Contract analysis

I. PURPOSE AND BACKGROUND A. Purpose. The purpose of this memorandum is to document, for the internal files of Calderwood & Harkness LLP ("C&H" or the "Firm"), the engagement team composition, individual billing rates, projected hours allocation by engagement phase and workstream, role descriptions, and reporting structure for the C&H team staffed on the Belmont Ridge Bank National Association ("BRB" or the "Bank") B

II. ENGAGEMENT TEAM COMPOSITION The following sections set forth the composition of the C&H engagement team, together with each team member's role, responsibilities, billing rate, relevant experience, and reporting relationships. The team has been assembled to provide the Bank with a comprehensive range of expertise spanning banking regulatory enforcement, BSA/AML compliance, OFAC sanctions, intellectual property and

III. RATE SCHEDULE SUMMARY The following table summarizes the 2025 hourly billing rates for all members of the C&H engagement team staffed on this matter: Rate Basis. The rates set forth above are the Firm's 2025 standard hourly rates for each respective team member, as established in the engagement letter dated February 10, 2025. These rates apply to all work performed in connection with C&H Matter No. 1045-00002 du

IV. PROJECTED HOURS ALLOCATION — PHASE 1 (FEBRUARY 10, 2025 – MAY 15, 2025) A. Phase 1 Overview Phase 1 of the Engagement encompasses the initial assessment, regulatory engagement, and remediation planning period. The duration of Phase 1 is approximately 95 calendar days (13.5 weeks), running from the Engagement commencement date of February 10, 2025, through the Comprehensive Remediation Action Plan submission deadl

V. PROJECTED HOURS ALLOCATION — PHASE 2 (MAY 16, 2025 – FEBRUARY 15, 2026) A. Phase 2 Overview Phase 2 of the Engagement commences on May 16, 2025, following the submission of the Comprehensive Remediation Action Plan to the OCC, and continues through February 15, 2026, which coincides with the Consent Order's deadline for the Bank's compliance self-certification. The duration of Phase 2 is approximately nine (9) mon

VI. TOTAL ENGAGEMENT HOURS & FEE PROJECTION SUMMARY The following table presents the combined hours and fee projections for the full Engagement across both Phase 1 and Phase 2: Budget Reconciliation. The core team projected fees of approximately $3,242,400 represent approximately 40.5% of the total $8,000,000 engagement budget. The remaining budget capacity of approximately $4,757,600 is allocated to the following ca

VII. STAFFING FLEXIBILITY & SUPPLEMENTAL RESOURCES The staffing plan set forth in this memorandum establishes the core engagement team for the BRB BSA/AML remediation matter. However, given the scale, complexity, and duration of the Engagement, it is anticipated that supplemental resources will be required on a periodic or sustained basis during certain phases of the work. Authorization for Supplemental Staffing. The

VIII. KEY CLIENT AND THIRD-PARTY CONTACTS FOR STAFFING COORDINATION The following tables identify the primary BRB client contacts and key third-party contacts for purposes of workstream coordination and communication. A. Primary BRB Contacts B. Key Third-Party Contacts All engagement team members should direct communications with the individuals listed above through the appropriate channels as determined by the Respo

IX. ADMINISTRATIVE NOTES The following administrative protocols apply to all members of the engagement team in connection with this matter: Time Recording. All time entries are to be recorded under C&H Matter No. 1045-00002. Team members should use task-based billing codes consistent with the Bank's outside counsel guidelines, which have been distributed to all team members. Time entries should be recorded contempora

X. APPROVAL This Staffing Plan & Rate Schedule is approved for implementation in connection with C&H Matter No. 1045-00002. APPROVED: CALDERWOOD & HARKNESS LLP By: ________ Name: Philip Hartmann Title: Partner, Banking & Finance Practice Group Role: Responsible Partner Date: ________ ACKNOWLEDGED — BILLING ARRANGEMENTS CONFIRMED: CALDERWOOD & HARKNESS LLP By: ________ Name: Marcus Delgado Title: Partner, intellectual