Contract analysis

ARTICLE I — PURPOSE The Risk Committee (the "Committee") is a standing committee of the Board of Directors (the "Board") of Belmont Ridge Bank NA (the "Bank"), a national bank chartered under the laws of the United States (OCC Charter Number 24-0738), with its principal office and headquarters located at 600 Lexington Avenue, 34th Floor, New York, NY 10022. The purpose of the Committee is to assist the Board in fulfi

ARTICLE II — COMPOSITION AND MEMBERSHIP

Section 2.1 — Number of Members The Committee shall consist of no fewer than members of the Board, each of whom shall be an independent director as defined in Section 2.2 of this Charter. The current composition of the Committee consists of five (5) independent directors. The Board shall appoint members of the Committee annually, at or promptly following the annual meeting of the Board, or more frequently as needed t

Section 2.2 — Independence Requirements Each member of the Committee shall satisfy the independence requirements of: (a) the applicable rules and listing standards of the Nasdaq Stock Market applicable to risk committee members of listed companies; (b) applicable regulations and supervisory guidance of the Office of the Comptroller of the Currency, including the heightened standards applicable to national banks with

Section 2.4 — Chair The Board shall designate a Chair of the Committee (the "Committee Chair") from among the independent members of the Committee. The current Committee Chair is Priya Venkataraman, who has served as an independent director of the Bank since 2020 and who previously served as Chief Risk Officer of Lakemont Financial Corporation, a bank holding company with approximately $52 billion in total consolidat

Section 2.5 — Removal and Vacancies Members of the Committee may be removed by the Board at any time, with or without cause, by resolution adopted by a majority of the full Board. Any vacancy on the Committee, whether arising from removal, resignation, retirement, or any other cause, shall be filled by the Board upon the recommendation of the Governance & Nominating Committee. A member appointed to fill a vacancy sha

Section 3.2 — Quorum A majority of the members of the Committee then in office shall constitute a quorum for the transaction of business at any meeting of the Committee. All actions of the Committee shall be taken by a majority vote of the members present at a meeting at which a quorum is present. The Committee may act by unanimous written consent in lieu of a meeting, in accordance with applicable law and the Bank's

Section 3.3 — Attendance by Non-Members The Committee may invite to any meeting such members of management, officers, employees, and advisors as the Committee deems appropriate, including without limitation the Chief Risk Officer, the Chief Compliance Officer, the BSA Officer, the Chief Financial Officer (Catherine L. Ng), members of the internal audit department, the Bank's external auditors (Ridgewell & Haines LLP,

Section 3.4 — Agendas and Materials

Section 3.5 — Minutes and Reporting The Committee shall maintain written minutes of its meetings, which shall be prepared by the Corporate Secretary or his or her designee and shall be filed with the corporate records of the Bank. Minutes shall be approved by the Committee at its next regularly scheduled meeting or by such other process as the Committee Chair may direct. The Committee Chair shall report to the full B

ARTICLE IV — DUTIES AND RESPONSIBILITIES The Committee shall have the following duties and responsibilities, subject to the overriding authority of the full Board. The enumeration of specific duties and responsibilities in this Article IV is not intended to limit the scope of the Committee's authority, and the Committee may take such other actions and exercise such other powers as it deems necessary or appropriate to

Section 4.1 — Enterprise Risk Oversight The Committee shall oversee the Bank's enterprise risk management framework, including the policies, procedures, systems, and practices for identifying, measuring, monitoring, and managing material risks across the organization. The Committee's oversight shall extend to all business lines, legal entities, and functions of the Bank, and shall encompass both on-balance-sheet and

Section 4.2 — Risk Appetite and Tolerance The Committee shall review and recommend to the Board for approval the Bank's Risk Appetite Statement and enterprise-wide risk limits. The Risk Appetite Statement shall articulate the aggregate level and types of risk that the Bank is willing to accept in pursuit of its strategic objectives, and shall be expressed through both qualitative statements and quantitative metrics.

Section 4.3 — Chief Risk Officer Oversight

Section 4.4 — Risk Management Staffing and Resources

Section 4.5 — Regulatory and Compliance Risk The Committee shall oversee the Bank's compliance risk management framework, including oversight of the compliance function, the Bank Secrecy Act and Anti-Money Laundering ("BSA/AML") program, and the Bank's adherence to applicable laws, regulations, and supervisory guidance. The Committee shall receive regular reports from the Chief Compliance Officer and the BSA Officer

Section 4.6 — Coordination with Other Committees The Committee shall coordinate with the Audit Committee on matters involving internal controls over financial reporting, internal audit activities, and financial reporting risk, in order to ensure comprehensive and non-duplicative oversight of the Bank's control environment.

Section 4.7 — Stress Testing and Capital Adequacy

Section 4.8 — Escalation Protocol for Enterprise Risk Matters

Section 4.8(a) — Escalation Triggers

Section 4.8(b) — Escalation Timelines

Section 4.8(c) — Escalation Reporting and Documentation

Section 4.8(d) — Independent Risk-Assessment Resources for Escalation Events

Section 4.8(e) — Coordination with Regulatory Authorities

Section 4.9 — Risk-Related Policies The Committee shall review and approve, or recommend to the Board for approval, all material risk-related policies of the Bank, including but not limited to the following: (a) Enterprise Risk Management Policy; (b) Credit Risk Policy; (c) Market Risk Policy; (d) Liquidity Risk Policy; (e) Operational Risk Policy; (f) Compliance Risk Policy; (g) Bank Secrecy Act and Anti-Money Laund

ARTICLE V — DIRECT REPORTING LINE OF THE CHIEF RISK OFFICER

ARTICLE VI — AUTHORITY AND RESOURCES

Section 6.1 — Authority The Committee shall have full authority to investigate any matter within the scope of its responsibilities under this Charter, the Bank's Bylaws, and any applicable resolution of the Board. In carrying out any such investigation, the Committee shall have direct and unrestricted access to any officer, employee, or agent of the Bank and of Belmont Ridge Financial Group, Inc., and each such perso

Section 6.2 — Funding The Bank shall provide the Committee with appropriate funding, as determined by the Committee in its sole discretion, for: (a) compensation to any independent consultants, legal counsel, and other advisors retained by the Committee; (b) ordinary administrative expenses of the Committee, including meeting expenses, travel, and materials; and (c) any other purposes the Committee deems necessary or

ARTICLE VII — ANNUAL ASSESSMENT The Committee shall conduct an annual self-assessment of its performance and effectiveness. The results of the self-assessment shall be reported to the Governance & Nominating Committee (currently chaired by Margaret R. Ellsworth) and to the full Board.

ARTICLE VIII — REVIEW AND AMENDMENT OF CHARTER This Charter shall be reviewed at least annually by the Committee, and any proposed amendments shall be recommended to the full Board for approval. The Committee shall ensure that the Charter remains current and responsive to changes in applicable law, regulation, supervisory guidance, and best practices in risk governance.

ARTICLE IX — EFFECTIVE DATE AND APPROVAL This Amended and Restated Charter of the Risk Committee of the Board of Directors of Belmont Ridge Bank NA shall become effective upon approval by the Board of Directors. The target date for Board consideration and approval of this Charter is the October 2025 regularly scheduled meeting of the Board, consistent with the Calderwood & Harkness engagement timeline, which targets