Contract analysis

1. Purpose and Background 1.1 Purpose of This Matrix This BaaS Partner CDD/EDD Responsibility Matrix (the "Matrix") establishes a comprehensive RACI (Responsible, Accountable, Consulted, Informed) framework delineating the obligations and respective roles of Belmont Ridge Bank National Association ("BRB" or the "Bank"), as the chartered national bank holding OCC Charter No. 48271, and each of its fourteen (14) active

2. Definitions and Key Terms 2.1 Key Definitions For purposes of this Matrix, the following terms shall have the meanings set forth below. Where a term is defined by reference to a statute or regulation, the definition shall be construed consistently with the applicable statutory or regulatory provision, including any amendments thereto. "CDD" or "Customer Due Diligence" refers to the procedures required for identify

3. Governing Principles 3.1 BRB's Non-Delegable Regulatory Responsibilities The foundational principle underlying this Matrix is that BRB, as a nationally chartered bank (OCC Charter No. 48271, FDIC Certificate No. 31845), is the regulated entity accountable to the OCC, FinCEN, the Office of Foreign Assets Control ("OFAC"), and all other applicable federal and state regulatory authorities for all aspects of BSA/AML c

4. Master RACI Matrix — CDD/EDD Lifecycle Activities This Section 4 sets forth the detailed RACI allocation for each CDD/EDD activity across the full customer lifecycle. The Matrix is organized by lifecycle phase: Customer Onboarding / Account Opening (Section 4.1), Enhanced Due Diligence for High-Risk Customers (Section 4.2), Ongoing Monitoring (Section 4.3), Periodic Review (Section 4.4), and Account Closure / Offb

5. Partner-Specific Detail — Tier 1 Partners This Section 5 provides individualized CDD/EDD responsibility detail for each of BRB's three Tier 1 BaaS Partners. These three partners collectively represent approximately 87% of total BaaS transaction volume and the overwhelming majority of BaaS-related compliance risk. The general RACI framework set forth in Section 4 applies to all Tier 1 partners; this Section 5 suppl