Contract analysis

1. INTRODUCTION AND PURPOSE This Appendix A (the "Scope of Work" or "SOW") is attached to and forms an integral part of the Independent Consultant Engagement Agreement, dated February 10, 2025 (the "Engagement Agreement"), between Belmont Ridge Bank National Association ("BRB" or the "Bank"), OCC Charter No. 48271, FDIC Certificate No. 31845, headquartered at 680 Lexington Avenue, 22nd Floor, New York, NY 10022, and

2. BACKGROUND 2.1 Regulatory Context The OCC conducted a targeted BSA/AML examination of Belmont Ridge Bank National Association commencing in March 2024 and concluding in September 2024, representing a six-month examination cycle focused on the Bank's BSA/AML compliance program, OFAC sanctions screening operations, customer due diligence practices, transaction monitoring systems, and governance and oversight structu

3. THORNFIELD ENGAGEMENT TEAM Thornfield shall staff this engagement with a dedicated team of experienced BSA/AML, OFAC, and financial crimes compliance professionals. The core engagement team is as follows: Dr. Vivian Castellano, Managing Director, Financial Crimes Advisory — Engagement Lead. Dr. Castellano shall serve as the overall Engagement Lead and shall bear primary responsibility for engagement management, qu

4. ENGAGEMENT PHASES AND TIMELINE 4.1 Overview of Phases The engagement shall be organized into four sequential phases over a total engagement period of twelve (12) months, commencing in February 2025 and concluding in February 2026. The phases, their descriptions, and target dates are set forth in the following table: The total engagement period runs from the Effective Date of February 10, 2025 through February 15,