Contract analysis

I. EXECUTIVE SUMMARY This Enterprise-Wide BSA/AML Training Plan (the "Training Plan" or "Plan") is a core component of Workstream 5 (BSA/AML Program Governance & Training Enhancement) of the Comprehensive Remediation Action Plan (the "Remediation Plan") being prepared for submission to the Office of the Comptroller of the Currency (the "OCC") by Belmont Ridge Bank National Association ("BRB") on or before May 15, 202

II. REGULATORY FRAMEWORK AND TRAINING OBLIGATIONS A. Statutory and Regulatory Basis The training program established under this Plan is grounded in a comprehensive statutory and regulatory framework that imposes training obligations on financial institutions, their boards of directors, officers, employees, and agents. This section sets forth the principal authorities relevant to the design and content of BRB's traini

Article V of OCC Consent Order No. OCC-2025-003 specifically requires BRB to "develop and implement a comprehensive, enterprise-wide training program addressing Bank Secrecy Act / Anti-Money Laundering compliance, customer due diligence and enhanced due diligence, OFAC sanctions screening, and suspicious activity identification and reporting, tailored to the specific roles, responsibilities, and risk exposure of all

III. TRAINING GOVERNANCE AND ACCOUNTABILITY A. Program Ownership Effective governance of the training program requires clearly defined ownership, accountability, and oversight mechanisms. The following individuals and bodies constitute the program's governance structure: Program Sponsor: Patricia Langston, Chief Compliance Officer. As the Chief Compliance Officer of Belmont Ridge Bank NA, Ms. Langston bears ultimate

IV. AUDIENCE SEGMENTATION The training program employs a risk-based audience segmentation model that assigns each individual within the scope of the program to one of five tiers based on their role, responsibilities, and exposure to BSA/AML risk. This tiered approach ensures that training is appropriately tailored — both in depth and content — to the specific needs of each audience segment, consistent with the FFIEC

V. CURRICULUM OUTLINE This section sets forth the substantive content of each training module that comprises BRB's enterprise-wide BSA/AML training curriculum. Each module is designed to address specific regulatory requirements, Consent Order findings, and operational needs. The modules are cross-referenced to the audience tiers identified in Section IV and to the specific articles and provisions of the Consent Order