Contract analysis

I. Entry of Appearance and Identification of Client Calderwood & Harkness LLP ("Calderwood & Harkness" or "C&H") has been retained by Belmont Ridge Bank National Association ("BRB" or the "Bank") in connection with the above-referenced matter. By this letter, Calderwood & Harkness enters its appearance as counsel to BRB in connection with the investigation referenced in the Staff's voluntary request letter dated Sept

II. Acknowledgment of Receipt of the Voluntary Request Letter BRB confirms that it received the Staff's voluntary request letter dated September 18, 2023 (the "Voluntary Request Letter"). We acknowledge receipt of this letter and have carefully reviewed its contents with our client. BRB understands that the Voluntary Request Letter relates to the Bank's public filings with the Commission, specifically the following:

III. Confirmation of BRB's Cooperation Posture BRB wishes to affirmatively state, at the outset, that the Bank intends to cooperate fully with the Staff's inquiry. BRB is committed to transparency and to working constructively with the Division of Enforcement to address the Staff's questions and concerns. The Bank recognizes that meaningful cooperation, as set forth in the Commission's framework for evaluating cooper

IV. Request for Meet-and-Confer Regarding Scope and Timing BRB respectfully requests an opportunity to meet and confer with the Staff at the Staff's earliest convenience to discuss the scope and timing of BRB's response to the Voluntary Request Letter. We believe that an early dialogue will help ensure that BRB's collection, review, and production efforts are appropriately targeted and responsive to the Staff's areas

V. Preliminary Identification of Key Contacts at BRB To facilitate the Staff's planning and to provide context for the Bank's organizational structure as it relates to the subject matter of the inquiry, BRB wishes to identify the following key individuals whose roles are relevant to the matters under review: Derek Sung, General Counsel and Chief Legal Officer. Mr. Sung serves as the primary internal legal contact for

VI. Reservation of Rights BRB wishes to make clear that this letter and BRB's cooperation with the Staff's inquiry do not constitute, and shall not be construed as, an admission of any wrongdoing, violation of any federal or state securities law or regulation, or any deficiency in the Bank's public filings, financial statements, disclosures, or internal controls over financial reporting. BRB has at all times endeavor

VII. Closing BRB looks forward to working cooperatively with the Staff to resolve this inquiry promptly and efficiently. The Bank is committed to providing the Staff with the information necessary to address the Staff's questions and concerns, and BRB believes that the collaborative approach outlined in this letter will best serve the interests of all parties. We respectfully request that the Staff contact Victoria C