Contract analysis

I. EXECUTIVE SUMMARY Belmont Ridge Bank National Association ("BRB" or the "Bank") respectfully submits this Interim Status Report on Suspicious Activity Report Backlog Clearance (this "Report") to the Office of the Comptroller of the Currency ("OCC") in compliance with the March 31, 2025 interim reporting deadline established under Article V of Consent Order No. OCC-2025-003 (the "Consent Order"). The purpose of thi

II. BACKGROUND A. Consent Order Context On January 15, 2025, the OCC issued Consent Order No. OCC-2025-003 against Belmont Ridge Bank National Association, a national banking association organized under the laws of the United States, with its principal office located at 680 Lexington Avenue, 22nd Floor, New York, NY 10022. The Consent Order was the product of the OCC's targeted BSA/AML examination of BRB, which was c

III. SAR BACKLOG CLEARANCE — SCOPE AND METHODOLOGY A. Backlog Definition The universe of alerts subject to the SAR backlog clearance effort (the "Backlog" or "Backlog Alerts") consists of 2,400 transaction monitoring alerts generated by BRB's Veridian TMS v.8.3 system that were identified by the OCC as unreviewed or undispositioned as of the conclusion of the OCC's targeted BSA/AML examination in September 2024. For

1. Transaction Data Retrieval and Analysis: The assigned analyst retrieves and reviews the underlying transaction data that triggered the alert, including transaction amounts, dates, originator and beneficiary information, transaction descriptions, and relevant metadata from BRB's core banking system and the Veridian TMS v.8.3 platform.

2. Customer Account Review: The analyst reviews the customer's account profile, transaction history, account opening documentation, and any prior alerts or SARs associated with the customer to establish context for the alert activity.

3. CDD/EDD File Review: The analyst reviews the customer's CDD and, where applicable, EDD documentation to assess whether the alerted activity is consistent with the customer's known risk profile, expected account activity, source of funds, and source of wealth. Where CDD/EDD files are incomplete or outdated, the analyst documents the deficiency and coordinates with BRB's CDD/EDD remediation team to obtain supplement

4. Open-Source and Database Research: The analyst conducts open-source research and database searches (including adverse media screening, beneficial ownership databases, and sanctions screening tools) to identify any additional risk-relevant information concerning the customer or the transaction counterparties.

5. Narrative Assessment: The analyst prepares a written narrative assessment documenting the alert details, the investigation conducted, the findings, and the analyst's recommended disposition.

6. Disposition Recommendation: Based on the investigation, the analyst recommends one of the following disposition outcomes: (a) SAR Filing Required: The investigation reveals sufficient indicia of known or suspected suspicious activity to warrant the filing of a SAR with FinCEN. The alert proceeds to the SAR drafting stage, followed by quality review by senior BRB compliance staff, and submission to FinCEN through t

IV. RESOURCE DEPLOYMENT A. Pinnacle Compliance Solutions LLC — Temporary Staffing To address the immediate staffing shortfall identified as a root cause of the SAR backlog deficiency, BRB engaged Pinnacle Compliance Solutions LLC ("Pinnacle") under a Managed Services Agreement (Statement of Work Reference: PCS-BRB-2025-0012, effective February 10, 2025) to provide 30 full-time-equivalent BSA/AML analysts for a 12-mon

V. PROGRESS TO DATE (AS OF MARCH 31, 2025) A. Quantitative Progress As of March 31, 2025, BRB has made the following quantitative progress toward clearance of the 2,400-alert Backlog: Since the full deployment of the 30-FTE Pinnacle analyst team on March 17, 2025, BRB has achieved a weekly average disposition rate of approximately 176 alerts per week. This rate represents a significant increase from the pre-deploymen

VI. COORDINATION WITH INDEPENDENT CONSULTANT Thornfield Consulting Group LLC ("Thornfield"), engaged as the OCC-mandated independent consultant under Engagement Reference TCG-BRB-2025-001, commenced its on-site assessment on March 1, 2025. Thornfield's engagement team is led by Dr. Vivian Castellano, Managing Director, Financial Crimes Advisory, and includes the following senior team members: • Robert Eastman, Senior

VII. COORDINATION WITH FINCEN The Financial Crimes Enforcement Network ("FinCEN") is monitoring BRB's SAR filing remediation in coordination with the OCC. As of the date of this Report, FinCEN has not filed a separate enforcement action against BRB, although FinCEN has reserved its enforcement rights in connection with the BSA/AML deficiencies identified in the OCC examination. BRB understands that FinCEN's decision

VIII. CHALLENGES AND RISK FACTORS BRB has identified the following challenges and risk factors that have affected or may affect the pace, scope, or outcome of the SAR backlog clearance effort. BRB is actively managing these risks and will promptly communicate to the OCC if any of these factors materially jeopardizes the June 30, 2025 clearance deadline. Staffing Ramp-Up Timing. Full deployment of the 30 Pinnacle FTEs