Contract analysis

I. BACKGROUND: OCC SUPERVISORY RELATIONSHIP WITH BELMONT RIDGE BANK NA A. Overview of BRB's Charter and Regulatory Status Belmont Ridge Bank National Association is a national banking association organized and existing under the National Bank Act, 12 U.S.C. §§ 21 et seq., and chartered by the Office of the Comptroller of the Currency under OCC Charter No. 24891. As a national bank, BRB is subject to the primary super

II. SUMMARY OF OCC SUPERVISORY INTERACTIONS REGARDING ACL METHODOLOGY A. Scope of OCC Review As part of its regular supervisory program for BRB, the OCC conducted a substantive review of the Bank's allowance for credit losses ("ACL") methodology, with particular attention to the application of the CECL framework (ASC 326) to the BridgeFin consumer lending portfolio. This review was undertaken within the context of th

III. CONCURRENT SUPERVISORY ASSESSMENT DURING SEC INVESTIGATION PERIOD A. OCC Awareness of SEC Inquiry Following the commencement of the SEC investigation — which originated with a voluntary document request letter from the SEC Division of Enforcement dated September 18, 2023, and progressed to the issuance of a Formal Order of Investigation, No. EN-2023-0947, dated October 12, 2023 — BRB promptly notified the OCC of

IV. SIGNIFICANCE OF OCC FINDINGS FOR THE WELLS SUBMISSION A. The OCC's Concurrent Assessment Supports the Reasonableness of BRB's CECL Methodology The OCC is the primary prudential regulator of national banks and possesses the deepest institutional expertise in evaluating the adequacy of national banks' allowances for credit losses. The OCC's supervisory mandate under the National Bank Act and implementing regulation

V. CONCLUSION The OCC's concurrent supervisory assessment of BRB's allowance for credit losses methodology and BridgeFin portfolio credit-quality reporting — conducted by experienced bank examiners with full and unrestricted access to granular loan-level data, model documentation, and all relevant internal records — found no material deficiency in BRB's approach and resulted in no enforcement or supervisory action of