Contract analysis

I. The Wells Notification On March 8, 2024, you and Assistant Director Gregory Bonham conducted a telephonic Wells notification call with the undersigned and our colleagues at Calderwood & Harkness. During that call, the Staff advised that it was considering recommending that the Commission institute an enforcement action against BRB for alleged violations of the federal securities laws. Specifically, the Staff ident

II. Request for Extension BRB respectfully requests that the Staff grant a one-week extension of the Current Deadline for filing its Wells Submission, from March 29, 2024 to April 5, 2024 (the "Proposed Deadline"). This represents a modest, one-time request for seven additional calendar days beyond the Current Deadline. BRB does not anticipate seeking any further extensions of time. We recognize that the Wells proces

III. Justification for the Requested Extension The requested extension is warranted by several factors, each of which we describe in detail below. A. Complexity of the Underlying Accounting Issues The Investigation centers on BRB's allowance for credit losses ("ACL") as reported in its consolidated financial statements, and specifically on the Bank's application of the current expected credit loss methodology ("CECL"

IV. Assurance of Continued Cooperation We wish to reiterate, in the strongest terms, that BRB remains fully committed to its cooperative posture throughout the Investigation. BRB has cooperated extensively with the Staff's inquiry from its inception, as evidenced by the Bank's timely and voluminous document productions, the voluntary provision of three witnesses for investigative testimony, and the constructive dialo

V. Proposed New Deadline and Request for Confirmation To summarize, BRB respectfully requests that the Staff extend the deadline for filing BRB's Wells Submission from March 29, 2024 to April 5, 2024. We respectfully request the Staff's confirmation of this extension at the earliest convenience. Should you have any questions regarding this request, or should you wish to discuss the matter further, please do not hesit