likely to be implicated in any disputes, the systems and technologies used by licensees in the 800 MHz band, and the unique combination of mediation and arbitration in the ADR process envisioned by the Commission. Training was conducted by Squire Patton Boggs lawyers expert in Commission matters generally and the 800 MHz proceeding in particular, technical experts, and seasoned ADR practitioners. We anticipate that, if needed, twelve of these previously trained mediators would be available to the Clearinghouse. The ADR program has been managed on a day-to-day basis by a Chief Mediator to ensure compliance with the Commission’s substantive and procedural requirements, as well as consistency and quality across all disputes. The Chief Mediator has also been responsible for meeting with and providing the Commission with periodic reports regarding the number and status of disputes, the issues involved and, where appropriate, requesting the Commission’s guidance.

Best Practices and Operational Standards

5.0 Best Practices and Operational Standards

The adoption of best practices and operational standards is an inherent part of the culture of the members of our Team. It is part of our ethos. As the Clearinghouse, we would (1) engage in strategic planning and adopt goals and metrics to evaluate its performance, (2) adopt internal controls for its operations, (3) utilize enterprise risk management practices, (4) use best practices to protect against improper payments and to prevent fraud, waste, and abuse in its handling of funds, and (5) adequately separate any dispute resolution function from other operational functions. We will also create written procedures for our operations, using the Government Accountability Office’s (GAO’s) Green Book as a guide in satisfying such requirements. Through these best practices and operation standards we can ensure the Clearinghouse Selection Committee that we would be able to complete all of the responsibilities of the Clearinghouse. 5.1 Financial Solvency We have the financial resources to complete the Clearinghouse duties. CohnReznick is a national CPA firm and has been in business for over 100 years. Our annual revenues exceed $600 million and with over 300 partners and an $80 million line of credit, we have the financial resources to establish the Clearinghouse’s operations and remain solvent during the relocation transition period. Our length of time in business (over 100 years) financial position, and bank credit commitments demonstrate CohnReznick’s financial ability to remain solvent throughout the transition period. Our subcontractors also are well capitalized and have the credit facilities needed to remain solvent during the transition period. Squire Patton Boggs, founded in 1886, has one of the largest global footprints of any law firm, with 45 offices in 20 countries. The firm maintains a strong financial standing which is audited by PricewaterhouseCoopers. Revenues for each of the past two years were in excess of $500 million. We will provide our annual financial statements to demonstrate our financial stability and remain transparent in our ability to continue as a going concern and serve as the Clearinghouse for the term of operation for the relocation program. CohnReznick maintains commercially-reasonable insurance coverage for a leading firm in the accounting industry. Our insurance program includes, but is not limited to, the following types of policies: Commercial General Liability, Professional Liability, Cyber Liability, Automobile Liability, Workers’ Compensation, and Commercial Crime. As part of your evaluation of our qualifications, CohnReznick looks forward to an opportunity to review our insurance program in further detail. To the extent additional insurance coverage and/or bonding is required or otherwise appropriate, CohnReznick will work with you and our insurance brokers to address such requirements. SPB similarly maintains professional liability insurance. SPB 2020 professional liability coverage is led by Swiss Re. Policy limits are comparable to that maintained by law firms of similar size. Consistent with our standard engagement practices, we would fund the start-up costs for the Clearinghouse and the monthly operations until such time we are able to seek reimbursement in accordance with the Report and Order.

5.2 Fees and Expenses

Given the uncertainties regarding the scale of the C-band Relocation, such as the impact of lump sum payments on payment processing and the ADR caseload, we are proposing that our fees would be based upon the time and materials incurred by each organization. Both CohnReznick and Squire Patton Boggs have proposed hourly rates for their timekeepers that are heavily discounted from their standard commercial rates. Please note, that the Clearinghouse will be operated by employees of CohnReznick, Squire Patton Boggs, Intellicom, and consultant David Reed and will have no employees and therefore will not pay salaries. Please note that our hourly rates are confidential and commercially-sensitive information; however, we will gladly provide them to Commission staff upon request.

5.3 Accounting Methods CohnReznick will use the accrual method of accounting to record the revenue and expenses associated with operating the Relocation Payment Clearinghouse. As required, the Clearinghouse will engage a third-party CPA firm to conduct and audit of the funds expended to date, including the costs of the Clearinghouse by March 1 of each year. We will utilize Coupa as our claims processing and payment portal. It will allow incumbent space stations and earth stations to submit reimbursement claims through a secure portal and have visibility into the status of their approval and payment. In addition, our banking solution will be provided by Truist (formerly BB&T and SunTrust), one of the nation’s largest and most stable banks. Coupa will provide the claims reimbursement and payment platforms that will help make the reimbursement process a smooth and secure one. We will use a suite of Microsoft D365 tools to manage the operations of the Clearinghouse, including the estimating and forecasting of reimbursement claims and billing the overlay licensees for their share. In addition, we will use Microsoft PowerBi to report program performance, including key performance metrics of the Clearinghouse.

5.4 Protection Against Improper Payments; Prevention of Fraud, Waste, and Abuse The prevention of improper payments and fraud, waste, and abuse is the touchstone of any funds administrative program. As discussed above, CohnReznick has extensive experience serving as a funds administrator, including the collection and distribution of payments. We will implement best practices to protect against improper payments and to prevent fraud, waste, and abuse in its handling of funds. From our experience with federal grant programs, we are familiar with the Improper Payments Elimination and Recovery Improvement Act of 2012 (IPERIA) and understand the importance of preventing duplication of payments and implementing adequate safeguards against improper payments. To ensure smooth, efficient, and effective transition of all relocation efforts, we are adopting several measures that will safeguard the Reimbursement Fund from fraud, waste, and abuse. Specifically, the steps that we will take pertain to:

1. Obtaining justifications for when the estimated costs exceed predetermined costs estimates; 2. Retaining documentation of expenses incurred from first to last reimbursement until the end of the C- band relocation program (and longer, if desired by the Bureau); 3. Conducting audits, data validation, and site visits to entities receiving the money from the Reimbursement Fund; 4. Disseminating information related to cost estimates, actual costs, and reimbursements made public for transparency;

5. Obtaining certifications signed by entities under penalty of perjury, if allowed by the Bureau; and 6. Present Clearinghouse progress reports on funds spent to date by different entities, including the Clearinghouse fees and expenses to the Bureau for review and comments. As part of our written policies and procedures, we will incorporate the following steps performed by our technical SMEs when reviewing and approving the claims submitted for reimbursement to ensure proper protection and detection of any fraud, waste, abuse, or non-compliance and to prevent any improper payments.

Our focus on detecting duplicate requests and determining if the request was simply due to error or if it was a fraudulent attempt will be a key component of our anti-fraud, waste, and abuse efforts. We will implement procedures including review, approval, and the related controls to detect potential duplicate payment requests during claims processing. We will use various data analytics tools to identify anomalies in claims, including data extraction techniques to prevent and detect duplicate payments. When we identify an expense or claim that requires further analysis, we will request additional information from the incumbent or a vendor to supplement any claims that we deem deficient. We will design specific templates, including types of costs and the support that will be needed to adequately support the claims. The goal of requesting additional information will be to reimburse the costs, not deny payments. Therefore, we will work with the incumbents to ensure all avenues are exhausted before we deny any costs submitted for reimbursement. Coupa has automated controls in place that will help support a strong control environment. These automated controls, coupled with monitoring or detective controls over the process and IT controls such as onboarding and inactivating users and frequent password changes will all contribute to prevent fraud and waste. In addition,

Coupa has key controls imbedded and we will design the appropriate workflows to ensure the appropriate number of reviews have occurred prior to approvals, and that adequate segregation of duties exist between users that generate invoices, approve invoices, create or change vendors, or approve and process payments. Security will be reviewed to review users or change access and passwords will be changed periodically to ensure that only those that have access should continue to receive access. Finally, Coupa tracks changes made in the system and this can be analyzed as needed to review and detect inappropriate behaviors. As for the Treasury Management roles, these will be strictly permissioned to only a few individuals, and two- factor identification is required for their sign in. Bank statements will be reconciled by separate individuals to detect unusual or unauthorized activity.

5.4.1 Fraud Prevention and Detection Expertise Integrity Monitoring – Port Authority of New York and New Jersey To prevent and detect fraud, waste, and abuse, CohnReznick serves as Fiscal and Integrity Monitor for the Port Authority of New York and New Jersey (PANYNJ) Office of Inspectors General as LaGuardia Airport goes through a redevelopment of Terminal B – a $4 Billion P3 endeavor. For this engagement, we assembled a diverse team of forensic accountants; compliance officers; safety, environmental, and civil engineers; former law enforcement site monitors; private investigators; and lawyers. As part of this engagement, we monitor the Minority, Women, and Disadvantaged Business Enterprise (MWDBE) contractors to ensure compliance with MWDBE requirements and validate the relevant areas of the redevelopment project. We examine many areas of potential risk including, but not limited to: 1) charge back fraud; 2) fraudulent/inaccurate requisitions; 3) other direct costs and reimbursables fraud; 4) duplicate invoices submissions, and 5) estimates and contract compliance. We perform reviews of reimbursable costs and change orders for allowability per contract terms and conditions and review the reimbursements for against those contracts for reasonableness and accuracy.

5.5 Performance Goals and Metrics We are experts in advising on operational performance, projections, analytics, and delivery. We understand the nuances of a program’s lifecycle and additional implications associated with the capture, processing, dissemination of program information. We will utilize this expertise in developing goals and metrics for assessing our performance. During our Project Start-up Phase, we will engage in strategic planning for establishing the Clearinghouse’s operations and will develop a proposal for establishing goals and metrics for assessing our performance. Our approach for developing the proposal will begin with establishing a clear understanding of program objectives, assessing, and aligning program risk, establishing, and implementing effective internal control, developing a detailed project plan that includes all major activities, dependencies, milestones and deliverables, and building in effective measures for monitoring and reporting on program performance. Initial procedures will include, but are not limited to:

1. Establishing an inventory of the class of incumbent space stations and incumbent earth stations to confirm the entities taking part in the transition (and what entities may be eligible for relocation payments). 2. Confirming the deadline for clearing the band set by incumbent space station operators to either complete by 2025 accept the option to accelerate that process to 2021 for the lower 120 MHz and 2023 for the upper 180 MHz. 3. Creating a schedule of the relocation payments the incumbent operators are expected to receive based on Phase I and Phase II accelerated deadlines and non-accelerated timelines. 4. Confirm the clearing schedules and costs based on Transition Plans submitted by each operator and establish mechanisms for tracking completion of activities against proposed schedules. 5. Assessing program risk and aligning risk appetite and strategy. 6. Establishing a consistent methodology for managing the collection and distribution of relocation payments and the protection of program data.

7. Implementing processes for monitoring notification compliance and the resolution of transition delays by operators. 8. Documenting and maintaining operational procedures. Utilizing the inventory, deadlines, schedules, and payment methodologies, we will establish performance metrics related to the timeliness of operational performance and the reasonableness of costs of the Clearinghouse payment relocation costs. In addition, we will use data- driven analytics to measure and track performance and effectively manage incremental reductions in accelerated relocation payments. We will create workflows and track key factors related to relocation payments and performance milestones such as certification filings, to ensure prompt payment in compliance with performance requirements and to avoid delays in processing. Our workflows will allow us to maintain payment quality and timeliness while also monitoring operator performance. Establishing a centralized method for managing the collection and distribution of relocation payments also limits the potential for data exposure and error. Our processes will build in automated prompts, input requirements, data validations, and reminders to help eliminate the likelihood of incomplete or inaccurate data. We will drive performance and ensure transparency through ongoing tracking of activities.

1. Management Reporting– Presentations, Graphics, Information, etc. 2. Performance Measurement – Scorecards, Dashboards, Exceptions, Stock & Flow, etc. 3. System of Record Fraud Indications –Duplicate Data, Unsupported Costs, Abnormal Activity, etc. 4. Predictive Analysis and Projections – Trend analysis, Projections, Correlations, etc. 5. Resource Planning & Validation - Learning Curve Validation, Maturity vs. Cost, etc.

5.6 Enterprise Risk Management Experience 5.6.1 Enterprise Risk Management CohnReznick has extensive experience with helping organizations, large and small, implement Enterprise Risk Management (ERM). Our professionals are considered industry leaders and subject matter experts with a broad knowledge and keen understanding of the nuances within the ERM industry. Our thought leadership and best practices offer our clients the expertise and strategic thinking necessary to make ERM successful and sustaining. Our clients tell us that what sets CohnReznick apart from other firms is simple: Our professionals understand the complex array of issues that companies face and help address these industry challenges to meet our clients’ unique needs. CohnReznick has a proven track record of developing approaches to successfully support business needs and challenges. Our technical approach, based on industry best practices and our experience with similar projects, is flexible enough to be customized to the C-band relocation program’s specific needs, yet sufficiently structured to immediately address the most critical requirements of the program. This approach has been successfully utilized in the past by our team in performing enterprise risk assessments and federal, state, and local government programs.

We will leverage our ERM methodology that is built using the COSO 2017 ERM framework to identify program level risks and establish internal controls to mitigate or reduce the risks relevant to Relocation Payment Clearinghouse program. Based on the five components of the COSO 2017 ERM framework, CohnReznick’s ERM methodology will enable us to identify the most significant risks to the C-band program as they relate to the Relocation Payment Clearinghouse, its mission, vision, and core values of this program and its key supporting functions. Based on the risks we identify; we will develop and implement controls to reduce or mitigate those risks. We will conduct a thorough risk assessment of the program and activities of the risk assessment will include:

• Working with Bureau executives, C-band stakeholders and other relevant risk and compliance entities, we will establish a governance and oversight framework, including establishing an ERM team that would be responsible for project management and ongoing monitoring. • Developing a robust risk inventory based on information gathering and validated via facilitated workshop(s) with all the relevant C-band stakeholders. • Assess the risks with respect to their likelihood of occurrence, impact and where possible the velocity at which the risk can be exposed. • Developing a risk assessment template containing the program risks areas, specific risks, and the inherent risk score. • Preparing risk heat maps for presentation to Bureau senior management and other relevant C-band stakeholders, as needed, describing the top inherent risks relevant to Relocation Payment Clearinghouse responsibilities and proposed strategies on how to mitigate or reduce the overall impact of the risk. We will implement the processes and controls needed to mitigate the inherent risks identified for the Clearinghouse. The processes and internal controls will be established to ensure that risks of error, fraud or misstatement in financial reporting are addressed as part of developing and drafting our process documentation but not create barriers to efficient data processing. We have been most successful in achieving this through the use of automated processes and controls to move information through the process, document electronically, and maintain appropriate segregation of duties. Our team will develop and implement policies, procedures, systems, and controls to successfully accomplish program objectives. We have extensive experience developing internal control narratives, flow charts, and risk and control matrices, as we have been engaged to create those for government agencies and public companies (including Entity Level Controls, General Computer and all major financial reporting business cycles). We will utilize the GAO Green Book as a guide to help us formalize our processes to ensure the Clearinghouse operations run effectively and

efficiently; our reports provide reliable information; and we are in compliance with applicable laws and regulations. The documentation will be created under appropriate guidance of our SME on Green Book and the related internal controls. In addition to referencing the GAO Green Book, our approach uses the 2017 Committee of Sponsoring Organization’s (COSO) Internal Control – Integrated Framework (COSO Framework). Our documentation will be mapped to the five components and 20 principles in the COSO Framework. We will follow the below components to ensure that our policies and procedures are sound, and that the controls we develop are effective, efficient, and working as designed to protect the C-band Reimbursement Fund from fraud, waste, abuse, and/or non- compliance. Leveraging the understanding of the reimbursement claims processes obtained during the review of the Report and Order and the initial discussions with the Bureau, as well as a deep understanding of how the technology will support the process, we will prepare the methods and procedures documentation. As we are designing and documenting the control environment, we will consider preventative and detective controls, as well as automated and manual controls and work to ensure the most robust control environment while still enabling efficient processing. Documentation Will Include: • An outline of the process objective, scope, and key • Analysis and review of estimated, actual, and final costs performance indicators; (Transition Plans to Cost Catalog to all reimbursements by • Quality assurance review steps to ensure the process is eligible incumbent/vendor); accurate, complete and properly controlled; • Reviewing and approving expense documentation • Clearly defined roles and responsibilities; (telecommunication SMEs input, as needed); • Detailed procedures outlining the manual and automated • Reconciliation of funds disbursed to actual costs; steps required to perform a specific activity; and • Alternative Dispute Resolution (ADR)/Mediation; • Criteria to measure performance and communicate • Compliance monitoring standards; expectations to staff. • Data validation; • Receipt and submittal of reimbursement requests; • Internal controls; • Tracking estimated and actual costs submissions (Transition • Program reporting;

Plans vs. claims submitted for reimbursement); • Final accounting and project closeout; and • Audit documentation.

5.6.2 Internal Audit CohnReznick has expertise in the assessment and evaluation of regulatory compliance, IT audit and security, internal audit, risk assessment, and board advisory services. We focus on managing risks, identifying best practices, and streamlining processes, which enhance the value of our Governance, Risk, and Controls (GRC) services. We invest in our professionals to deliver timely, high quality, and cost- effective services. On average, our professionals have 10-15 years of prior industry experience in internal audit. Our internal control professionals possess a blend of financial, operational, and technology internal audit and control expertise, as well as business process improvement experience. Our staff is comprised of:

• Former chief audit executives (CAEs) • Internal audit directors, and managers • Certified SOX managers (CSOXM) • Certified internal auditors (CIAs), certified fraud investigators (CFEs)

• Certified information system auditors (CISAs), certified information systems security professionals (CISSPs), and • Certified anti-money laundering specialists (CAMS).

Governance, Risk, and Compliance Expertise Includes:

• Sarbanes-Oxley and other regulatory compliance • Pre- and post-implementation system review • Fraud risk assessment • Internal financial control documentation and review • COSO 2013 internal audit framework • Policy, procedure, and standard review and • COSO 2017 enterprise risk management framework development • Bank Secrecy Act / Anti-money laundering • Internal control risk assessment (BSA/AML) • Control rationalization and optimization • CFO / treasury advisory services • Technology / security audit and control • Anti-corruption / bribery risk evaluation and compliance services

Select Internal Audit Experience adidas Columbia University CohnReznick currently supports adidas CIA on multiple IT CohnReznick provided construction audit-related services audits. These audits include the adidas’ patch to Columbia University over a three-year period, from 2015- management program in 2018, the big data, IT asset 2018. We served the Columbia University Office of Internal management, and active directory audits in 2019, and the Audit as an advisory accountant to review the billings adidas information security audit in 2019. All the audits related to the University’s construction project to erect its were completed successfully on-time and on-site in Medical Graduate Education Building, a new 14-story, accordance with the adidas CIA standards. Each of the 107,000 square foot building in New York City. The scope audits received very positive feedback from the auditee in of work was two-fold; the first being an assessment of the the post-audit evaluation. payment requisition packages submitted to Columbia MasterCard University, the second being an analysis of project change order submittals. The costs reviewed included those of the CohnReznick has assisted in establishing SOX compliance University's Construction Manager for the project, as well programs for MasterCard, a global payment solutions as the project subcontractors. company that provides a variety of services in support of The objective was to determine that costs billed by the the credit, debit and related payment programs of nearly Construction Manager and the subcontractors were valid 25,000 financial institutions. CohnReznick was retained to and complied with the terms and conditions of the assist MasterCard Worldwide with its ongoing risk and Guaranteed Maximum Price (GMP) Contract between compliance efforts; build and support their risk Columbia and the Construction Manager, as well as with the management framework through various initiatives; ensure related subcontractor agreements. that internal controls over key processes are designed The analysis concentrated on labor costs for both the adequately and operating effectively; provide CFO Construction Manager management and the Construction advisory and support services; and develop and Manager and subcontractor trades with 25 payment continuously sustain supporting policies and procedures applications and 40 change orders under review on the $91 through formal policies, desktop procedures, process million GMP contract. flowcharts, and control documentation. Toys “R” Us Alcatel-Lucent CohnReznick was retained by Toys “R” Us’ Internal Audit Alcatel-Lucent provides solutions that enable service function to support testing of internal controls over financial providers, enterprises and governments worldwide to reporting (SOX 404) globally as well as assist with other deliver voice, data and video communication services to internal audits. As part of our engagement with Toys “R” end-users. CohnReznick was retained by Lucent to provide Us, we deployed resources globally, leveraging GRC staff augmentation to assist in their SOX compliance CohnReznick’s Chennai team and resources from our effort and to perform quality assurance reviews. Nexia affiliates to support the local, on-the-ground testing Barnes & Noble at Toys “R” Us locations worldwide. CohnReznick’s global team successfully leveraged the methodology developed We perform an external quality assessment of Barnes & by Toys “R” Us and was able to complete the engagement Noble’s internal audit function which operates in two within a timely manner. segments: Barnes & Noble Retail (B&N Retail) and NOOK.

5.7 GAO Green Book Procedures CohnReznick has extensive experience with creating written procedures using the GAO Green Book. Standards for A-123 and Internal Control in the Federal Government were promulgated by the GAO (known as the Green Book) and provide the overall framework for establishing and maintaining an effective internal control system This revision took place in 2015 and enhanced requirements around internal controls and enterprise risk management. The Green Book provides specific requirements for assessing and reporting on controls and management is responsible for designing the policies and procedures to fit an entity’s circumstances and building them in as an integral part of the entity’s operations. Management documents in policies the internal control responsibilities of the organization and communicates to personnel the policies and procedures so that personnel can implement the control activities for their assigned responsibilities We are fortunate to include as part of the Clearinghouse team Mr. Bill Hughes, CohnReznick Partner and Federal Market Leader with over 28 years of professional external audit, audit remediation, internal control, financial management and risk management experience. He is a subject matter expert in Federal agency internal controls having extensive experience performing Office of Management and Budget (OMB) Circular No. A-123, Management's Responsibility for Enterprise Risk Management and Internal Control (A-123), support at over twenty-five federal agencies. Mr. Hughes was a Board Member of the GAO Green Book Advisory Council (2013- 2018), which was established by the Comptroller General of the United States to provide input and recommendations for revisions to the Green Book Mr. Hughes will lead the efforts that ensure the entity stands up a full, internal process that includes proper documentation such as policies and procedures, process narratives, flow charts, risk control matrices, and test plans for its operations and to help manage funds, distribute payments, and track progress. This includes (1) planning and scoping, (2) testing internal controls to assess their design, (3) testing their operational effectiveness, and (4) maturity of their internal control documentation.

Privacy and Data Security

6.0 Privacy and Data Security

We recognize the criterial importance of privacy and data security. Our Clearinghouse team members already have robust privacy and data security best practices in their operations. Our systems and practices would include: (1) making real time disclosures as to the content and timing of communications among auction participants; (2) complying with all applicable laws and Federal government guidance on privacy and information security requirements such as relevant provisions in the Federal Information Security Management Act, National Institute of Standards and Technology publications, and Office of Management and Budget Guidance; and (3) hiring an independent third-party firm to audit and verify, on an annual basis, the entity’s compliance with privacy and information security requirements and to provide recommendations based on any audit findings, to correct any negative audit findings and adopt any additional best practices suggested by the auditor, and to report the results to the Bureau.

6.1 Confidentiality, Privacy, and Data Security Our team will comply with the FCC’s requirements for the Clearinghouse to disclose in real-time the content, the timing of, and the parties to communications, if any, from or to applicants in Auction 107, starting on the initial deadline for filing auction short-form applications until the deadline for making post-auction down payments. Our team, especially the attorneys from Squire Patton Boggs that have experience with FCC spectrum auctions, is familiar and has managed compliance with Section 1.2105(c) of the FCC’s rules, which prohibits certain auction- related communications. We will establish procedures and implement internal controls to ensure compliance with the requirements of Section 1.2105(c), including developing and utilizing a written Clearinghouse Confidentiality Policy, which we will share with the FCC, that will incorporate restrictions on communications from or to applicants in Auction 107 and procedures for reporting communications, if any, that occur. CohnReznick is committed to ensuring the security of confidential and personal information under our control and will maintain all systems and monitor the privacy, and data security of our subcontractors who will be responsible for following our guidance on these matters. Our information security program is designed to comply with applicable law and adhere to industry standards and best practices for safeguarding information. Squire Patton Boggs has a corporate information security program that is certified to ISO/IEC 27001:2013 standards; its program is continually evolving to meet the data security and privacy requirements affecting the firm and its clients. The Information Technology (IT) organization is continually expanding its offering and adding new capabilities to support these business needs. Additionally, the firm’s Office of General Counsel and Procurement functions consult with IT to ensure appropriate data protection, privacy, and information security terms are incorporated into IT subcontractor and vendor contracts. In addition to its enterprise-wide information security capabilities, the firm has the ability to meet individual client information security requirements as needed. Squire Patton Boggs is continuously making improvements to its corporate information security program. Our claims processing system partner, Coupa takes the privacy and data security of our enabling platforms very seriously. Coupa has a backup strategy which allows critical operations to continue in the event of a disaster. Coupa maintains a well-defined backup strategy and formal disaster recovery and business continuity plans that outline the actions required in the event of a serious business interruption.

All customer data is stored on redundant database servers with live failover, in addition to the physical redundancy (network and power) that Amazon Coupa Adheres to the provides. All customer data is stored on RAID class hardware and replicated Following Compliance in real time to a secondary environment in a different Availability Zone (AZ). Standards: A MySQL database serves as the master database in the Amazon AZ A and every transaction is continuously replicated to the slave database in AZ B. • ITAR • HIPAA If the primary hardware in AZ A fails, Coupa employs the concurrently • ISO27001 • CCPA running hardware in AZ B. The slave database in AZ B is promoted to • TUV • PCI master and a slave database in AZ C is immediately initiated. The new slave Certified • SOC 1 database is continuously synchronized with the new master database. Cloud • SOC 2 Service Additionally, Coupa maintains a self-assessment with the Cloud Security • GDPR Alliance through which Coupa submits an annual Consensus Assessments Initiative Questionnaire (CAIQ). All of the Coupa products, from the supplier portal to invoicing and payment platforms are performed in the Payment Card Industry Data Security Standard (PCI DSS) compliant infrastructure, held to the highest money movement standards of credit card companies like Visa and Mastercard. Controls include but are not limited to: notarized and validated Know Your Customer protocols, limited privileged users with access to bank accounts and ACH capabilities, 2-factor authentication, and encrypted data at rest. All platforms also are audited annually and are SOC 2 compliant. In addition to these strict compliance standards, most Coupa platforms (except Coupa Pay) are going through the process of obtaining FedRAMP ATO. The Coupa FedRAMP environment is based off the National Institute of Standards and Technology Risk Management Framework.

6.2 Federal Privacy and Information Security Requirements.

CohnReznick has extensive experience working with our clients in helping them to ensure compliance with Federal privacy and information security requirements, including the Federal Information Security Management Act, National Institute of Standards and Technology publications, and Office of Management and Budget guidance. We will use this experience to protect the systems used to operate the Clearinghouse. CohnReznick recognizes that the relocation claims reimbursement system may be subject to threats that can have an adverse effect on the reimbursement program, its operations, space station operators, earth station operators, overlay licensees, and other claimants. The threats can compromise the confidentiality, integrity, availability, or reliability of the Clearinghouse systems, information processed, or transmitted by the system. CohnReznick will comply with all applicable laws and federal government guidance on privacy and information security requirements and relevant provisions of the Federal Information Security Management Act. We will do so by leveraging the NIST Risk Management Framework and Office of Management and Budget guidance to help identify and manage the risks to Clearinghouse’s systems efficiently and effectively, as we have on other large projects. We will document a System Security Plan (SSP) for the system and will follow the steps below in managing the risks to the system: Categorize the System We will categorize the relocation claims reimbursement system based on criticality and sensitivity of the system and potential adverse impact to the overall mission of the program. We will leverage the overall risk assessment that was performed to identify key controls. We will use the guidance from FIPS 199 and NIST SP 800-60 to categorize the system.

Select and Implement Baseline Controls We understand the importance of NIST 800-53, 800-39, and 800-30. Our team will adhere and comply with security and privacy controls for the federal information systems and organizations (NIST 800-53), managing information security risks (NIST 800-39), and guidelines for conducting risk assessments (NIST 800-30). Once we categorize the system, we will select a baseline of security controls, identify the key controls and the

supplemental controls as needed based on the results of the risk assessment. We will use the guidance from FIPS 200 and select controls from NIST 800-53 rev 5 (the latest version). We will ensure that all the selected controls are documented in the SSP. Upon selection of the baseline information security controls from NIST 800- 53, we will work with the solutions provider and ensure that the controls are implemented within the system architecture and appropriate security configuration settings are applied to the reimbursement system. Our proposed relocation claims reimbursement system is Coupa and as discussed in Section 6.1 has strict privacy and data security protocols. Annual Audit As part of our assessment and continuous monitoring phase as described in the response, we will assess all the key controls for all of our systems used to operate the Clearinghouse and engage an independent third party to audit our systems on an annual basis. Security Monitoring CohnReznick will deploy a comprehensive threat intelligence platform such as AlienVault, SolarWinds, ManageEngine, or LogRhythm, etc. to monitor the Clearinghouse’s systems continuously for cyber-attacks. Our dedicated threat monitoring team, coupled with advanced threat detection platform is capable of identifying the latest threats, attacker techniques and effective defenses. Our solution offers some unique advantage over other security point products. Utilizing predictable data sources for threat feeds, enables our threat research team to have a comprehensive understanding of the interactions between the different data types being collected, correlated and analyzed. This in-depth knowledge enables us to engineer the threat management platform to provide effective security controls and seamlessly integrated threat intelligence for any environment. Our engineers will proactively monitor the Clearinghouse’s systems and the related network and will be alerted with any anomalies or threat events. Once an event is identified and detected based on definitions and guidance in NIST Special Publication 800-61 Revision 2, we will notify the FCC leveraging the United States- Computer Emergency Readiness Team (US-CERT) Federal Incident Notification Guidelines (2015). Vulnerability Remediation We will address any vulnerabilities found in the system and maintain a log of these vulnerabilities and the remediation activities that were undertaken to address them. We will provide details as to the cause, potential impact, and the mitigation actions taken to address the vulnerabilities, as requested.

Other Information

7.0 Other Information

Based on our thorough understanding and familiarity with the proposed C-band Relocation, prior experience with similar type projects, as well as our extensive expertise in the telecommunication industry, we are well equipped to function as the Clearinghouse tasked with establishing and administering the C-band Reimbursement Fund over the course of four distinct phases: Program Kickoff, Program Start, Program Execution, and Program Wind Down. We would be operational immediately and without delays. We would also be able to notify overlay licenses of their payment obligation within 14 days of completion of the auction and confirmation of the geographic areas necessary for the PEA calculation. Finally, we would be able to assist the Bureau in its determination of the lump sum payment amounts for each class of earth station, for each such operator that opts for lump sum payments. 7.1 Operational Timeline Once selected, we will be able to start the Clearinghouse operations immediately and without delays. Because of our familiarity with the Report and Order and our extensive experience with managing similar size and magnitude projects, as well as vast experience in the telecommunications industry backed by the support of our teaming partners, we are ready to begin our operations as soon as we are selected for this role. Based on the timeline in the Report and Order, the selection of the Clearinghouse with be finalized by August 14, 2020, at the latest. Given that information, we are operating under the assumption that immediately following the announcement, we would begin with our Program Kickoff activities, as described detail below. 7.2 Notification of Overlay Licensees We will meet with the space station operators and review their transition plans and obtain their cost reimbursement forecasts, including the forecasted period in which relocation costs will be incurred. We would also be able to notify overlay licenses of their payment obligation within 14 days of completion of the auction and confirmation of the geographic areas necessary for the PEA calculation. Pro Rata Share Calculation The Reimbursement Fund will be funded with the proceeds from the public auction (Auction 107) held by the Commission in December 2020. Upon completion of the public auction, and once the winners of the auction are announced, we will begin our process to apportion the costs among overlay licensees as it is prescribed by the Report and Order. We will review the auction results to identify the winners and determine the specific amounts that each overlay licensee will need to contribute as their share to the Reimbursement Fund. We will base the amounts owed on the below calculations to arrive at the pro-rata share of each overlay licensee contributing to the Reimbursement Fund. We will calculate the pro-rata share for each overlay licensee of their six months’ worth of estimated transition costs to be contributed to the Reimbursement Fund. In addition, we will calculate the pro-rata share for every six months thereafter, until the C-band transition is complete. If the Reimbursement Fund runs out of money before

59 the next six-month share is due, we will request the additional pro-rata shares be provided within 30 days of the request. It is important to note that the Auction 107 will be designed as an ascending clock auction format, where each licensee’s share would be based on its share of gross winning bids at the end of the clock phase of the auction. In addition, certain payments, such as the Phase I accelerated relocation payments, would be apportioned only among those purchasing overlay licenses in the Phase I spectrum blocks and areas, as per the formulas described below. The following picture represents different types of calculations we will perform to correctly determine the pro-rata amount for each overlay licensee.

Final clock phase prices for the set of all license Pro-rata share of each blocks won by bidder Total eligible flexible-use license Total final clock phase prices for ALL license relocation costs blocks sold in the auction

Final clock phase prices for the set of all license PEA specific earth Pro-rata share of each blocks won by bidder in each PEA station and fixed flexible licensee in a PEA Total final clock phase prices for ALL license service relocation blocks sold in the PEA area costs

Pro-rata share of each Final clock phase prices for the set of all license Total Accelerated flexible-use licensee of the blocks won by bidder Relocation 3.7-3.8 MHz in the 46 PEAs Total final clock phase prices for ALL license Payment for cleared by 12/4/2021 blocks sold in those 46 PEAs area Phase I

Final clock phase prices for the set of all license Total Accelerated Pro-rata share of each blocks won by bidder Relocation flexible-use licensee Total final clock phase prices for ALL license Payment for blocks sold in the auction Phase II

Billings and Collections Based on the calculated pro rata share above, bills will be distributed to the bidders via email with a request to pay into the Fund within 30 days. Checks can be mailed to the lockbox, or ACH or Wires can be received. As part of the accounting process collections will be reviewed periodically and followed up to ensure property receipt from all parties. Bank statements will be reconciled monthly.

7.3 Incumbent Earth Station Cost Calculations and Lump Sum Payments

In accordance with the Report and Order, eligible earth stations have a choice between accepting: 1) reimbursement for the reasonable relocation costs by maintaining satellite reception; or 2) a lump sum reimbursement for all of the incumbent earth stations based on the average, estimated costs of relocating all of their incumbent earth stations. Once the lump sum option is selected, the decision is final and the incumbent earth station will not be able to submit the estimated or actual costs to the Clearinghouse for reimbursement. In addition to selecting a lump- sum payment, the incumbent earth station will need to indicate whether it will transition to the upper 200 MHz to maintain the C-band service or discontinue C-band services. We will compile the listing of all incumbent earth stations that opted for the lump sum payments and will track those entities and implement controls to ensure they are not included in any Transition Plans and do not submit any costs for reimbursement.

If requested by the Bureau, our Team will calculate average cost estimates (using a bottom-up approach) for transitioning incumbent earth stations to assist the Bureau in determining lump sum payment amounts. Intellicom’s intimate knowledge of the satellite industry and equipment manufacturers, and its experience over the past thirty years implementing earth station terminals of all sizes and complexity, give Intellicom the knowledge to accurately price lump sum payments for each class of terminal. Another approach Intellicom will deploy to accurately identify lump sum payments will be to create a Bill of Materials including modulation and compression subsystems and other identifiable options for each earth station class. Intellicom will then identify a price range based on minimum or maximum terminal configuration. This approach is similar to the methodology identified in the FCC’s Public Notice released on June 4, 2020 (DA 20-586).

Attachment 2: Neutrality and Independence

Independence and Neutrality

The CohnReznick Team has met all requirements necessary to establish that it will operate as a “neutral, independent entity with no conflicts of interest (organizational or personal) on the part of its organization or its officers, directors, employees, contractors, or significant subcontractors.” (Report and Order para. 258). Attached are the Certifications of each member of the CohnReznick Team attesting that (1) they have no financial interest in any incumbent space station operators, incumbent earth station operators, content companies that distribute programming using the 3.7 GHz to 4.2 GHz Band (C-Band), wireless operators, or any entity that may seek to acquire flexible use licenses or manufacture or market equipment in the C-Band; (2) they have no conflict of interest in serving as the Clearinghouse, or a subcontractor thereto; (3) that their officers or directors (or, in the case of Squire Patton Boggs, its Global Board members and Executive Committee) have no financial or organizational conflicts of interest; and, (4) that their personnel involved in the preparation of the Proposal and to be involved in the provision of Clearinghouse services have no financial or organizational conflicts of interest. Each Team member has also certified that it has not undertaken the representation of or provided assistance to any party related to the realignment of the C-Band pursuant to the Report and Order and, should the CohnReznick Team be selected to serve as the Clearinghouse, will not undertake any such representation or assistance in matters before the Clearinghouse or otherwise with respect to the realignment of the C-Band. The CohnReznick Team members have disclosed all active commercial relationships with any of the members of the Search Committee and have made such other disclosures as deemed appropriate. To assure the on-going independence and neutrality of the Clearinghouse, the CohnReznick Team will publish and adhere to and Independence Management Plan and Code of Conduct to be effective during the course of C-Band realignment. The Plan will assure transparency of any commercial relationships between Team members and any engaged program stakeholder and provide for separation between personnel involved in Clearinghouse activities and personnel involved in any such commercial relationships and will provide such others safeguards as may be deemed appropriate. The Code of Conduct will provide for restrictions against ownership of stock in engaged program stakeholders by personnel of each Team member involved in the provision of Clearinghouse services. Clearinghouse activities, including the implementation and maintenance of the Independence Management Plan and Code of Conduct will be subject to the on-going oversight of the FCC.

Certifications of Independence CohnReznick LLP

Squire Patton Boggs

Intellicom Technologies, Inc.

David Reed

Clearinghouse Entities, Officers, Directors, Employees, & Contractors

For the purposes of our proposal to serve as the Relocation Payment Clearinghouse, the CohnReznick Team considers the following to be within the scope of “the Clearinghouse, or its officers, directors, employees and/or contractors”:

1) CohnReznick LLP Team Members:

• Frank Banda • Timothy Bender • William Hughes • Julie Miner • Amanda Gibbs • Briana Levens • Lena Chapeton • Emily Alexiou

2) Squire Patton Boggs (US) LLP Team Members:

• Robert B. Kelly • Robert E. Stup, Jr. • Steven Lederman • Joseph Markoski • Paul Besozzi • Eduardo Guzmán • Whitney Williams • Janine Provenzano

3) Intellicom Technologies, Inc. Team Members:

• Jesse Hindemith • Paul Moller • Ken Ryan • David Price • Lee Vishloff • Brian Graf • Graham Woodring • Dan Makinster • Norm Larson • Mike Rekrut • Frederic Reiger • Alex Birger

4) David P. Reed, Ph.D.

For purposes of the Certifications of Independence and No Financial Interest, we have considered all Team personnel identified above as within the scope of the certification. For purposes of the Certification of Independence and No Financial Interest, we have considered CohnReznick’s Officers and Executive Board Members as within the scope of the certification: Officers

• David Kessler, Chief Executive Officer • Leonard Korn, Chief Financial Officer • Phillip Mandel, Chief Operating Officer Executive Board Members

• Claudine M. Cohen • David Kessler • Phillip Mandel • James Martinko • Mike Monahan • Brian Newman • Ira Weinstein • Alan Wolfson • Michelle Fleishman • Shelsie Royster • Kristen Soles

For purposes of the Certification of Independence and No Financial Interest, we have considered Intellicom’s Officers and Directors as within the scope of the certification: Officers and Directors

• Jesse Hindemith • Paul Moller

For purposes of the Certification of Independence and No Financial Interest, we have considered the Squire Patton Boggs Global Board and Executive Committee as within the scope of the certification: Global Board • Gassan A. Baloul • Cipriano S. Beredo III • Amy Brown Doolittle • Karol K. Denniston • Jonathan J. Jones • Stacy H. Krumin • Traci L. Martinez • Frederick R. Nance • Aubrey A. Rothrock III • Mark J. Ruehlmann • Alison E. Treliving • Thomas P. Wilson

Executive Committee • Mark J. Ruehlmann • Stephen C. Mahon • Edward J. Newberry • Jonathan J. Jones • Frederick R. Nance • Stacy D. Ballin

CohnReznick will form a wholly-owned Limited Liability Company (LLC) to serve as the Clearinghouse entity. The LLC, in turn, would contract with all Team members for the provision of Clearinghouse services. CohnReznick would serve as the sole member of the LLC. It is not contemplated that the LLC would have employees.

Attachment 3: Forecast of Fees and Expenses

Forecast of Annual Cost (or by Period if less than 12 months)

Estimated Costs by Period Program Start Up & Phase 1 Phase 2 Phase 3 Closeout 8/15/20- 1/1/21- 1/1/22- 1/1/23- 1/1/24- 1/1/25- 1/1/26- Description 12/31/2020 12/31/21 12/31/22 1/31/23 12/31/24 12/31/25 6/30/26 Total # of Months 4.5 12 12 12 12 12 6 70.5

Estimated Labor Costs $5,585,620 $13,285,260 $10,334,280 $10,334,280 $8,898,240 $8,898,240 $1,267,780 $58,603,700

Estimated Expenses $494,000 $584,000 $559,000 $559,000 $534,000 $534,000 $310,000 $3,574,000

Total $6,079,620 $13,869,260 $10,893,280 $10,893,280 $9,432,240 $9,432,240 $1,577,780 $62,177,700

Actual fees and expenses will be based upon the time and materials incurred.