Extract to table

Deadline Computation The Consent Order specifies that the CMP shall be paid within sixty (60) calendar days of the effective date of the Consent Order

A request for installment payments or deferral could be viewed unfavorably by the OCC, potentially signaling financial weakness or a lack of commitment to the remediation process, and could adversely affect the supervisory relationship at a time when BRB must demonstrate full cooperation and compliance

Payment Method The CMP must be paid by wire transfer to the United States Treasury

In either case, the wire must be transmitted via the Fedwire Funds Service to ensure same-day settlement in immediately available funds

If the liability was not accrued as of December 31, 2024, the issuance of the Consent Order on January 15, 2025 constitutes a subsequent event under ASC 855 (Subsequent Events) that must be evaluated as either a recognized subsequent event (Type I) or a non-recognized subsequent event (Type II)

The Consent Order and the CMP have material disclosure implications that must be carefully managed