Contract analysis

I. Introduction and Purpose This Exhibit provides a detailed chronological account of the disclosure enhancements voluntarily undertaken by Belmont Ridge Bank National Association ("BRB" or the "Bank") with respect to its BridgeFin digital lending portfolio (the "BridgeFin Portfolio" or "BridgeFin"). The timeline set forth herein demonstrates that BRB proactively improved investor transparency regarding credit-qualit

II. Baseline Disclosure Framework — FY 2021 Form 10-K and Prior Periods A. Initial BridgeFin Disclosures (FY 2020 10-K and FY 2021 10-K) When the BridgeFin platform launched in the third quarter of 2020, BRB's initial disclosures treated the BridgeFin portfolio as part of the Bank's broader consumer loan segment in its Annual Report on Form 10-K for the fiscal year ended December 31, 2020 (the "FY 2020 10-K"). At tha

III. FY 2022 Form 10-K (Filed February 28, 2023) — Disclosures at the Time of the Filings Under Review The Annual Report on Form 10-K for the fiscal year ended December 31, 2022 (the "FY 2022 10-K"), filed on February 28, 2023, is the principal filing under review in the Staff's investigation. Set forth below is a description of the BridgeFin-related disclosures contained in that filing, which BRB submits were materi

IV. Q1 2023 Form 10-Q (Filed May 10, 2023) A. Incremental Enhancements The Quarterly Report on Form 10-Q for the quarter ended March 31, 2023 (the "Q1 2023 10-Q"), filed on May 10, 2023, reflected incremental enhancements to BRB's BridgeFin disclosures as management continued to refine its reporting in the ordinary course of business. The Q1 2023 10-Q added a brief qualitative discussion in the MD&A section regarding

V. Q2 2023 Form 10-Q (Filed August 9, 2023) A. Disclosures. The Quarterly Report on Form 10-Q for the quarter ended June 30, 2023 (the "Q2 2023 10-Q"), filed on August 9, 2023, maintained BridgeFin sub-segment reporting consistent with the framework established in the FY 2022 10-K and carried forward in the Q1 2023 10-Q. Credit quality tables continued to present aggregate-level aging data for the BridgeFin portfolio

VI. September 18, 2023 — SEC Voluntary Request Letter Received On September 18, 2023, Senior Staff Attorney Andrea Felton of the SEC's Division of Enforcement issued a voluntary request letter to BRB, opening an inquiry into BRB's disclosures relating to the BridgeFin portfolio (File No. HO-14287). The letter requested production of documents and information relating to, among other things, BRB's ACL methodology for

VII. Q3 2023 Form 10-Q (Filed November 9, 2023) — Major Voluntary Disclosure Enhancements The Quarterly Report on Form 10-Q for the quarter ended September 30, 2023 (the "Q3 2023 10-Q"), filed on November 9, 2023, represented a significant step forward in BRB's disclosure of BridgeFin credit quality information. The enhancements introduced in this filing addressed each of the principal areas of disclosure granularity

VIII. FY 2023 Form 10-K (Filed February 27, 2024) — Further Enhancements The Annual Report on Form 10-K for the fiscal year ended December 31, 2023 (the "FY 2023 10-K"), filed on February 27, 2024, carried forward and further expanded the disclosure enhancements introduced in the Q3 2023 10-Q, representing the most comprehensive set of BridgeFin disclosures that BRB had published to date. A. Continued and Expanded Vi

IX. Summary of Disclosure Enhancements — Comparative Table The following table summarizes the progressive enhancement of BRB's BridgeFin-related disclosures across the filing periods covered by this Exhibit. The table demonstrates the systematic and voluntary nature of BRB's disclosure improvements, with the most significant additions appearing in the Q3 2023 10-Q and FY 2023 10-K. As the table illustrates, BRB's dis

X. Conclusion The chronology set forth in this Exhibit demonstrates that BRB's disclosure enhancements with respect to the BridgeFin portfolio were:

1. Initiated before the SEC investigation began. Internal Disclosure Committee and Risk Management Committee discussions regarding expanded vintage-level credit reporting commenced in the first and second quarters of 2023 — months before the SEC's September 18, 2023 voluntary request letter. The preliminary decision to introduce vintage-level delinquency tables in the Q3 2023 10-Q was reached at the Disclosure Commit

2. Implemented voluntarily in Q3 2023 and further expanded in FY 2023. The significant disclosure enhancements introduced in the Q3 2023 10-Q — including vintage-level delinquency tables, quantification of modified and re-aged loans, expanded MD&A narrative, and qualitative overlay transparency — were not mandated by any SEC comment letter, enforcement directive, consent order, or other regulatory requirement. They w

3. Responsive to evolving investor needs and industry best practices, not solely to the SEC investigation. BRB's disclosure enhancements were informed by peer institution benchmarking, industry developments in digital lending disclosure, dialogue with Whitfield Keane LLP regarding emerging audit and disclosure expectations, and input from BRB's own Risk Management Committee regarding the utility of vintage-level data

4. Consistent with BRB's longstanding cooperative posture with its regulators. BRB has maintained a satisfactory composite CAMELS rating of 2 under OCC Charter No. 24891 and has a history of constructive engagement with its prudential regulators. BRB's approach to disclosure enhancement reflects the same cooperative and proactive posture that has characterized its regulatory relationships more broadly. Taken together