Contract analysis

I. Purpose and Background This memorandum summarizes the four prevailing wage determination ("PWD") requests filed today, June 26, 2023, with the U.S. Department of Labor's National Prevailing Wage Center ("NPWC") in Washington, D.C., on behalf of our client, Lumos Analytics Inc. ("Lumos" or the "Company"). The purpose of this memorandum is to provide a consolidated record of the filings, set forth the analytical bas

II. Summary Table of All Four PWD Requests The following table provides a consolidated overview of the four prevailing wage determination requests filed with the NPWC on June 26, 2023. Detailed position-by-position analyses are set forth in Section III below. Note: All four beneficiaries hold at least a Master's degree or its foreign educational equivalent and will qualify for EB-2 classification as Advanced Degree P

III. Position-by-Position Analysis A. Beneficiary 1: Rajan Mehta — VP, Engineering — Core Platform

1. Position Details. • Job Title: Vice President, Engineering — Core Platform • SOC Code: 15-1252 (Software Developers) • Proposed Wage Level: Level IV (fully competent; exercises independent judgment and authority) • Offered Salary: $285,000 per year • Worksite: 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303 • EB-2 Basis: Advanced Degree (Master's degree in Computer Science) The Vice President, Engineering — C

2. Beneficiary Background. • Citizenship: India • Current Immigration Status: H-1B nonimmigrant, valid through September 14, 2025 • Education: • M.S., Computer Science, Indian Institute of Technology Bombay ("IIT Bombay"), conferred May 2014 • B.Tech., Computer Science, National Institute of Technology Tiruchirappalli ("NIT Trichy"), conferred May 2012 Mr. Mehta has approximately nine years of post-baccalaureate expe

3. Minimum Requirements as Stated on PWD Request. The following minimum requirements were set forth on the ETA Form 9141 submitted to the NPWC: • Minimum Education: Master's degree in Computer Science or a closely related field • Minimum Experience: Five (5) years of progressive post-baccalaureate experience in software engineering, including two (2) years of experience in distributed systems architecture • Special R

4. SOC Code Selection Rationale. SOC 15-1252 (Software Developers) is the closest occupational classification for a VP-level engineering role directing core platform development, software architecture, and engineering teams. The BLS description for SOC 15-1252 encompasses professionals who "research, design, and develop computer and network software or specialized utility programs" and who "analyze user needs and dev

5. Wage Level Justification. Level IV is appropriate for this position. Under the DOL's four-tier wage level framework, Level IV corresponds to positions that require a high degree of independent judgment, innovation, and supervisory authority. A Level IV classification is warranted where the employee operates with substantial autonomy, exercises authority over significant organizational resources, and is expected to

6. Notes. The offered salary of $285,000 per year is expected to significantly exceed the prevailing wage at Level IV for SOC 15-1252 in the San Jose-Sunnyvale-Santa Clara, CA MSA. Based on our preliminary review of the current OES wage data published by the BLS for this SOC code and geographic area, the Level IV prevailing wage is estimated to fall in the range of approximately $190,000 to $205,000 per year. The sub

1. Position Details. • Job Title: Senior Director, Data Science & Machine Learning • SOC Code: 15-2051 (Data Scientists) • Proposed Wage Level: Level IV (fully competent; exercises independent judgment and authority) • Offered Salary: $310,000 per year • Worksite: 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303 • EB-2 Basis: Advanced Degree (Ph.D. in Statistics) The Senior Director, Data Science & Machine Learni

2. Beneficiary Background. • Citizenship: Hungary • Current Immigration Status: H-1B nonimmigrant, valid through March 2, 2026 • Education: • Ph.D., Statistics, ETH Glenrock Assurance (Swiss Federal Institute of Technology), conferred September 2016 • M.Sc., Applied Mathematics, Eötvös Loránd University (Budapest, Hungary), conferred June 2012 Dr. Varga is a recognized researcher in the field of statistical learning

3. Minimum Requirements as Stated on PWD Request. The following minimum requirements were set forth on the ETA Form 9141 submitted to the NPWC: • Minimum Education: Ph.D. in Statistics, Computer Science, or a closely related quantitative field • Minimum Experience: Three (3) years of post-doctoral experience in applied machine learning, including two (2) years of experience in financial services credit modeling • Spe

4. SOC Code Selection Rationale. SOC 15-2051 (Data Scientists) is the most accurate occupational classification for a role focused on developing and leading machine learning models, conducting statistical analysis, and directing AI-driven credit risk analytics. The BLS describes SOC 15-2051 as encompassing professionals who "develop and implement a set of techniques or analytics applications to transform raw data int

5. Wage Level Justification. Level IV is appropriate for this position. The role requires the highest level of independent judgment and innovation within the data science function. Dr. Varga is expected to conduct original research, develop novel statistical methodologies, and exercise broad supervisory authority over the entire data science and machine learning organization. The position involves strategic decision-

6. Notes. The offered salary of $310,000 per year is the highest among the four positions and is expected to comfortably exceed the Level IV prevailing wage for SOC 15-2051 in the San Jose-Sunnyvale-Santa Clara, CA MSA. Based on our preliminary review of the current OES data, the Level IV prevailing wage for Data Scientists in this MSA is estimated to fall in the range of approximately $180,000 to $195,000 per year.

1. Position Details. • Job Title: Vice President, Product — Fintech Solutions • SOC Code: 11-2021 (Marketing Managers) • Proposed Wage Level: Level III (experienced; exercises independent judgment within broadly defined parameters) • Offered Salary: $275,000 per year • Worksite: 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303 • EB-2 Basis: Advanced Degree (MBA) combined with five (5) years of progressive post-ba

2. Beneficiary Background. • Citizenship: Mexico • Current Immigration Status: L-1A intracompany transferee, valid through July 30, 2024 • Education: • MBA, IPADE Business School (Mexico City, Mexico), conferred December 2013 • B.S., Industrial Engineering, Tecnológico de Monterrey (Monterrey, Mexico), conferred May 2010 Mr. Aguilar-Reyes brings approximately thirteen years of progressive post-baccalaureate experienc

3. Minimum Requirements as Stated on PWD Request. The following minimum requirements were set forth on the ETA Form 9141 submitted to the NPWC: • Minimum Education: Master's degree in Business Administration, Finance, or a closely related field • Minimum Experience: Five (5) years of progressive experience in fintech product management, including three (3) years of experience managing cross-functional teams of fiftee

4. SOC Code Selection Rationale. SOC 11-2021 (Marketing Managers) is the closest DOL occupational classification match for product management roles. This warrants explanation, as the position title includes "Product" rather than "Marketing." The DOL's Standard Occupational Classification system does not include a discrete "Product Manager" category. Within the universe of available SOC codes, 11-2021 (Marketing Manag

5. Wage Level Justification. Level III is appropriate for this position given the combination of managerial responsibility, cross-functional leadership, and specialized fintech regulatory knowledge required by the role. Although the position carries a VP title, the SOC 11-2021 code's Level III already encompasses substantial supervisory and strategic functions, and the marginal difference in autonomy and independent

6. Notes. The offered salary of $275,000 per year is expected to exceed the Level III prevailing wage for SOC 11-2021 in the San Jose-Sunnyvale-Santa Clara, CA MSA. Based on our preliminary review of the current OES data, the Level III prevailing wage for Marketing Managers in this MSA is estimated to fall in the range of approximately $170,000 to $185,000 per year. L-1A Status — Timeline Considerations. Special atte

1. Position Details. • Job Title: Director, Information Security & Compliance • SOC Code: 15-1212 (Information Security Analysts) • Proposed Wage Level: Level IV (fully competent; exercises independent judgment and authority) • Offered Salary: $260,000 per year • Worksite: 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303 • EB-2 Basis: Advanced Degree (M.S. in Cybersecurity) The Director, Information Security & Co

2. Beneficiary Background. • Citizenship: Japan • Current Immigration Status: H-1B nonimmigrant, valid through November 18, 2025 • Education: • M.S., Cybersecurity, Carnegie Mellon University (Pittsburgh, Pennsylvania), conferred May 2017 • B.Eng., Information Engineering, University of Tokyo (Tokyo, Japan), conferred March 2015 Ms. Tanaka holds the Certified Information Systems Security Professional ("CISSP") certif

3. Minimum Requirements as Stated on PWD Request. The following minimum requirements were set forth on the ETA Form 9141 submitted to the NPWC: • Minimum Education: Master's degree in Cybersecurity, Information Systems, or a closely related field • Minimum Experience: Four (4) years of progressive experience in information security, including two (2) years of experience in SOC 2 Type II and ISO 27001 compliance imple

4. SOC Code Selection Rationale. SOC 15-1212 (Information Security Analysts) is the direct occupational classification match for a role centered on planning and implementing an organization's information security program, including compliance frameworks and cloud security. The BLS description for SOC 15-1212 encompasses professionals who "plan, implement, upgrade, or monitor security measures for the protection of co

5. Wage Level Justification. Level IV is appropriate for this position. The Director, Information Security & Compliance holds responsibility for the entire information security and compliance function at Lumos, encompassing cybersecurity operations, data protection, SOC 2 Type II and ISO 27001 compliance frameworks, vendor security assessments, and incident response planning across the Company's cloud-native SaaS inf

6. Notes. The offered salary of $260,000 per year is expected to exceed the Level IV prevailing wage for SOC 15-1212 in the San Jose-Sunnyvale-Santa Clara, CA MSA. Based on our preliminary review of the current OES data, the Level IV prevailing wage for Information Security Analysts in this MSA is estimated to fall in the range of approximately $175,000 to $190,000 per year. As noted above, the CISSP certification re

IV. Prevailing Wage Area and OES Data All four positions that are the subject of the PWD requests filed today are located at Lumos Analytics Inc.'s headquarters at 2240 Embarcadero Way, Suite 600, Palo Alto, California 94303. None of the four beneficiaries is required to travel to secondary worksites or perform duties at locations outside of the Palo Alto headquarters on a regular basis. The applicable prevailing wag

V. Procedural Notes and Next Steps All four prevailing wage determination requests were submitted electronically via the U.S. Department of Labor's Foreign Labor Application Gateway ("FLAG") system on June 26, 2023. Each request was submitted on ETA Form 9141, Application for Prevailing Wage Determination, and an electronic confirmation receipt was generated for each submission. The FLAG system confirmation numbers h

1. Confirm Salary Compliance. We will confirm that the offered salary for each position exceeds the prevailing wage as determined by the NPWC. Under 20 C.F.R. § 656.40(a), the employer must offer and pay a wage that is at least equal to the prevailing wage for the occupation in the area of intended employment. If the offered salary for any position falls below the determined prevailing wage, the employer must increas

2. Initiate Supervised Recruitment Campaign. Upon confirmation of salary compliance, we will initiate the supervised recruitment campaign required under 20 C.F.R. § 656.17(e) in coordination with Broadgate Compliance Services LLC, Lumos's recruitment advertising vendor. The primary contact at Broadgate is Gerald Fitzmorris, Principal, located at 1414 K Street NW, Suite 730, Washington, DC 20005. Broadgate will assist

3. Prepare SWA Job Order. We will prepare and submit a State Workforce Agency ("SWA") job order for each position for posting via CalJOBS, the online job matching system administered by the California Employment Development Department ("EDD"), in compliance with 20 C.F.R. § 656.17(e)(1)(i). The SWA job order must be posted for a minimum of thirty (30) calendar days.

4. Schedule Print Advertisements. We will schedule two consecutive Sunday print advertisements in The Peninsula Gazette, a newspaper of general circulation in the Palo Alto, California area, in compliance with 20 C.F.R. § 656.17(e)(1)(i)(B). Our advertising representative at The Peninsula Gazette is Noreen Caswell, located at 780 Hamilton Avenue, Palo Alto, CA 94301. The two print advertisements must appear on two di

5. Coordinate Additional Recruitment Steps. In addition to the mandatory SWA job order and print advertisements, we will coordinate the following additional recruitment steps required under 20 C.F.R. § 656.17(e)(1)(ii) for professional occupations: • Industry Publication Posting: Posting in FinTech Talent Weekly, a trade publication targeting fintech professionals, published by Creston Media Group, Inc., 41 East 11th

6. Monitor and Respond to Applicants. Throughout the recruitment campaign, we will work with Lumos's HR team (Janelle Kwon) and Broadgate Compliance Services to monitor applications received in response to the recruitment advertisements, screen applicants against the minimum requirements for each position, and document the lawful, job-related reasons for rejecting any U.S. worker applicants. All applicant resumes and

VI. Document Retention Copies of all four prevailing wage determination request submissions (ETA Forms 9141), including all supporting documentation submitted to the NPWC, have been saved to the firm's electronic matter file under Matter Number 1008-00004. The submissions are organized by beneficiary name within the matter file. The prevailing wage determinations, once received from the NPWC, must be retained in the

VII. Post-Filing Annotations — Prevailing Wage Determination Results The following annotations were added to this memorandum by hand upon receipt of the prevailing wage determinations from the NPWC. These notations supplement the original memorandum dated June 26, 2023. PWD Results Received: Handwritten notation: "All four offered salaries exceed PWDs — no salary adjustments required. Proceed to recruitment. — TR" Ha