1045-00007 · Client 1045 · Correspondence/SEC

supplemental-letter-to-sec-staff.docx DOCUMENT Litigation

13 / 35 ← → ✕

CALDERWOOD & HARKNESS LLP Attorneys at Law

425 Lexington Avenue, 30th Floor New York, New York 10017

Telephone: (212) 558-4000 Facsimile: (212) 558-3588 www.calderwoodharkness.com

April 22, 2024

VIA ECF AND HAND DELIVERY

Gregory Bonham Assistant Director, Financial Fraud Unit Division of Enforcement U.S. Securities and Exchange Commission 100 F Street NE Washington, D.C. 20549

Renata Moss Branch Chief Division of Enforcement U.S. Securities and Exchange Commission 100 F Street NE Washington, D.C. 20549

Re: In the Matter of Belmont Ridge Bank National Association SEC File No. HO-14287; Formal Order No. EN-2023-0947 Supplemental Submission Following Wells Submission of April 5, 2024

Dear Mr. Bonham and Ms. Moss:

I. Introduction and Purpose of Letter

This firm represents Belmont Ridge Bank National Association ("BRB" or the "Bank") (Nasdaq: BRDG) in the above-referenced investigation being conducted by the Division of Enforcement (the "Staff") of the U.S. Securities and Exchange Commission (the "Commission"). We write to supplement the Wells Submission filed on behalf of BRB on April 5, 2024 (the "Wells Submission"), which comprised forty-two (42) pages of narrative argument plus Exhibits A through G, with updated credit-quality data and related information that we believe is material to the Staff's ongoing analysis.

Specifically, the purpose of this supplemental letter is threefold. First, we provide the Staff with updated credit-quality data from BRB's BridgeFin digital lending division for the quarter ended December 31, 2023 ("Q4 2023"), including delinquency rates, net charge-off rates, and performance data on the subset of re-aged and modified loans that have been a focal point of the Staff's inquiry. Second, we bring to the Staff's attention BRB's updated allowance for credit losses ("ACL") as reported in BRB's Annual Report on Form 10-K for the fiscal year ended December 31, 2023 ("FY 2023 Form 10-K"), filed with the Commission on February 27, 2024. Third, we explain the significance of these data points in the context of the arguments set forth in the Wells Submission.

The Q4 2023 data was not yet available in final audited form at the time we filed the Wells Submission, and the underlying audit work papers were finalized by BRB's independent registered public accounting firm only on February 23, 2024. We are now providing this information to give the Staff the most current and complete picture of BRB's credit-quality trends and ACL methodology, and to ensure that the Staff's analysis rests on the fullest possible factual record.

BRB continues to cooperate fully with the Staff's investigation and remains committed to providing any further information or documentation the Staff may require. Nothing in this supplemental submission is intended to waive any privileges, defenses, or arguments previously asserted, all of which are expressly preserved.

II. Background and Context

By way of brief background, and as more fully detailed in Sections I through III of the Wells Submission, the Staff's investigation was opened on September 18, 2023, when BRB received a voluntary request letter from the Division of Enforcement seeking documents and information concerning the adequacy of BRB's ACL disclosures for its BridgeFin digital lending portfolio. The filings at issue are BRB's Annual Report on Form 10-K for the fiscal year ended December 31, 2022 ("FY 2022 Form 10-K"), filed with the Commission on February 28, 2023; BRB's Quarterly Report on Form 10-Q for the quarter ended March 31, 2023 ("Q1 2023 Form 10-Q"), filed with the Commission on May 10, 2023; and BRB's Quarterly Report on Form 10-Q for the quarter ended June 30, 2023 ("Q2 2023 Form 10-Q"), filed with the Commission on August 9, 2023.

As articulated by the Staff during the Wells call conducted on March 8, 2024, the core issue under investigation is whether BRB's reported ACL of $143.5 million — representing 3.50% of the $4.1 billion in outstanding BridgeFin loans as of December 31, 2022 — materially understated expected credit losses in BRB's FY 2022 Form 10-K. The Staff's concern centers on BRB's treatment of 12,847 re-aged and modified BridgeFin loans with an aggregate outstanding principal balance of approximately $236.4 million. According to the Staff's preliminary analysis, these loans were treated as "current" following modification when, in the Staff's view, they should have been classified in their original vintage delinquency buckets for purposes of the CECL loss-rate estimation. The Staff's preliminary view, as communicated during the March 8 Wells call, is that BRB's ACL should have been approximately $180.8 million, or 4.41% of outstanding BridgeFin loans, representing a potential understatement of $37.3 million.

As set forth at length in the Wells Submission, BRB respectfully disagrees with the Staff's preliminary conclusions for several independently sufficient reasons:

(a) BRB's CECL methodology, developed and maintained in accordance with Accounting Standards Codification Topic 326, Financial Instruments — Credit Losses ("ASC 326"), was reasonable and fell within the range of acceptable estimates, as ASC 326 expressly contemplates that different institutions applying the standard to similar portfolios may reach different but equally valid estimates;

(b) BRB's treatment of re-aged and modified loans as "current" following modification was consistent with guidance published in the Office of the Comptroller of the Currency's Comptroller's Handbook: Allowance for Credit Losses (updated April 2023) and was disclosed in the Management's Discussion and Analysis ("MD&A") sections of BRB's relevant periodic reports;

(c) any difference between BRB's reported ACL and the Staff's preliminary adjusted figure reflects the exercise of good-faith professional judgment — inherent in the estimation process that ASC 326 requires — rather than a material misstatement of BRB's financial condition;

(d) there is no evidence of scienter on the part of BRB, its officers, or any other person associated with the Bank's financial reporting process, and the Staff has not identified any such evidence; and

(e) a peer-bank comparison analysis, presented in Wells Submission Exhibit E, demonstrates that BRB's ACL coverage ratio of 3.50% fell within the interquartile range (25th to 75th percentile) of ACL coverage ratios reported by a cohort of fifteen comparable digital-lending institutions for the same period.

We incorporate by reference the full arguments, supporting data, and exhibits presented in the Wells Submission and do not repeat them in detail here. Rather, this supplemental letter focuses on the Q4 2023 and full-year FY 2023 data that has become available since the Wells Submission was filed, and which we submit strongly corroborates BRB's position on every element of the Staff's inquiry.

III. Updated BridgeFin Credit Metrics — Q4 2023

The data presented in this section is drawn from BRB's FY 2023 Form 10-K, BRB's internal credit-risk reporting systems, and the work papers of BRB's independent auditor, Whitfield Keane LLP. We have reviewed this data with BRB's Chief Risk Officer, Annette Kowalski, and BRB's Chief Accounting Officer, Raymond Hu, and are authorized to represent that the figures set forth below are accurate and consistent with BRB's audited financial statements.

A. 90+ Day Delinquency Rate

As of December 31, 2023, the BridgeFin portfolio's 90-plus-day delinquency rate — defined as the aggregate outstanding principal balance of loans 90 or more days past due as a percentage of total outstanding BridgeFin loans — declined to 1.48%. This figure is reported in Note 7 (Loans and Allowance for Credit Losses) to BRB's consolidated financial statements included in the FY 2023 Form 10-K at pages F-32 through F-41.

This 1.48% delinquency rate compares favorably to each of the relevant benchmarks that have been discussed in this investigation:

• BRB's FY 2022 Reported Figure: BRB reported a 90-plus-day delinquency rate of 1.72% for the BridgeFin portfolio as of December 31, 2022, as set forth in the FY 2022 Form 10-K. The Q4 2023 figure of 1.48% thus reflects a decline of 24 basis points, or approximately 14%, on a year-over-year basis.

• Staff's Preliminary Adjusted Figure: During the March 8, 2024 Wells call and in the accompanying staff memorandum, the Staff indicated that its preliminary analysis — which reclassified re-aged and modified loans into their original vintage delinquency buckets — yielded an adjusted 90-plus-day delinquency rate of approximately 2.38% as of December 31, 2022. The actual Q4 2023 delinquency rate of 1.48% is 90 basis points below the Staff's adjusted figure, representing a difference of nearly 38%.

The significance of this data cannot be overstated. The 1.48% delinquency rate as of December 31, 2023 reflects the actual observed performance of the BridgeFin portfolio — including the re-aged and modified loans that are the centerpiece of the Staff's inquiry — over a full twelve-month period following the reporting dates at issue. In other words, the loans that the Staff's preliminary analysis suggested would perform materially worse than BRB's CECL model projected have, in fact, performed meaningfully better than even BRB's own reported figures, let alone the Staff's adjusted estimates.

Moreover, this improvement in portfolio delinquency occurred notwithstanding the continued maturation of the post-Q2 2021 vintage cohorts that were a particular focus of the Staff's inquiry. As noted in the Wells Submission at pages 22–25 and Wells Submission Exhibit B, the Staff expressed concern that the post-Q2 2021 vintage cohorts — originated during a period of rapid BridgeFin growth — would exhibit elevated loss rates as they seasoned through their loss emergence periods. The Q4 2023 data demonstrates that these cohorts have, in fact, performed within the parameters originally modeled by BRB's credit-risk team, and that the loss emergence curves have not deviated materially from BRB's projections.

B. Net Charge-Off Rate

The BridgeFin portfolio's net charge-off rate also exhibited a consistently improving trend over the course of FY 2023, providing further corroboration of BRB's FY 2022 credit-quality assumptions. The quarterly net charge-off rates (annualized) for BridgeFin during FY 2023 were as follows:

As reported in BRB's FY 2022 Form 10-K, BridgeFin's full-year net charge-off rate for FY 2022 was 2.14%. The FY 2023 full-year net charge-off rate of 1.88% represents a 26-basis-point improvement, and the Q4 2023 quarterly figure of 1.67% reflects a particularly favorable trajectory entering 2024.

These figures stand in sharp contrast to the Staff's preliminary view, expressed during the Wells call, that BRB's FY 2022 vintage-cohort loss-rate assumptions implied an effective net charge-off rate closer to 3.05% on a through-the-cycle basis for the BridgeFin portfolio. The actual charge-off experience of the portfolio during FY 2023, when the loans at issue were in their most critical loss-emergence windows, demonstrates that BRB's original loss-rate assumptions were not only reasonable but proved to be somewhat conservative relative to actual outcomes. The declining charge-off trend throughout 2023 further validates BRB's modeling approach and the underlying assumptions embedded in its CECL framework as of the FY 2022 measurement date.

C. Re-Aged / Modified Loan Performance

Perhaps the most directly probative data concerns the performance of the 12,847 re-aged and modified loans ($236.4 million in aggregate outstanding principal balance as of December 31, 2022) that constitute the focal point of the Staff's inquiry. As the Staff is aware, these loans were modified through BRB's BridgeFin Borrower Assistance Program ("BAP") between Q3 2021 and Q4 2022, and were treated as "current" for delinquency-reporting and CECL-modeling purposes following modification — a treatment the Staff has questioned.

BRB has tracked the performance of this specific loan cohort on a monthly basis since the commencement of the Staff's investigation. As of December 31, 2023, the performance data for these 12,847 loans is as follows:

• Of the 12,847 loans, 10,917 (85.0%) remained current (0–29 days past due) as of December 31, 2023.

• An additional 978 loans (7.6%) were 30–59 days past due.

• 512 loans (4.0%) were 60–89 days past due.

• 289 loans (2.2%) were 90 or more days past due.

• 151 loans (1.2%) had been charged off during FY 2023.

• The cumulative net charge-off rate for this cohort through December 31, 2023 was 1.87%, compared with BRB's CECL model projection of a cumulative net charge-off rate of 2.20% for these loans at the time of the FY 2022 measurement date.

These results are significant for several reasons. First, the 85.0% current rate demonstrates that the overwhelming majority of borrowers who received modifications through the BAP have resumed — and sustained — regular payment performance, vindicating BRB's judgment that these borrowers represented curable, temporary delinquencies rather than the permanent credit impairments the Staff's preliminary analysis assumed. Second, the cumulative net charge-off rate of 1.87% for this cohort is not only within the range projected by BRB's CECL model, but is actually 33 basis points below BRB's own modeled projection of 2.20%, suggesting that BRB's original estimate was, if anything, conservative with respect to these loans. Third, and most importantly, these results confirm that BRB's treatment of these loans as "current" after modification was not only consistent with the regulatory guidance issued by the OCC — as discussed at length in Section IV of the Wells Submission — but was also substantively accurate as a predictive matter. The modifications achieved their intended purpose, borrowers returned to performing status, and the portfolio's loss experience validated BRB's credit-risk judgments.

IV. Updated ACL — FY 2023 Form 10-K

A. Increased ACL Figure

In its FY 2023 Form 10-K, filed with the Commission on February 27, 2024, BRB reported an ACL of $156.2 million for the BridgeFin portfolio. Total outstanding BridgeFin loans as of December 31, 2023 were approximately $4.27 billion, yielding an ACL coverage ratio of approximately 3.66%.

This represents an increase of $12.7 million from the $143.5 million ACL (3.50% coverage ratio) reported as of December 31, 2022. However, it is critical to understand the nature of this increase. The higher ACL does not reflect a correction or restatement of BRB's prior-period financial statements. BRB has not restated, and does not intend to restate, any previously filed periodic report or financial statement. Rather, the increase reflects enhanced qualitative overlays that BRB's management incorporated into the CECL model during FY 2023, as described in greater detail in Section IV.B below.

BRB's independent registered public accounting firm, Whitfield Keane LLP (Public Company Accounting Oversight Board Registration No. 2847, engagement partner Lorraine Dupont, CPA), issued an unqualified (clean) opinion on BRB's consolidated financial statements for FY 2023, including the ACL and the related provision for credit losses. Whitfield Keane's audit report, dated February 23, 2024, and included in the FY 2023 Form 10-K at pages F-2 through F-4, contains no qualifications, explanatory paragraphs regarding critical audit matters related to the ACL, or other indications of disagreement with BRB's management regarding the adequacy of the ACL for any period.

B. Nature of Enhanced Qualitative Overlays

The $12.7 million increase in the BridgeFin ACL during FY 2023 is attributable to enhanced qualitative adjustments that BRB's management implemented beginning in Q3 2023. These enhancements were developed and implemented under the direction of BRB's Chief Financial Officer, Patricia Navarrete; Chief Accounting Officer, Raymond Hu; and Chief Risk Officer, Annette Kowalski, working in coordination with BRB's Credit Risk Modeling Group and the BridgeFin business unit's risk management team.

The enhanced qualitative overlays include the following three principal components:

(i) Refined Vintage-Cohort Segmentation. BRB refined the granularity of its vintage-cohort segmentation for BridgeFin loans originated after Q2 2021 — the period during which the BridgeFin platform experienced its most rapid origination growth. The prior segmentation methodology grouped originations into semi-annual cohorts; the enhanced methodology segments originations into quarterly cohorts, permitting more precise loss-rate estimation for periods of varying credit conditions and origination volumes. This refinement responds, in part, to developments in industry practice and to the Staff's feedback during the investigative process regarding the granularity of BRB's vintage-level analysis.

(ii) Expanded Macroeconomic Scenario Weighting. BRB expanded the number and probability weighting of macroeconomic scenarios used as inputs to its CECL model. The prior methodology employed three scenarios (baseline, optimistic, and adverse) with probability weights of 50%, 20%, and 30%, respectively. The enhanced methodology employs five scenarios — including a severe adverse scenario and a moderately optimistic scenario — with revised probability weights that BRB's economics team determined more accurately captured the range of potential macroeconomic outcomes as of the measurement date. This refinement increases the ACL by giving greater weight to tail-risk economic scenarios while maintaining the model's overall calibration to expected loss outcomes.

(iii) Supplementary Qualitative Factors for Digital-Lending Channel Characteristics. BRB added qualitative adjustment factors to the CECL model that specifically address evolving credit characteristics unique to the digital-lending channel, including the BridgeFin platform's applicant demographic profile, digital-channel customer engagement metrics, and historical modification re-default rates. These factors are applied as supplementary adjustments to the quantitative model output and are documented in accordance with BRB's model risk management framework.

We wish to emphasize that each of these enhancements represents a prospective methodology improvement consistent with the ongoing refinement that ASC 326 contemplates and, indeed, encourages. ASC 326 recognizes that the CECL framework requires entities to continuously evaluate and update their methodologies, assumptions, and inputs as new information becomes available and as modeling techniques evolve. The enhancements adopted by BRB during FY 2023 reflect precisely this type of iterative improvement. They are not, and should not be construed as, admissions that BRB's prior-period ACL estimates were deficient, unreasonable, or in any way inconsistent with ASC 326.

In this connection, we note that BRB voluntarily enhanced its credit-quality disclosures in its Quarterly Report on Form 10-Q for the quarter ended September 30, 2023 ("Q3 2023 Form 10-Q"), filed with the Commission on November 9, 2023. As detailed in Wells Submission Exhibit C, the enhanced disclosures in the Q3 2023 Form 10-Q included (a) vintage-level delinquency tables disaggregated by quarterly origination cohort; (b) expanded MD&A discussion of the BridgeFin portfolio's credit-quality trends, modification activity, and re-default rates; and (c) additional quantitative disclosures regarding the macroeconomic scenarios and probability weights used in BRB's CECL model. These voluntary disclosure enhancements further demonstrate BRB's good faith and its commitment to transparent communication with investors and the Commission.

C. Audit Committee Oversight

The qualitative overlay enhancements described in Section IV.B above were reviewed and approved by the Audit Committee of BRB's Board of Directors. The Audit Committee is chaired by independent director Gwendolyn Prescott, who has served on the Board since 2018 and who the Board has designated as an "audit committee financial expert" within the meaning of Item 407(d)(5) of Regulation S-K based on her extensive experience in financial services and public-company governance.

The Audit Committee received presentations from Ms. Navarrete, Mr. Hu, and Ms. Kowalski regarding the proposed CECL methodology enhancements at its regular meetings on August 14, 2023 and November 6, 2023, and at a special session convened on January 22, 2024 to review the FY 2023 year-end ACL estimate prior to the filing of the FY 2023 Form 10-K. In addition, Whitfield Keane LLP presented its audit findings regarding the ACL, including its assessment of the reasonableness of the qualitative overlays, to the Audit Committee on February 19, 2024. The Audit Committee's active oversight of the CECL methodology and qualitative overlays reflects the robust internal controls over financial reporting that BRB has maintained throughout the relevant period.

V. Significance for the Staff's Analysis

A. Reasonableness of Original ACL

The data presented in Sections III and IV above, taken together, confirm that BRB's FY 2022 ACL of $143.5 million was within the range of reasonable estimates under ASC 326. The very credit-quality outcomes that the Staff's preliminary analysis predicted would materialize — elevated delinquencies among re-aged loans, rising charge-off rates as post-Q2 2021 cohorts matured, and the need for a substantially higher ACL — have not occurred. Instead, the actual performance of the BridgeFin portfolio through Q4 2023 demonstrates that:

• The 90-plus-day delinquency rate declined from 1.72% to 1.48%, rather than rising toward the 2.38% figure the Staff's reclassification methodology would have implied;

• The net charge-off rate declined from 2.14% (FY 2022) to 1.88% (FY 2023), rather than rising toward the 3.05% figure the Staff's preliminary analysis suggested;

• The re-aged and modified loans performed better than BRB's own CECL model projected, with a cumulative net charge-off rate of 1.87% versus a projected rate of 2.20%; and

• BRB's ACL increased modestly — by $12.7 million, or approximately 8.9% — reflecting prospective methodology refinements, not a correction of prior-period errors.

The Staff's preliminary view of a $37.3 million understatement (an ACL of $180.8 million, or 4.41% of outstanding BridgeFin loans) was predicated on assumptions about the future performance of re-aged loans and the loss-emergence trajectories of post-Q2 2021 vintage cohorts that the actual Q4 2023 data simply does not support. The re-aged loans have performed within or better than BRB's original modeled loss parameters. The vintage cohorts have seasoned without exhibiting the elevated loss rates the Staff hypothesized. And the portfolio as a whole has exhibited improving credit quality throughout FY 2023. Under these circumstances, the Staff's preliminary adjusted ACL figure of $180.8 million is not a more accurate reflection of expected credit losses than BRB's reported figure of $143.5 million; rather, BRB's reported figure has proven to be the more accurate estimate.

B. Materiality Considerations

Even if the Staff were to maintain its preliminary view that BRB's FY 2022 ACL was understated by $37.3 million, the materiality analysis does not support an enforcement action. As discussed in Section VII of the Wells Submission, BRB's quantitative materiality threshold — calculated as 5% of FY 2022 pre-tax income of $612 million — is $30.6 million. The Staff's preliminary understatement figure of $37.3 million exceeds this threshold by only $6.7 million.

This $6.7 million excess must be evaluated in context. BRB is a $38.2 billion institution (total consolidated assets as of December 31, 2022) with $4.03 billion in shareholders' equity. The $6.7 million excess over the quantitative materiality threshold represents approximately 0.02% of total assets and 0.17% of shareholders' equity. Under both quantitative and qualitative materiality analysis — as articulated in SEC Staff Accounting Bulletin No. 99, Materiality, and the related Commission and judicial guidance — these figures do not support a conclusion that BRB's reported ACL was materially misleading to a reasonable investor.

Moreover, as discussed in Section V.A above, the Q4 2023 data further undermines the factual predicate for the Staff's $37.3 million understatement estimate. To the extent the actual credit-quality experience of the portfolio is probative of whether BRB's original estimate was reasonable — and we submit that it is highly probative — the evidentiary basis for any materiality finding has been substantially weakened by the data now available.

C. No Restatement Required

BRB has not restated and does not intend to restate any prior-period financial statements in connection with the matters under investigation. BRB's management has evaluated the need for restatement in accordance with ASC 250, Accounting Changes and Error Corrections, and has concluded that no error exists requiring restatement or revision of previously issued financial statements.

Whitfield Keane LLP has concurred with BRB's determination that no restatement is warranted. Whitfield Keane's concurrence is reflected in its unqualified audit opinions on BRB's financial statements for both FY 2022 and FY 2023, and in its representations to the BRB Audit Committee.

Additionally, the Office of the Comptroller of the Currency, which exercises primary supervisory authority over BRB under OCC Charter No. 24891, has maintained BRB's satisfactory (2 composite) CAMELS rating throughout the period under investigation. The OCC has not identified a material deficiency in BRB's ACL methodology, has not directed BRB to increase its ACL, and has not taken any informal or formal supervisory action relating to BRB's credit-loss accounting. The status of BRB's OCC supervisory relationship is summarized in Wells Submission Exhibit D, which includes correspondence from the OCC's Examiner-in-Charge confirming BRB's satisfactory supervisory standing.

VI. Conclusion

The supplemental data presented in this letter reinforces each of the principal arguments set forth in BRB's April 5, 2024 Wells Submission. The improving BridgeFin credit metrics — including a 90-plus-day delinquency rate of 1.48%, a full-year FY 2023 net charge-off rate of 1.88%, and an 85.0% current rate among re-aged and modified loans — demonstrate that BRB's CECL model produced reasonable and substantially accurate credit-loss estimates as of the measurement dates at issue. The strong performance of the re-aged and modified loan cohort confirms that BRB's treatment of these loans as "current" following modification was both compliant with applicable regulatory guidance and predictively sound. And the enhanced — but not corrective — ACL methodology adopted during FY 2023 reflects the kind of ongoing model refinement that ASC 326 contemplates, not an acknowledgment of prior-period error.

In sum, BRB's FY 2022 Form 10-K, Q1 2023 Form 10-Q, and Q2 2023 Form 10-Q disclosures were made in good faith, were based on reasonable professional judgments, and were not materially misleading to investors. No enforcement action under Sections 13(a) or 13(b)(2)(A) of the Securities Exchange Act of 1934, 15 U.S.C. §§ 78m(a) and 78m(b)(2)(A), or Rules 13a-1 and 12b-20 promulgated thereunder, 17 C.F.R. §§ 240.13a-1 and 240.12b-20, is warranted on these facts.

BRB respectfully requests that the Staff close this investigation without recommending an enforcement action to the Commission. Should the Staff determine, however, that further analysis or additional information is needed, BRB remains available and willing to provide any supplemental materials, data, or testimony that the Staff may require. We welcome the opportunity to discuss this supplemental submission with the Staff at the Staff's convenience.

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

Victoria Chambers Partner

425 Lexington Avenue, 30th Floor New York, New York 10017 Telephone: (212) 558-4127

Email: vchambers@calderwoodharkness.com

Counsel to Belmont Ridge Bank National Association

Matter No. SC-MAT-2023-4172

cc (via ECF):

Andrea Felton, Senior Staff Attorney, Division of Enforcement, U.S. Securities and Exchange Commission

Christopher Yuen, Staff Attorney, Division of Enforcement, U.S. Securities and Exchange Commission

Diane Milosevic, Staff Accountant, Division of Enforcement, U.S. Securities and Exchange Commission

cc (via separate cover, subject to attorney-client privilege and work product protections):

Derek Sung, General Counsel, Belmont Ridge Bank National Association

cc (internal):

Jasmine Thornton, Calderwood & Harkness LLP

Liam Donahue, Calderwood & Harkness LLP

Quarter	Net Charge-Off Rate (Annualized)
Q1 2023	2.08%
Q2 2023	1.94%
Q3 2023	1.81%
Q4 2023	1.67%
FY 2023 (Full Year)	1.88%

CALDERWOOD & HARKNESS LLP Attorneys at Law
425 Lexington Avenue, 30th Floor New York, New York 10017
Telephone: (212) 558-4000 Facsimile: (212) 558-3588 www.calderwoodharkness.com
April 22, 2024
VIA ECF AND HAND DELIVERY
Gregory Bonham Assistant Director, Financial Fraud Unit Division of Enforcement U.S. Securities and Exchange Commission 100 F Street NE Washington, D.C. 20549
Renata Moss Branch Chief Division of Enforcement U.S. Securities and Exchange Commission 100 F Street NE Washington, D.C. 20549
Re: In the Matter of Belmont Ridge Bank National Association SEC File No. HO-14287; Formal Order No. EN-2023-0947 Supplemental Submission Following Wells Submission of April 5, 2024
Dear Mr. Bonham and Ms. Moss:
I. Introduction and Purpose of Letter
This firm represents Belmont Ridge Bank National Association ("BRB" or the "Bank") (Nasdaq: BRDG) in the above-referenced investigation being conducted by the Division of Enforcement (the "Staff") of the U.S. Securities and Exchange Commission (the "Commission"). We write to supplement the Wells Submission filed on behalf of BRB on April 5, 2024 (the "Wells Submission"), which comprised forty-two (42) pages of narrative argument plus Exhibits A through G, with updated credit-quality data and related information that we believe is material to the Staff's ongoing analysis.
Specifically, the purpose of this supplemental letter is threefold. First, we provide the Staff with updated credit-quality data from BRB's BridgeFin digital lending division for the quarter ended December 31, 2023 ("Q4 2023"), including delinquency rates, net charge-off rates, and performance data on the subset of re-aged and modified loans that have been a focal point of the Staff's inquiry. Second, we bring to the Staff's attention BRB's updated allowance for credit losses ("ACL") as reported in BRB's Annual Report on Form 10-K for the fiscal year ended December 31, 2023 ("FY 2023 Form 10-K"), filed with the Commission on February 27, 2024. Third, we explain the significance of these data points in the context of the arguments set forth in the Wells Submission.
The Q4 2023 data was not yet available in final audited form at the time we filed the Wells Submission, and the underlying audit work papers were finalized by BRB's independent registered public accounting firm only on February 23, 2024. We are now providing this information to give the Staff the most current and complete picture of BRB's credit-quality trends and ACL methodology, and to ensure that the Staff's analysis rests on the fullest possible factual record.
BRB continues to cooperate fully with the Staff's investigation and remains committed to providing any further information or documentation the Staff may require. Nothing in this supplemental submission is intended to waive any privileges, defenses, or arguments previously asserted, all of which are expressly preserved.
II. Background and Context
By way of brief background, and as more fully detailed in Sections I through III of the Wells Submission, the Staff's investigation was opened on September 18, 2023, when BRB received a voluntary request letter from the Division of Enforcement seeking documents and information concerning the adequacy of BRB's ACL disclosures for its BridgeFin digital lending portfolio. The filings at issue are BRB's Annual Report on Form 10-K for the fiscal year ended December 31, 2022 ("FY 2022 Form 10-K"), filed with the Commission on February 28, 2023; BRB's Quarterly Report on Form 10-Q for the quarter ended March 31, 2023 ("Q1 2023 Form 10-Q"), filed with the Commission on May 10, 2023; and BRB's Quarterly Report on Form 10-Q for the quarter ended June 30, 2023 ("Q2 2023 Form 10-Q"), filed with the Commission on August 9, 2023.
As articulated by the Staff during the Wells call conducted on March 8, 2024, the core issue under investigation is whether BRB's reported ACL of $143.5 million — representing 3.50% of the $4.1 billion in outstanding BridgeFin loans as of December 31, 2022 — materially understated expected credit losses in BRB's FY 2022 Form 10-K. The Staff's concern centers on BRB's treatment of 12,847 re-aged and modified BridgeFin loans with an aggregate outstanding principal balance of approximately $236.4 million. According to the Staff's preliminary analysis, these loans were treated as "current" following modification when, in the Staff's view, they should have been classified in their original vintage delinquency buckets for purposes of the CECL loss-rate estimation. The Staff's preliminary view, as communicated during the March 8 Wells call, is that BRB's ACL should have been approximately $180.8 million, or 4.41% of outstanding BridgeFin loans, representing a potential understatement of $37.3 million.
As set forth at length in the Wells Submission, BRB respectfully disagrees with the Staff's preliminary conclusions for several independently sufficient reasons:
(a) BRB's CECL methodology, developed and maintained in accordance with Accounting Standards Codification Topic 326, Financial Instruments — Credit Losses ("ASC 326"), was reasonable and fell within the range of acceptable estimates, as ASC 326 expressly contemplates that different institutions applying the standard to similar portfolios may reach different but equally valid estimates;
(b) BRB's treatment of re-aged and modified loans as "current" following modification was consistent with guidance published in the Office of the Comptroller of the Currency's Comptroller's Handbook: Allowance for Credit Losses (updated April 2023) and was disclosed in the Management's Discussion and Analysis ("MD&A") sections of BRB's relevant periodic reports;
(c) any difference between BRB's reported ACL and the Staff's preliminary adjusted figure reflects the exercise of good-faith professional judgment — inherent in the estimation process that ASC 326 requires — rather than a material misstatement of BRB's financial condition;
(d) there is no evidence of scienter on the part of BRB, its officers, or any other person associated with the Bank's financial reporting process, and the Staff has not identified any such evidence; and
(e) a peer-bank comparison analysis, presented in Wells Submission Exhibit E, demonstrates that BRB's ACL coverage ratio of 3.50% fell within the interquartile range (25th to 75th percentile) of ACL coverage ratios reported by a cohort of fifteen comparable digital-lending institutions for the same period.
We incorporate by reference the full arguments, supporting data, and exhibits presented in the Wells Submission and do not repeat them in detail here. Rather, this supplemental letter focuses on the Q4 2023 and full-year FY 2023 data that has become available since the Wells Submission was filed, and which we submit strongly corroborates BRB's position on every element of the Staff's inquiry.
III. Updated BridgeFin Credit Metrics — Q4 2023
The data presented in this section is drawn from BRB's FY 2023 Form 10-K, BRB's internal credit-risk reporting systems, and the work papers of BRB's independent auditor, Whitfield Keane LLP. We have reviewed this data with BRB's Chief Risk Officer, Annette Kowalski, and BRB's Chief Accounting Officer, Raymond Hu, and are authorized to represent that the figures set forth below are accurate and consistent with BRB's audited financial statements.
A. 90+ Day Delinquency Rate
As of December 31, 2023, the BridgeFin portfolio's 90-plus-day delinquency rate — defined as the aggregate outstanding principal balance of loans 90 or more days past due as a percentage of total outstanding BridgeFin loans — declined to 1.48%. This figure is reported in Note 7 (Loans and Allowance for Credit Losses) to BRB's consolidated financial statements included in the FY 2023 Form 10-K at pages F-32 through F-41.
This 1.48% delinquency rate compares favorably to each of the relevant benchmarks that have been discussed in this investigation:
• BRB's FY 2022 Reported Figure: BRB reported a 90-plus-day delinquency rate of 1.72% for the BridgeFin portfolio as of December 31, 2022, as set forth in the FY 2022 Form 10-K. The Q4 2023 figure of 1.48% thus reflects a decline of 24 basis points, or approximately 14%, on a year-over-year basis.
• Staff's Preliminary Adjusted Figure: During the March 8, 2024 Wells call and in the accompanying staff memorandum, the Staff indicated that its preliminary analysis — which reclassified re-aged and modified loans into their original vintage delinquency buckets — yielded an adjusted 90-plus-day delinquency rate of approximately 2.38% as of December 31, 2022. The actual Q4 2023 delinquency rate of 1.48% is 90 basis points below the Staff's adjusted figure, representing a difference of nearly 38%.
The significance of this data cannot be overstated. The 1.48% delinquency rate as of December 31, 2023 reflects the actual observed performance of the BridgeFin portfolio — including the re-aged and modified loans that are the centerpiece of the Staff's inquiry — over a full twelve-month period following the reporting dates at issue. In other words, the loans that the Staff's preliminary analysis suggested would perform materially worse than BRB's CECL model projected have, in fact, performed meaningfully better than even BRB's own reported figures, let alone the Staff's adjusted estimates.
Moreover, this improvement in portfolio delinquency occurred notwithstanding the continued maturation of the post-Q2 2021 vintage cohorts that were a particular focus of the Staff's inquiry. As noted in the Wells Submission at pages 22–25 and Wells Submission Exhibit B, the Staff expressed concern that the post-Q2 2021 vintage cohorts — originated during a period of rapid BridgeFin growth — would exhibit elevated loss rates as they seasoned through their loss emergence periods. The Q4 2023 data demonstrates that these cohorts have, in fact, performed within the parameters originally modeled by BRB's credit-risk team, and that the loss emergence curves have not deviated materially from BRB's projections.
B. Net Charge-Off Rate
The BridgeFin portfolio's net charge-off rate also exhibited a consistently improving trend over the course of FY 2023, providing further corroboration of BRB's FY 2022 credit-quality assumptions. The quarterly net charge-off rates (annualized) for BridgeFin during FY 2023 were as follows:
As reported in BRB's FY 2022 Form 10-K, BridgeFin's full-year net charge-off rate for FY 2022 was 2.14%. The FY 2023 full-year net charge-off rate of 1.88% represents a 26-basis-point improvement, and the Q4 2023 quarterly figure of 1.67% reflects a particularly favorable trajectory entering 2024.
These figures stand in sharp contrast to the Staff's preliminary view, expressed during the Wells call, that BRB's FY 2022 vintage-cohort loss-rate assumptions implied an effective net charge-off rate closer to 3.05% on a through-the-cycle basis for the BridgeFin portfolio. The actual charge-off experience of the portfolio during FY 2023, when the loans at issue were in their most critical loss-emergence windows, demonstrates that BRB's original loss-rate assumptions were not only reasonable but proved to be somewhat conservative relative to actual outcomes. The declining charge-off trend throughout 2023 further validates BRB's modeling approach and the underlying assumptions embedded in its CECL framework as of the FY 2022 measurement date.
C. Re-Aged / Modified Loan Performance
Perhaps the most directly probative data concerns the performance of the 12,847 re-aged and modified loans ($236.4 million in aggregate outstanding principal balance as of December 31, 2022) that constitute the focal point of the Staff's inquiry. As the Staff is aware, these loans were modified through BRB's BridgeFin Borrower Assistance Program ("BAP") between Q3 2021 and Q4 2022, and were treated as "current" for delinquency-reporting and CECL-modeling purposes following modification — a treatment the Staff has questioned.
BRB has tracked the performance of this specific loan cohort on a monthly basis since the commencement of the Staff's investigation. As of December 31, 2023, the performance data for these 12,847 loans is as follows:
• Of the 12,847 loans, 10,917 (85.0%) remained current (0–29 days past due) as of December 31, 2023.
• An additional 978 loans (7.6%) were 30–59 days past due.
• 512 loans (4.0%) were 60–89 days past due.
• 289 loans (2.2%) were 90 or more days past due.
• 151 loans (1.2%) had been charged off during FY 2023.
• The cumulative net charge-off rate for this cohort through December 31, 2023 was 1.87%, compared with BRB's CECL model projection of a cumulative net charge-off rate of 2.20% for these loans at the time of the FY 2022 measurement date.
These results are significant for several reasons. First, the 85.0% current rate demonstrates that the overwhelming majority of borrowers who received modifications through the BAP have resumed — and sustained — regular payment performance, vindicating BRB's judgment that these borrowers represented curable, temporary delinquencies rather than the permanent credit impairments the Staff's preliminary analysis assumed. Second, the cumulative net charge-off rate of 1.87% for this cohort is not only within the range projected by BRB's CECL model, but is actually 33 basis points below BRB's own modeled projection of 2.20%, suggesting that BRB's original estimate was, if anything, conservative with respect to these loans. Third, and most importantly, these results confirm that BRB's treatment of these loans as "current" after modification was not only consistent with the regulatory guidance issued by the OCC — as discussed at length in Section IV of the Wells Submission — but was also substantively accurate as a predictive matter. The modifications achieved their intended purpose, borrowers returned to performing status, and the portfolio's loss experience validated BRB's credit-risk judgments.
IV. Updated ACL — FY 2023 Form 10-K
A. Increased ACL Figure
In its FY 2023 Form 10-K, filed with the Commission on February 27, 2024, BRB reported an ACL of $156.2 million for the BridgeFin portfolio. Total outstanding BridgeFin loans as of December 31, 2023 were approximately $4.27 billion, yielding an ACL coverage ratio of approximately 3.66%.
This represents an increase of $12.7 million from the $143.5 million ACL (3.50% coverage ratio) reported as of December 31, 2022. However, it is critical to understand the nature of this increase. The higher ACL does not reflect a correction or restatement of BRB's prior-period financial statements. BRB has not restated, and does not intend to restate, any previously filed periodic report or financial statement. Rather, the increase reflects enhanced qualitative overlays that BRB's management incorporated into the CECL model during FY 2023, as described in greater detail in Section IV.B below.
BRB's independent registered public accounting firm, Whitfield Keane LLP (Public Company Accounting Oversight Board Registration No. 2847, engagement partner Lorraine Dupont, CPA), issued an unqualified (clean) opinion on BRB's consolidated financial statements for FY 2023, including the ACL and the related provision for credit losses. Whitfield Keane's audit report, dated February 23, 2024, and included in the FY 2023 Form 10-K at pages F-2 through F-4, contains no qualifications, explanatory paragraphs regarding critical audit matters related to the ACL, or other indications of disagreement with BRB's management regarding the adequacy of the ACL for any period.
B. Nature of Enhanced Qualitative Overlays
The $12.7 million increase in the BridgeFin ACL during FY 2023 is attributable to enhanced qualitative adjustments that BRB's management implemented beginning in Q3 2023. These enhancements were developed and implemented under the direction of BRB's Chief Financial Officer, Patricia Navarrete; Chief Accounting Officer, Raymond Hu; and Chief Risk Officer, Annette Kowalski, working in coordination with BRB's Credit Risk Modeling Group and the BridgeFin business unit's risk management team.
The enhanced qualitative overlays include the following three principal components:
(i) Refined Vintage-Cohort Segmentation. BRB refined the granularity of its vintage-cohort segmentation for BridgeFin loans originated after Q2 2021 — the period during which the BridgeFin platform experienced its most rapid origination growth. The prior segmentation methodology grouped originations into semi-annual cohorts; the enhanced methodology segments originations into quarterly cohorts, permitting more precise loss-rate estimation for periods of varying credit conditions and origination volumes. This refinement responds, in part, to developments in industry practice and to the Staff's feedback during the investigative process regarding the granularity of BRB's vintage-level analysis.
(ii) Expanded Macroeconomic Scenario Weighting. BRB expanded the number and probability weighting of macroeconomic scenarios used as inputs to its CECL model. The prior methodology employed three scenarios (baseline, optimistic, and adverse) with probability weights of 50%, 20%, and 30%, respectively. The enhanced methodology employs five scenarios — including a severe adverse scenario and a moderately optimistic scenario — with revised probability weights that BRB's economics team determined more accurately captured the range of potential macroeconomic outcomes as of the measurement date. This refinement increases the ACL by giving greater weight to tail-risk economic scenarios while maintaining the model's overall calibration to expected loss outcomes.
(iii) Supplementary Qualitative Factors for Digital-Lending Channel Characteristics. BRB added qualitative adjustment factors to the CECL model that specifically address evolving credit characteristics unique to the digital-lending channel, including the BridgeFin platform's applicant demographic profile, digital-channel customer engagement metrics, and historical modification re-default rates. These factors are applied as supplementary adjustments to the quantitative model output and are documented in accordance with BRB's model risk management framework.
We wish to emphasize that each of these enhancements represents a prospective methodology improvement consistent with the ongoing refinement that ASC 326 contemplates and, indeed, encourages. ASC 326 recognizes that the CECL framework requires entities to continuously evaluate and update their methodologies, assumptions, and inputs as new information becomes available and as modeling techniques evolve. The enhancements adopted by BRB during FY 2023 reflect precisely this type of iterative improvement. They are not, and should not be construed as, admissions that BRB's prior-period ACL estimates were deficient, unreasonable, or in any way inconsistent with ASC 326.
In this connection, we note that BRB voluntarily enhanced its credit-quality disclosures in its Quarterly Report on Form 10-Q for the quarter ended September 30, 2023 ("Q3 2023 Form 10-Q"), filed with the Commission on November 9, 2023. As detailed in Wells Submission Exhibit C, the enhanced disclosures in the Q3 2023 Form 10-Q included (a) vintage-level delinquency tables disaggregated by quarterly origination cohort; (b) expanded MD&A discussion of the BridgeFin portfolio's credit-quality trends, modification activity, and re-default rates; and (c) additional quantitative disclosures regarding the macroeconomic scenarios and probability weights used in BRB's CECL model. These voluntary disclosure enhancements further demonstrate BRB's good faith and its commitment to transparent communication with investors and the Commission.
C. Audit Committee Oversight
The qualitative overlay enhancements described in Section IV.B above were reviewed and approved by the Audit Committee of BRB's Board of Directors. The Audit Committee is chaired by independent director Gwendolyn Prescott, who has served on the Board since 2018 and who the Board has designated as an "audit committee financial expert" within the meaning of Item 407(d)(5) of Regulation S-K based on her extensive experience in financial services and public-company governance.
The Audit Committee received presentations from Ms. Navarrete, Mr. Hu, and Ms. Kowalski regarding the proposed CECL methodology enhancements at its regular meetings on August 14, 2023 and November 6, 2023, and at a special session convened on January 22, 2024 to review the FY 2023 year-end ACL estimate prior to the filing of the FY 2023 Form 10-K. In addition, Whitfield Keane LLP presented its audit findings regarding the ACL, including its assessment of the reasonableness of the qualitative overlays, to the Audit Committee on February 19, 2024. The Audit Committee's active oversight of the CECL methodology and qualitative overlays reflects the robust internal controls over financial reporting that BRB has maintained throughout the relevant period.
V. Significance for the Staff's Analysis
A. Reasonableness of Original ACL
The data presented in Sections III and IV above, taken together, confirm that BRB's FY 2022 ACL of $143.5 million was within the range of reasonable estimates under ASC 326. The very credit-quality outcomes that the Staff's preliminary analysis predicted would materialize — elevated delinquencies among re-aged loans, rising charge-off rates as post-Q2 2021 cohorts matured, and the need for a substantially higher ACL — have not occurred. Instead, the actual performance of the BridgeFin portfolio through Q4 2023 demonstrates that:
• The 90-plus-day delinquency rate declined from 1.72% to 1.48%, rather than rising toward the 2.38% figure the Staff's reclassification methodology would have implied;
• The net charge-off rate declined from 2.14% (FY 2022) to 1.88% (FY 2023), rather than rising toward the 3.05% figure the Staff's preliminary analysis suggested;
• The re-aged and modified loans performed better than BRB's own CECL model projected, with a cumulative net charge-off rate of 1.87% versus a projected rate of 2.20%; and
• BRB's ACL increased modestly — by $12.7 million, or approximately 8.9% — reflecting prospective methodology refinements, not a correction of prior-period errors.
The Staff's preliminary view of a $37.3 million understatement (an ACL of $180.8 million, or 4.41% of outstanding BridgeFin loans) was predicated on assumptions about the future performance of re-aged loans and the loss-emergence trajectories of post-Q2 2021 vintage cohorts that the actual Q4 2023 data simply does not support. The re-aged loans have performed within or better than BRB's original modeled loss parameters. The vintage cohorts have seasoned without exhibiting the elevated loss rates the Staff hypothesized. And the portfolio as a whole has exhibited improving credit quality throughout FY 2023. Under these circumstances, the Staff's preliminary adjusted ACL figure of $180.8 million is not a more accurate reflection of expected credit losses than BRB's reported figure of $143.5 million; rather, BRB's reported figure has proven to be the more accurate estimate.
B. Materiality Considerations
Even if the Staff were to maintain its preliminary view that BRB's FY 2022 ACL was understated by $37.3 million, the materiality analysis does not support an enforcement action. As discussed in Section VII of the Wells Submission, BRB's quantitative materiality threshold — calculated as 5% of FY 2022 pre-tax income of $612 million — is $30.6 million. The Staff's preliminary understatement figure of $37.3 million exceeds this threshold by only $6.7 million.
This $6.7 million excess must be evaluated in context. BRB is a $38.2 billion institution (total consolidated assets as of December 31, 2022) with $4.03 billion in shareholders' equity. The $6.7 million excess over the quantitative materiality threshold represents approximately 0.02% of total assets and 0.17% of shareholders' equity. Under both quantitative and qualitative materiality analysis — as articulated in SEC Staff Accounting Bulletin No. 99, Materiality, and the related Commission and judicial guidance — these figures do not support a conclusion that BRB's reported ACL was materially misleading to a reasonable investor.
Moreover, as discussed in Section V.A above, the Q4 2023 data further undermines the factual predicate for the Staff's $37.3 million understatement estimate. To the extent the actual credit-quality experience of the portfolio is probative of whether BRB's original estimate was reasonable — and we submit that it is highly probative — the evidentiary basis for any materiality finding has been substantially weakened by the data now available.
C. No Restatement Required
BRB has not restated and does not intend to restate any prior-period financial statements in connection with the matters under investigation. BRB's management has evaluated the need for restatement in accordance with ASC 250, Accounting Changes and Error Corrections, and has concluded that no error exists requiring restatement or revision of previously issued financial statements.
Whitfield Keane LLP has concurred with BRB's determination that no restatement is warranted. Whitfield Keane's concurrence is reflected in its unqualified audit opinions on BRB's financial statements for both FY 2022 and FY 2023, and in its representations to the BRB Audit Committee.
Additionally, the Office of the Comptroller of the Currency, which exercises primary supervisory authority over BRB under OCC Charter No. 24891, has maintained BRB's satisfactory (2 composite) CAMELS rating throughout the period under investigation. The OCC has not identified a material deficiency in BRB's ACL methodology, has not directed BRB to increase its ACL, and has not taken any informal or formal supervisory action relating to BRB's credit-loss accounting. The status of BRB's OCC supervisory relationship is summarized in Wells Submission Exhibit D, which includes correspondence from the OCC's Examiner-in-Charge confirming BRB's satisfactory supervisory standing.
VI. Conclusion
The supplemental data presented in this letter reinforces each of the principal arguments set forth in BRB's April 5, 2024 Wells Submission. The improving BridgeFin credit metrics — including a 90-plus-day delinquency rate of 1.48%, a full-year FY 2023 net charge-off rate of 1.88%, and an 85.0% current rate among re-aged and modified loans — demonstrate that BRB's CECL model produced reasonable and substantially accurate credit-loss estimates as of the measurement dates at issue. The strong performance of the re-aged and modified loan cohort confirms that BRB's treatment of these loans as "current" following modification was both compliant with applicable regulatory guidance and predictively sound. And the enhanced — but not corrective — ACL methodology adopted during FY 2023 reflects the kind of ongoing model refinement that ASC 326 contemplates, not an acknowledgment of prior-period error.
In sum, BRB's FY 2022 Form 10-K, Q1 2023 Form 10-Q, and Q2 2023 Form 10-Q disclosures were made in good faith, were based on reasonable professional judgments, and were not materially misleading to investors. No enforcement action under Sections 13(a) or 13(b)(2)(A) of the Securities Exchange Act of 1934, 15 U.S.C. §§ 78m(a) and 78m(b)(2)(A), or Rules 13a-1 and 12b-20 promulgated thereunder, 17 C.F.R. §§ 240.13a-1 and 240.12b-20, is warranted on these facts.
BRB respectfully requests that the Staff close this investigation without recommending an enforcement action to the Commission. Should the Staff determine, however, that further analysis or additional information is needed, BRB remains available and willing to provide any supplemental materials, data, or testimony that the Staff may require. We welcome the opportunity to discuss this supplemental submission with the Staff at the Staff's convenience.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Victoria Chambers Partner
425 Lexington Avenue, 30th Floor New York, New York 10017 Telephone: (212) 558-4127
Email: vchambers@calderwoodharkness.com
Counsel to Belmont Ridge Bank National Association
Matter No. SC-MAT-2023-4172
cc (via ECF):
Andrea Felton, Senior Staff Attorney, Division of Enforcement, U.S. Securities and Exchange Commission
Christopher Yuen, Staff Attorney, Division of Enforcement, U.S. Securities and Exchange Commission
Diane Milosevic, Staff Accountant, Division of Enforcement, U.S. Securities and Exchange Commission
cc (via separate cover, subject to attorney-client privilege and work product protections):
Derek Sung, General Counsel, Belmont Ridge Bank National Association
cc (internal):
Jasmine Thornton, Calderwood & Harkness LLP
Liam Donahue, Calderwood & Harkness LLP
Quarter | Net Charge-Off Rate (Annualized)
Q1 2023 | 2.08%
Q2 2023 | 1.94%
Q3 2023 | 1.81%
Q4 2023 | 1.67%
FY 2023 (Full Year) | 1.88%

CALDERWOOD & HARKNESS LLP Attorneys at Law

VIA ECF AND HAND DELIVERY

CALDERWOOD & HARKNESS LLP

Record

Parties

Dates

Amounts