Contract analysis

I. Purpose and Background This memorandum sets forth Calderwood & Harkness LLP's ("C&H") recommendations for the reporting framework (the "Reporting Framework") to be adopted by the newly established Compliance Committee (the "Compliance Committee" or the "Committee") of the Board of Directors (the "Board") of Belmont Ridge Financial Group, Inc. ("BRFG") and its wholly owned national bank subsidiary, Belmont Ridge Ba

II. Reporting Cadence The Reporting Framework establishes four tiers of reporting cadence: (A) monthly reporting during the active remediation period, (B) quarterly reporting aligned with OCC filing deadlines, (C) ad hoc or event-driven reporting for material developments, and (D) a recommended post-remediation cadence to be adopted following the submission of the compliance self-certification. Each tier is described

III. Monthly Report — Recommended Content and Metrics This Section sets forth the recommended content and specific metrics to be included in each monthly report to the Compliance Committee during the remediation period. The monthly report should be organized into the subsections described below, each of which corresponds to a critical area of the remediation program or the Bank's ongoing BSA/AML compliance operations

I. Remediation Budget Tracking Effective financial oversight of the remediation program is a core responsibility of the Compliance Committee and the Board. The monthly report should include a comprehensive budget tracking section covering the following: Total Remediation Budget. Confirmation of the total Board-approved remediation budget of $42,500,000, exclusive of the $14,500,000 civil money penalty. The report sho

IV. Quarterly Report — Additional Content Beyond Monthly Metrics In addition to the monthly metrics described in Section III, each quarterly report should include the following additional content areas. These additions are designed to provide the Compliance Committee and the Board with deeper analytical insight, to support the preparation of the OCC quarterly progress reports, and to address topics that do not requir

V. Reporting Responsibilities and Workflow This Section describes the roles and responsibilities of the individuals and teams involved in the preparation, review, approval, and distribution of the monthly and quarterly reports, as well as the recordkeeping requirements applicable to all reports produced under this Framework. A. Report Preparation The following individuals are designated as the primary report owners f