Contract analysis

I. COVER LETTER A. Introductory Paragraph Belmont Ridge Bank, National Association ("BRB" or the "Bank"), OCC Charter No. 18742, RSSD ID 2847391, FDIC Certificate No. 28463, hereby submits this notice to the Office of the Comptroller of the Currency (the "OCC") pursuant to 12 C.F.R. § 5.47 in connection with the Bank's proposed issuance of subordinated debt securities. BRB is a nationally chartered commercial bank or

II. DESCRIPTION OF THE APPLICANT BANK A. General Information The following sets forth certain identifying information with respect to the Bank: BRB is a wholly owned subsidiary of Belmont Ridge Financial Group, Inc. ("BRFG" or the "Parent"), a Delaware corporation and bank holding company registered under the Bank Holding Company Act of 1956, as amended. BRFG's principal executive offices are also located at 600 Lexi

III. DESCRIPTION OF THE PROPOSED SUBORDINATED DEBT ISSUANCE A. Summary of Terms The following is a summary of the material terms and conditions of the proposed Notes. A more complete description is set forth in the Draft Term Sheet attached hereto as Exhibit A and the Summary of Key Terms of the Draft Form of Indenture attached hereto as Exhibit B.

1. Instrument. 6.750% Fixed-to-Floating Rate Subordinated Notes due 2036 (the "Notes").

2. Aggregate Principal Amount. $350,000,000 (Three Hundred Fifty Million Dollars). The Bank does not intend to issue any additional Notes in excess of this aggregate principal amount without filing a separate notice or supplement with the OCC.

3. Maturity Date. March 1, 2036 (the "Maturity Date"), representing a ten-year tenor from the expected issuance date. The Notes will have an original maturity of ten years, which exceeds the five-year minimum maturity required for Tier 2 capital instruments under 12 C.F.R. Part 3.

4. Interest Rate — Fixed Rate Period. During the period from and including the original issuance date (expected to be on or about February 24, 2026) to but excluding March 1, 2031 (the "Fixed Rate Period"), the Notes will bear interest at a fixed rate of 6.750% per annum. Interest during the Fixed Rate Period will be payable semi-annually in arrears on March 1 and September 1 of each year, commencing September 1, 202

5. Interest Rate — Floating Rate Period. During the period from and including March 1, 2031 (the "Reset Date") to but excluding March 1, 2036 (the Maturity Date) (the "Floating Rate Period"), the Notes will bear interest at a floating rate equal to the Compounded Secured Overnight Financing Rate ("SOFR") plus 275 basis points (2.75%) per annum. Interest during the Floating Rate Period will be payable quarterly in arr

6. Form and Denomination. The Notes will be issued in the form of one or more fully registered global notes in book-entry form only. The global notes will be deposited with, or on behalf of, The Depository Trust Company ("DTC") and will be registered in the name of Cede & Co., as nominee of DTC. Beneficial interests in the global notes will be represented through participants' accounts at DTC and will be shown on, an

7. Issue Price. The Notes will be issued at a price of 99.750% of par (the "Issue Price"), resulting in gross proceeds to the Bank of $349,125,000. The original issue discount of 0.250% (or $875,000) will be amortized over the life of the Notes for tax purposes. The yield to maturity at the Issue Price is approximately 6.793%.

8. Ranking and Subordination. The Notes will constitute subordinated unsecured obligations of BRB. The payment obligations of the Bank under the Notes, including the obligation to pay principal, interest, and any other amounts due thereunder, will be subordinate and junior in right of payment to the prior payment in full of all Senior Indebtedness (as defined in the Indenture) and all Deposits (as defined in the Inde

9. Optional Redemption. The Notes will be redeemable at the option of the Bank, in whole or in part, under the following circumstances, in each case subject to the prior written approval of the OCC as required by 12 C.F.R. § 5.47 and the capital adequacy rules of 12 C.F.R. Part 3: (a) Optional Redemption on or after the Reset Date: On or after March 1, 2031 (the Reset Date), the Bank may redeem the Notes, in whole or

10. No Acceleration / Regulatory Restrictions. The Notes will not be subject to acceleration at the option of the holders or the trustee, except upon the occurrence of a "Liquidation Event," which will be defined in the Indenture to mean the appointment of the FDIC or another receiver or conservator for the Bank, whether under the Federal Deposit Insurance Act, 12 U.S.C. § 1821, or otherwise. This restriction on acce

11. Trustee. The trustee for the Notes under the Indenture will be: Brindoval Trust Company, National Association Corporate Trust Office 100 Federal Street, Suite 800 Boston, Massachusetts 02110 Attention: Corporate Trust Administration Corporate Trust Officer: Helen M. Briggs Telephone: (617) 482-3300 Brindoval Trust Company, National Association is a national banking association authorized to exercise trust and fid

IV. INTENDED USE OF PROCEEDS A. Net Proceeds Calculation The following table sets forth the Bank's calculation of the estimated net proceeds from the proposed offering: Estimated offering expenses of approximately $1,150,000 include fees and expenses of legal counsel to the Bank and to the initial purchasers, accounting and auditing fees, trustee acceptance fees and counsel fees, fees of the nationally recognized sta

V. TIER 2 CAPITAL QUALIFICATION ANALYSIS A. Regulatory Framework The Notes are intended to qualify as Tier 2 capital of the Bank under 12 C.F.R. Part 3, which implements the Basel III capital framework for national banks and federal savings associations. Tier 2 capital includes, among other things, subordinated debt instruments that satisfy the eligibility criteria set forth in 12 C.F.R. § 3.20(d). The Bank has struc

VI. EXISTING SUBORDINATED DEBT A. Outstanding Subordinated Notes As of the date of this notice, the Bank has one series of subordinated debt securities outstanding: The existing 2027 notes are subordinated unsecured obligations of the Bank ranking pari passu with the proposed new Notes in right of payment. The existing notes were issued in reliance upon an exemption from registration under the Securities Act and are

VII. RATINGS The Bank has obtained indicative credit ratings for the proposed Notes from two nationally recognized statistical rating organizations ("NRSROs"), as follows: The Bank conducted rating agency presentations to Meridian Ratings Group, Inc. and Archer Bond Analytics LLC on January 8, 2026. These presentations included a detailed discussion of the Bank's financial condition, capital position, asset quality,

VIII. CORPORATE AUTHORIZATION The Board of Directors of Belmont Ridge Bank, National Association has considered and approved, by resolutions duly adopted at a meeting of the Board of Directors held on January 15, 2026, the issuance of the Notes and the execution and delivery of all related transaction documents, including the Indenture, the Purchase Agreement, and the Registration Rights Agreement, and has authorized

IX. LEGAL COUNSEL The following professionals are engaged in connection with the proposed offering: Issuer's Counsel: Calderwood & Harkness LLP One Liberty Plaza, 52nd Floor New York, New York 10006 Responsible Partner: Vivienne St. Claire Telephone: (212) 819-7200 Email: vstclaire@calderwoodharkness.com Calderwood & Harkness LLP represents BRB in connection with this regulatory filing and the proposed offering and i

X. POST-ISSUANCE NOTIFICATION COMMITMENT In accordance with the requirements of 12 C.F.R. § 5.47, BRB hereby commits to filing a post-issuance notification with the OCC following the closing of the offering and the issuance of the Notes. The post-issuance notification will be filed within ten (10) calendar days of the Closing Date, or within such other time period as may be required or specified by the OCC. The post-

XI. CERTIFICATIONS AND REPRESENTATIONS In connection with this notice, the undersigned officers of Belmont Ridge Bank, National Association hereby certify and represent as follows:

1. Well-Capitalized Status. BRB certifies that it is "well-capitalized" as defined in 12 C.F.R. Part 6 as of the most recent quarterly reporting date (December 31, 2025). The Bank's capital ratios, as set forth in Section II.D of this notice, exceed all applicable "well-capitalized" thresholds under the prompt corrective action framework.

2. Absence of Supervisory Action. BRB certifies that it is not subject to any conditions imposed in a written agreement, consent order, cease-and-desist order, capital directive, prompt corrective action directive, or any other formal or informal supervisory enforcement action that would preclude, prohibit, restrict, or otherwise impede the Bank's issuance of subordinated debt as described in this notice.

3. Compliance with 12 C.F.R. § 5.47 and Part 3. BRB certifies that the terms of the proposed subordinated debt, as described in this notice and the attached exhibits, satisfy the requirements of 12 C.F.R. § 5.47 for the issuance of subordinated debt by a national bank, and that the proposed Notes are structured to qualify as Tier 2 capital of the Bank under 12 C.F.R. § 3.20(d) and the other applicable provisions of 1

4. Eligible Bank Status. BRB certifies that it qualifies as an "eligible bank" under 12 C.F.R. § 5.3 and is therefore eligible to file this notice in lieu of a formal application for approval of the proposed issuance.

5. Truth and Accuracy. BRB represents and warrants that the information contained in this notice and the attached exhibits is true, complete, and accurate in all material respects to the best of the knowledge, information, and belief of the undersigned officers, after due inquiry. The Bank acknowledges that the OCC will rely on the accuracy of the information provided in this notice in making its determination as to

6. Ongoing Compliance Commitment. BRB commits to ongoing compliance with all applicable regulatory requirements in connection with the issuance and maintenance of the Notes as Tier 2 capital, including, without limitation, timely and accurate reporting of the Notes in the Bank's Call Reports (Schedule RC-R) and compliance with all OCC supervisory guidance related to the issuance and treatment of subordinated debt.

XII. SIGNATURE BLOCK The undersigned, being duly authorized officers of Belmont Ridge Bank, National Association, do hereby submit this Notice of Intent to Issue Subordinated Debt to the Office of the Comptroller of the Currency pursuant to 12 C.F.R. § 5.47, and do hereby certify and represent that the statements and representations made herein are true, complete, and accurate to the best of their knowledge, informat

XIII. EXHIBITS AND ATTACHMENTS The following exhibits and attachments are submitted as part of this notice and are incorporated herein by reference in their entirety. EXHIBIT A — DRAFT TERM SHEET Belmont Ridge Bank, National Association 6.750% Fixed-to-Floating Rate Subordinated Notes due 2036 Preliminary Term Sheet — For Discussion Purposes Only This term sheet is provided for informational purposes only in connecti

XIV. INTERNAL NOTATION CALDERWOOD & HARKNESS LLP — INTERNAL — NOT FOR FILING Matter No.: 1045-00001 Client: Belmont Ridge Bank, National Association This draft was prepared by Eric Johannsen (Associate) and Claire Dempsey (Associate), under the supervision of, and reviewed by, Vivienne St. Claire (Partner), Calderwood & Harkness LLP. This draft reflects the version of the Notice as filed with the Office of the Comptr