Contract analysis

1. Purpose and Summary This memorandum documents the results of the comprehensive conflicts of interest check conducted by the Conflicts Department of Calderwood & Harkness LLP ("C&H" or the "Firm") in connection with the proposed engagement of Belmont Ridge Bank National Association ("BRB") for regulatory advisory services. The proposed engagement relates to BSA/AML and sanctions compliance-program remediation in re

2. Engagement Team The following attorneys have been identified as the proposed engagement team for Matter No. 1045-00002. Each team member has been individually screened against the full party list set forth in Section 4, including searches for personal relationships, financial interests, prior employment, and any other circumstance that could give rise to an actual or apparent conflict of interest. • Philip Hartman

3. Scope of Engagement The proposed engagement encompasses the following scope of work, as described in the preliminary engagement letter dated February 6, 2025, and as further refined in discussions between Mr. Hartmann and BRB's General Counsel, Gregory Nardone: C&H is to serve as outside regulatory counsel to BRB, advising on and assisting with all aspects of BSA/AML and sanctions compliance-program remediation re

4. Parties Searched The following entities and individuals were searched against the Firm's Glenrock Health ITCONFLICTS database, the Firm's historical engagement records (dating to the Firm's founding), lateral hire conflict disclosures, and individual attorney certifications. Searches were conducted using all known names, aliases, identifiers, and associated entities. A total of 38 discrete parties (entities and in

5. Conflicts Check Results The following subsections report the results of the conflicts check for each party or group of parties identified in Section 4 above. For each party, the memorandum reports: (a) the results of the database search, including whether any current or prior C&H representation was identified; (b) whether any current adverse representation was identified; (c) any relevant observations or contextua

6. Observations and Monitoring Recommendations While no disqualifying conflicts of interest have been identified, the following observations and monitoring recommendations are provided for the engagement team's guidance. These recommendations are intended to ensure ongoing compliance with the Firm's ethical obligations throughout the duration of the engagement, which is expected to extend through at least February 15

7. Engagement Team Certifications Each member of the proposed engagement team has been individually screened against the complete party list set forth in Section 4 and has confirmed, through the Firm's standard individual certification process, that he or she has no personal conflicts of interest, financial interests, familial or personal relationships, prior employment affiliations, or any other circumstance that wo

8. Conclusion and Clearance Based on the comprehensive search of C&H's Glenrock Health ITCONFLICTS database, historical engagement records, lateral hire disclosures, and individual attorney certifications, and based on the analysis set forth in Sections 5 and 6 above, the Conflicts Department hereby issues the following clearance: Conflicts Check No. CC-2025-01124 is CLEARED. No disqualifying conflicts of interest ha

1. The monitoring recommendations set forth in Section 6 (Sections 6.1 through 6.4) should be implemented for the duration of the engagement.

2. Supplemental conflicts checks should be conducted on a rolling basis as new parties are identified during the engagement, including but not limited to the remaining 11 BaaS partners not individually screened in this memorandum.

3. If any existing relationship described herein becomes materially adversarial — including but not limited to adversity involving BaaS partners, the significant shareholder Brindoval Capital Partners, or predecessor counsel Drayton Mercer — the engagement team should promptly submit a supplemental conflicts check request to the Conflicts Department.

4. The engagement team should notify the Conflicts Department immediately upon becoming aware of any change in circumstances that could affect this clearance, including the addition of new engagement team members, the identification of new adverse parties, or any development giving rise to a potential personal conflict of any team member. This clearance does not constitute legal advice regarding the ethical permissib

9. Approval Prepared by: ________________________________________ Elena R. Fitzpatrick Senior Conflicts Analyst Conflicts Department Calderwood & Harkness LLP Date: February 9, 2025 Reviewed and Approved by: ________________________________________ The Honorable David N. Whitaker (Ret.) Partner, Conflicts Committee Calderwood & Harkness LLP Date: February 9, 2025 Distribution: • Philip Hartmann, Responsible Partner —