NTB Charter Tracker — Source Provenance Audit

subject to the following conditions: 1. The Bank must limit its operations to those of a trust company and activities related thereto, as specifically stated in the business plan. The Bank must not meet the definition of "bank" under section 2(c)(1)-(2) of the Bank Holding Company Act. 2. If and to the extent necessary, the Bank must conform, cease, or divest its proposed collateral trustee structure and any other activities to comply with the GENIUS Act (12 USC 5901 et seq.), any implementing regulations, and any other applicable laws and regulations that take effect in the future, such compliance to be determined in the sole discretion of the OCC. 3. The Bank: (i) must give the Novel Bank Supervisory Office at least sixty (60) days prior written notice of the Bank's intent to significantly deviate or change from its business plan or operations (if such deviation is the subject of an application filed with the OCC, no separate notice to the supervisory office is required); and (ii) must obtain the OCC's written determination of no objection before the Bank engages in any significant deviation or change from its business plan or operations. For the avoidance of doubt, a significant deviation includes changes to the Bank's risk and operating limits, as detailed in its business plan. 6 Mr. Kevin Murphy 2025-Charter-342299 2025-Waiver-342964 The OCC may impose additional conditions it deems appropriate in a written determination of no objection to the Bank's notice. This condition will remain in effect throughout the Bank's in organization period and during the Bank's first three years of operation. 4. The Bank must maintain a minimum $6.05 million in tier 1 capital of which the greater of at least 50 percent of its tier 1 capital or $3.025 million must be held in Eligible Liquid Assets.17 The Bank must assess the appropriateness of its level of capital and liquidity on a quarterly basis and hold such higher amounts of capital and liquidity as it determines necessary to support the bank's risk profile, business strategies, and future growth prospects, and to provide a cushion against unexpected losses. This condition will remain in effect during the Bank's first three years of operation. 5. The Bank must maintain 180 days of operating expenses18 in Eligible Liquid Assets. This amount must not be double counted with the Eligible Liquid Assets held to comply with the foregoing condition. This condition will remain in effect during the Bank's first three years of operation. 6. Prior to the appointment of any individual to the position of "senior executive officer," as defined in 12 CFR 5.51(c)(4), or the appointment of any individual to the board of directors, the proposed Bank must submit to the OCC the information described in the "Changes in Directors and Senior Executive Officers" booklet of the Comptroller's Licensing Manual, and receive a letter of no objection from the OCC. For purposes of this condition, "senior executive officer" includes the Chief Compliance Officer, the Bank Secrecy Act Officer, the Chief Technology Officer, the Chief Information Security Officer, the Chief Trust Officer, and any fiduciary officers or employees designated for that purpose. This information is required 17 The term "Eligible Liquid Assets" means only Liquid Assets that exceed the aggregate amount of all deposits, borrowed funds, and other liabilities on the Bank's balance sheet that reflect an obligation to repay funds to any party. The term Eligible Liquid Assets shall not include any assets that are pledged in any manner, nor any assets that are not free and kept free from any lien, encumbrance, charge, right of set off, credit or preference in connection with any claim against the Bank. The term "Liquid Assets" means: (i) unencumbered cash; (ii) deposits at insured depository institutions with a maturity of 90 days or less; (iii) United States government obligations maturing within 90 days or less; and (iv) such other assets as to which the Bank has obtained a written nonobjection from the OCC. The term Eligible Liquid Assets shall not include any obligation of any affiliate. 18 The minimum 180 days of operating expenses must include all fixed and variable operating expenses that would apply in a distressed, wind-down scenario and need not include expenses that would apply only in a normal operating scenario, such as expenses related to research and development. 7 Mr. Kevin Murphy 2025-Charter-342299 2025-Waiver-342964 by the authority of 12 USC 1818(b) and 12 CFR 5.20(g) and does not require the OCC to review or act on any such information within ninety (90) days. This condition will remain in effect throughout the Bank's in organization period and during the Bank's first three years of operation. The conditions of this approval are conditions "imposed in writing by a Federal banking agency in connection with any action on any application, notice, or other request" within the meaning of 12 USC 1818. As such, the conditions are enforceable under 12 USC 1818. As a de novo national bank, the Bank must also meet the following requirements prior to requesting its preopening examination and befor

subject to the following conditions: 1. The Bank must limit its operations to those of a trust company and activities related thereto, as specifically stated in the business plan. The Bank must not meet the definition of "bank" under section 2(c)(1)-(2) of the Bank Holding Company Act. 2. If and to the extent necessary, the Bank must conform, cease, or divest its proposed collateral trustee structure and any other activities to comply with the GENIUS Act (12 USC 5901 et seq.), any implementing regulations, and other 6 Mr. Brian Spahn 2025-Charter-342347 2025-Waiver-342476 applicable laws and regulations that take effect in the future, such compliance to be determined in the sole discretion of the OCC. 3. The Bank: (i) must give the Novel Bank Supervisory Office at least sixty (60) days' prior written notice of the Bank's intent to significantly deviate or change from its business plan or operations (if such deviation is the subject of an application filed with the OCC, no separate notice to the supervisory office is required); and (ii) must obtain the OCC's written determination of no objection before the Bank engages in any significant deviation or change from its business plan or operations. For the avoidance of doubt, a significant deviation includes changes to the Bank's risk and operating limits, as detailed in its business plan. The OCC may impose additional conditions it deems appropriate in a written determination of no objection to the Bank's notice. This condition will remain in effect throughout the Bank's in-organization period and during the Bank's first three years of operation. 4. The Bank must maintain a minimum $11.7 million in tier 1 capital of which the greater of at least 50 percent of its tier 1 capital or $5.85 million must be held in Eligible Liquid Assets.17 The Bank must assess the appropriateness of its level of capital and liquidity on a quarterly basis and hold such higher amounts of capital and liquidity as it determines necessary to support the bank's risk profile, business strategies, and future growth prospects, and to provide a cushion against unexpected losses. This condition will remain in effect during the Bank's first three years of operation. 5. The Bank must maintain 180 days of operating expenses18 in Eligible Liquid Assets. This amount must not be double counted with the Eligible Liquid Assets held to comply with the foregoing condition. This condition will remain in effect 17 The term "Eligible Liquid Assets" means only Liquid Assets that exceed the aggregate amount of all deposits, borrowed funds, and other liabilities on the Bank's balance sheet that reflect an obligation to repay funds to any party. The term Eligible Liquid Assets shall not include any assets that are pledged in any manner, nor any assets that are not free and kept free from any lien, encumbrance, charge, right of set off, credit or preference in connection with any claim against the Bank. The term Eligible Liquid Assets shall not include any obligation of any affiliate. The term "Liquid Assets" means: (i) unencumbered cash; (ii) deposits at insured depository institutions with a maturity of 90 days or less; (iii) United States government obligations maturing within 90 days or less; and (iv) such other assets as to which the Bank has obtained a written nonobjection from the OCC. 18 The minimum 180 days operating expenses must include all fixed and variable operating expenses that would apply in a distressed, wind-down scenario and need not include expenses that would apply only in a normal operating scenario, such as expenses related to research and development. 7 Mr. Brian Spahn 2025-Charter-342347 2025-Waiver-342476 during the Bank's first three years of operation. 6. Prior to the appointment of any individual to the position of "senior executive officer," as defined in 12 CFR 5.51(c)(4)or the appointment of any individual to the board of directors, the proposed Bank must submit to the OCC the information described in the "Changes in Directors and Senior Executive Officers" booklet of the Comptroller's Licensing Manual, and receive a letter of no objection from the OCC. For purposes of this condition, "senior executive officer" includes the Chief Compliance Officer, the Bank Secrecy Act Officer, the Chief Technology Officer, the Chief Information Security Officer, the Chief Trust Officer, and any fiduciary officers or employees designated for that purpose. This information is required by the authority of 12 USC 1818(b) and 12 CFR 5.20(g) and does not require the OCC to review or act on any such information within ninety (90) days. This condition will remain in effect throughout the Bank's in-organization period and during the first three years of operation. The conditions of this approval are conditions "imposed in writing by a Federal banking agency in connection with any action on any application, notice, or other request" within the meaning of 12 USC 1818. As such, the conditions are enforceable under 12 USC 1818. As a de novo national bank, the proposed Bank must also meet the following requirements prior to requesting its preopening examination

subject to the following conditions and conversion requirements: 1. The Bank must limit its operations to those of a trust company and activities related thereto, as specifically stated in the business plan. The Bank must not meet the definition of "bank" under section 2(c)(1)-(2) of the Bank Holding Company Act. 2. If and to the extent necessary, the Bank must conform, cease, or divest its proposed collateral trustee structure and any other activities to comply with the GENIUS Act (12 USC 5901 et seq.), any implementing regulations, and any other applicable laws and regulations that take effect in the future, such compliance to be determined in the sole discretion of the OCC. 3. The Bank must: (i) give the Novel Bank Supervisory Office at least sixty (60) days prior written notice of the proposed Bank's intent to significantly deviate or change from its business plan or operations (if such deviation is the subject of an application filed with the OCC, no separate notice to the supervisory office is required); and (ii) obtain the 7 Mr. Mark Chorazak 2025-Conversion-342828 2025-Waiver-344112 2025-Dividend-344142 OCC's written determination of no objection before the proposed Bank engages in any significant deviation or change from its business plan or operations. For the avoidance of doubt, a significant deviation includes changes to the proposed Bank's risk and operating limits, as detailed in its business plan. The OCC may impose additional conditions it deems appropriate in a written determination of no objection to the proposed Bank's notice. This condition will remain in effect during the Bank's first three years of operations as a national bank. 4. The Bank must obtain a written determination of no objection from the OCC before the Bank offers, markets, issues, or otherwise makes available Global Dollar (USDG) within the "Multi-Jurisdictional Stablecoin Issuance Platform" (or any substantially similar product). The OCC may impose additional conditions it deems appropriate in a written determination of no objection to the Bank's notice. 5. The Bank must complete its dividend pursuant to its distribution plan as soon as practicable. The Bank must obtain the OCC's written determination of no objection before deviating from this approved plan.26 6. The Bank must maintain at least $15 million in tier 1 capital of which and must hold the greater of at least 50 percent of its tier 1 capital or $7.5 million in Eligible Liquid Assets.27 The Bank must assess the appropriateness of its level of capital and liquidity on a quarterly basis and hold such higher amounts of capital and liquidity as it determines necessary to support the bank's risk profile, business strategies, and future growth prospects, and to provide a cushion against unexpected losses. This condition will remain in effect during the Bank's first three years of operations as a national bank. 7. The Bank must maintain 180 days of operating expenses28 in Eligible Liquid Assets. This 26 To the extent that assets subject to the distribution plan are non-conforming assets, the Bank must dispose of them as soon as possible, and in any event no later than 2 months after conversion. 27 The term "Eligible Liquid Assets" means only Liquid Assets that exceed the aggregate amount of all deposits, borrowed funds, and other liabilities on the Bank's balance sheet that reflect an obligation to repay funds to any party. The term Eligible Liquid Assets shall not include any assets that are pledged in any manner, nor any assets that are not free and kept free from any lien, encumbrance, charge, right of set off, credit or preference in connection with any claim against the Bank. The term "Liquid Assets" means: (i) unencumbered cash; (ii) deposits at insured depository institutions with a maturity of 90 days or less; (iii) United States government obligations maturing within 90 days or less; and (iv) such other assets as to which the Bank has obtained a written nonobjection from the OCC. The term Eligible Liquid Assets shall not include any obligation of any affiliate. 28 The minimum 180 days operating expenses must include all fixed and variable operating expenses that would apply in a distressed, wind-down scenario and need not include expenses 8 Mr. Mark Chorazak 2025-Conversion-342828 2025-Waiver-344112 2025-Dividend-344142 amount must not be double counted with the Eligible Liquid Assets held to comply with the foregoing condition. This condition will remain in effect during the Bank's first threeyears of operations as a national bank. 8. Prior to January 1, 2026, the Bank must set aside $7.25 million to invest in its compliance programs during 2026. In addition, prior to January 1, 2027, the Bank must set aside $8.5 million to invest in its compliance programs during 2027. The Bank must use these funds to remediate the issues described in the Consent Order issued by the New York Department of Financial Services dated August 7, 2025. 9. Prior to the appointment of any individual to the position of "senior executive officer," as defined in 12 CFR 5.51(c)(4) or the appointment of any individual to the board of directors, the proposed Bank shall submit to the OCC the information described in the "Changes in Directors and Senior Executive Officers" booklet of the Comptroller's Licensing Manual, and receive a letter of no objection from the OCC. For purposes of this condition, "senior executive officer" includes the Chief Compliance Officer, the Bank Secrecy Act Officer, the Chief Technology Officer, the Chief Information Security Officer, the Chief Trust Officer, and any fiduciary officers or employees designated for that purpose. This information is required by the authority of 12 USC 1818(b) and 12 CFR 5.24(e)(2) and does not require the OCC to review or act on any such information within ninety (90) days. This condition will remain in effect during the Bank's first three years of operations as a national bank. The conditions of this approval are conditions "imposed in writing by a Federal banking agency in connection with any action on any application, notice, or other request" within the meaning of 12 USC 1818. As such, the conditions are enforceable under 12 USC 1818. In addition, the following conversion requirements must be met: 1. The Bank must purchase adequate fidelity bond coverage in accordance

subject to the following conditions and conversion requirements: 1. The Bank must limit its operations to those of a trust company and activities related 24 See 12 USC 92a (permitting the OCC to authorize a national bank "to act as trustee, executor, administrator, registrar of stocks and bonds, guardian of estates, assignee, receiver, or any other fiduciary capacity in which State banks, trust companies, or other corporations which come into competition with national banks are permitted to act under the laws of the State in which the national bank is located"). 25 See OCC Interpretive Letter No. 1176. 6 thereto, as specifically stated in the business plan. The Bank must not meet the definition of "bank" under section 2(c)(1)-(2) of the Bank Holding Company Act. 2. The Bank must cease, or conform to the requirements for a national bank to engage in, receiving customer fees denominated in digital assets that cause any digital assets to be held on the Bank's balance sheet for any period of time, within two years of the date of consummation of the conversion. For any digital assets received during the two-year conformance period, the Bank must divest any nonconforming digital assets as soon as practicable and no longer than one business day following receipt of the digital assets. 3. If and to the extent necessary, the Bank must conform, cease, or divest its proposed stablecoin issuance and redemption activities and any other activities to comply with the GENIUS Act (12 USC 5901 et seq.), any implementing regulations, and any other applicable laws and regulations that take effect in the future, such compliance to be determined in the sole discretion of the OCC. 4. The Bank must: (i) give the Novel Bank Supervisory Office at least sixty (60) days prior written notice of the proposed Bank's intent to significantly deviate or change from its business plan or operations (if such deviation is the subject of an application filed with the OCC, no separate notice to the supervisory office is required); and (ii) obtain the OCC's written determination of no objection before the proposed Bank engages in any significant deviation or change from its business plan or operations. For the avoidance of doubt, a significant deviation includes changes to the proposed Bank's risk and operating limits, as detailed in its business plan. The OCC may impose additional conditions it deems appropriate in a written determination of no objection to the proposed Bank's notice. This condition will remain in effect during the Bank's first three years of operation as a national bank. 5. The Bank must maintain at least $8.7 million in tier 1 capital and must hold at least the greater of 50 percent of its tier 1 capital or $4.35 million in Eligible Liquid Assets.26 The Bank must assess the appropriateness of its level of capital and liquidity on a quarterly basis and hold such higher amounts of capital and liquidity as it determines necessary to support the Bank's risk profile, business strategies, and future growth prospects, and to provide a cushion against unexpected losses. This condition will remain in effect during the Bank's first three years of operation as a national bank. 26 The term "Eligible Liquid Assets" means only Liquid Assets that exceed the aggregate amount of all deposits, borrowed funds, and other liabilities on the Bank's balance sheet that reflect an obligation to repay funds to any party. The term Eligible Liquid Assets shall not include any obligation of any affiliate, any assets that are pledged in any manner, or any assets that are not free and kept free from any lien, encumbrance, charge, right of set off, credit or preference in connection with any claim against the Bank. The term "Liquid Assets" means: (i) unencumbered cash; (ii) deposits at insured depository institutions with a maturity of 90 days or less; (iii) United States government obligations maturing within 90 days or less; and (iv) such other assets as to which the Bank has obtained a written nonobjection from the OCC. . 7 6. The Bank must maintain 180 days of operating expenses27 in Eligible Liquid Assets. This amount must not be double counted with the Eligible Liquid Assets held to comply with the foregoing condition. This condition shall remain in effect during the Bank's first three-years of operation as a national bank. 7. Prior to the appointment of any individual to the position of "senior executive officer," as defined in 12 CFR 5.51(c)(4), or the appointment of any individual to the board of directors, the proposed Bank shall submit to the OCC the information described in the "Changes in Directors and Senior Executive Officers" booklet of the Comptroller's Licensing Manual, and receive a letter of no objection from the OCC. For purposes of this condition, "senior executive officer" includes the Chief Compliance Officer, the Bank Secrecy Act Officer, the Chief Technology Officer, the Chief Information Security Officer, the Chief Trust Officer, and any fiduciary officers or employees designated for that purpose. This information is required by the authority of 12 USC 1818(b) and 12 CFR 5.20(g) and does not require the OCC to review or act on any such information within ninety (90) days. This condition shall remain in effect during the first three years of operations upon conversion as a national bank. The conditions of this approval are conditions "imposed in writing by a federal banking agency in connection with any action on any application, notice, or other request" within the meaning of 12 USC 1818. As such, the conditions are enforceable under 12 USC 1818. In addition, the following conversion requirements must be met: 1. The Bank must purchase adequate fidelity bond coverage in accordance

subject to the following conditions: 1. Upon conversion, FDANA-NY must immediately complete its merger with and into Temporary Bank on the terms described in its application to the OCC. FDANA-NY must obtain the OCC's written determination of no objection before deviating from this approved plan, including the timing thereof. The OCC may impose additional conditions it deems appropriate in a written determination of no objection 2. The Bank 21 must limit its operations to those of a trust company and activities related thereto, as specifically stated in the business plan. The Bank must not meet the definition of "bank" under section 2(c)(1)-(2) of the Bank Holding Company Act. 20 See 12 CFR 5.20(f)-(h), 5.24(d). 21 As used in these conditions, "Bank" means FDANA-NY, Temporary Bank, and/or Resulting Bank to the extent each is in existence at the relevant time. 7 Mr. Michael Lewis 2025-Conversion-342359 2025-Charter-343796 2025-Waiver-343832 2025-Combination-343797 3. If and to the extent necessary, the Bank must conform, cease, or divest its proposed stablecoin issuance and redemption activities and any other activities to comply with the GENIUS Act (12 USC 5901 et seq.), any implementing regulations, and any other applicable laws and regulations that take effect in the future, such compliance to be determined in the sole discretion of the OCC. 4. The Bank must: (i) give the Trust Bank Supervision Office at least sixty (60) days prior written notice of its intent to significantly deviate or change from its business plan or operations, 22 and (ii) obtain the OCC's written determination of no objection before the bank engages in any significant deviation or change from its business plan or operations. For the avoidance of doubt, a significant deviation includes changes to the proposed Bank's risk and operating limits, as detailed in its business plan. The OCC may impose additional conditions it deems appropriate in a written determination of no objection to the bank's notice. This condition will remain in effect during the Bank's first three years of operation as a national bank. 5. The Bank must: obtain the OCC's written determination of no objection before the bank markets, issues, or otherwise makes available any Bank issued stablecoin (or any substantially similar product). The OCC may impose additional conditions it deems appropriate in a written determination of no objection to the Bank's notice. 6. The Bank must maintain at least $25 million in tier 1 capital and must hold at least the greater of 50 percent of its tier 1 capital or $12.5 million in Eligible Liquid Assets. 23 The Bank must assess the appropriateness of its level of capital and liquidity on a quarterly basis and hold such higher amounts of capital and liquidity as it determines necessary to support the bank's risk profile, business strategies, and future growth prospects, and to provide a cushion against unexpected losses. This condition will remain in effect during the bank's first three years of operation as a national bank. 22 If such deviation is the subject of an application filed with the OCC, no separate notice to the supervisory office is required. 23 The term "Eligible Liquid Assets" means only Liquid Assets that exceed the aggregate amount of all deposits, borrowed funds, and other liabilities on the Bank's balance sheet that reflect an obligation to repay funds to any party. The term Eligible Liquid Assets shall not include any obligation of any affiliate, any assets that are pledged in any manner, or any assets that are not free and kept free from any lien, encumbrance, charge, right of set off, credit or preference in connection with any claim against the Bank. The term "Liquid Assets" means: (i) unencumbered cash; (ii) deposits at insured depository institutions with a maturity of 90 days or less; (iii) United States government obligations maturing within 90 days or less; and (iv) such other assets as to which the Bank has obtained a written nonobjection from the OCC. 8 Mr. Michael Lewis 2025-Conversion-342359 2025-Charter-343796 2025-Waiver-343832 2025-Combination-343797 7. The Bank must maintain 180 days of operating expenses 24 in Eligible Liquid Assets. This amount must not be double counted with the Eligible Liquid Assets held to comply with the foregoing condition. This condition will remain in effect during the Bank's first three years of operation as a national bank. 8. Prior to the appointment of any individual to the position of "senior executive officer," as defined in 12 CFR 5.51(c)(4), or the appointment of any individual to the board of directors, the Bank must submit to the OCC the information described in the "Changes in Directors and Senior Executive Officers" booklet of the Comptroller's Licensing Manual, and receive a letter of no objection from the OCC. For purposes of this condition, "senior executive officer" includes the Chief Compliance Officer, the Bank Secrecy Act Officer, the Chief Technology Officer, the Chief Information Security Officer, the Chief Trust Officer, and any fiduciary officers or employees designated for that purpose. This information is required by the authority of 12 USC 1818(b), 12 CFR 5.20(g), and 5.24(e) and does not require the OCC to review or act on any such information within ninety (90) days. This condition will remain in effect during the Bank's first three years of operation as a national bank. These conditions are conditions "imposed in writing by a Federal banking agency in connection with any action or any application, notice, or other request" within the meaning of 12 USC 1818. As such, the conditions are enforceable under 12 USC 1818. In addition, the Bank 25 must meet the following requirements: 1. The Bank must purchase adequate fidelity bond coverage in accordance with 12 CFR 7.2013, which lists four factors the directors should consider to determine adequacy. 2. The board of directors and management of the Bank must adopt policies, practices, and procedures to ensure the safe and sound operation of the bank. In addition, the board of directors must review and adopt the policies, practices, and procedures continually and ensure the bank's compliance with them. 3. The Bank must apply for stock in a Federal Reserve Bank in accordance with 12 USC 222. 26 24 The minimum 180 days operating expenses must include all fixed and variable operating expenses that would apply in a distressed, wind-down scenario and need not include expenses that would apply only in a normal operating scenario, such as expenses related to research and development. As used in these requirements, "Bank" means FDANA-NY, Temporary Bank, and/or Resulting 25 Bank to the extent each is in existence at the relevant time. 26 See also 12 CFR 209.2. 9 Mr. Michael Lewis 2025-Conversion-342359 2025-Charter-343796 2025-Waiver-343832 2025-Combination-343797 4. The converting institution must ensure that all other required regulatory approvals have been obtained. 5. The directors of the Bank must own qualifying shares in conformance with 12 USC 72 and 12 CFR 7.2005. Upon completion of all steps required to convert to a national banking association, FDANA-NY must submit a Conversion Completion Certification certifying that it has done so. The OCC must be advised in writing in advance of the desired effective date for the Merger so it may issue the necessary certification letter. The OCC will issue a letter certifying consummation of the merger of FDANA-NY into the Temporary Bank when it receives the following: • A Secretary's Certificate for each institution, certifying that a majority of the board of directors approved the Bank Merger, if required. • A Secretary's Certificate from each institution, certifying that the shareholder approvals have been obtained, if required. • An executed merger agreement. • Evidence of all required regulatory approvals not previously submitted. • Documentation that all other conditions imposed by the OCC have been met. If the conversion of FDAS into FDANA-NY and the merger of FDANA-NY into the Temporary Bank are not consummated within six months of the OCCs approval date, the approvals will automatically terminate, unless the OCC grants an extension. Organizers, Directors and Officers The OCC poses no objection to the following persons serving as executive officers, directors, and/or organizers as proposed in the Application: Name Title Michael O'Reilly Director and Chairman, President John J. Burke III Director Irwin Barnes Director Michael Kearney Director David Morse Director Patricia Murphy Director Charles Senatore Director 10 Mr. Michael Lewis 2025-Conversion-342359 2025-Charter-343796 2025-Waiver-343832 2025-Combination-343797 Brian Hickey Head of Operations Anna Lent Head of Finance Penry Jackson Head of Risk Jill Evans Chief Compliance Officer Terrence Dempsey Head of Product Strategy Waiver of Residency Requirements The OCC also granted your request to waive the residency requirements of 12

subject to the following condition(s): 1. The Bank must limit its operations to those of a trust company and activities related thereto, as specifically stated in the business plan. The Bank must not meet the definition of "bank" under section 2(c)(1)-(2) of the Bank Holding Company Act. 2. If and to the extent necessary, the Bank must conform its proposed activities to comply 21 See, e.g., 12 USC 1841(c) (definition of bank excluding uninsured banks that do not both accept demand deposits and make commercial loans). 22 12 CFR 51. 6 Michael Nonaka, Esq. 2025-Charter-343449 2025-Waiver-343506 with the GENIUS Act (12 USC 5901 et seq.), any implementing regulations, and any other applicable laws and regulations that take effect in the future, such compliance to be determined in the sole discretion of the OCC. 3. The Bank shall: (i) give the Novel Bank Supervisory (NBS) Office at least sixty (60) days prior written notice of its intent to significantly deviate or change from its business plan or operations (if such deviation is the subject of an application filed with the OCC, no separate notice to the supervisory office is required); and (ii) shall obtain the OCC's written determination of no objection before the proposed Bank engages in any significant deviation or change from its business plan or operations. For the avoidance of doubt, a material deviation includes changes to the proposed Bank's risk and operating limits, as detailed in its business plan, including those established to ensure that the Bank will maintain a highly liquid balance sheet. The OCC may impose additional conditions it deems appropriate in a written determination of no objection to a bank's notice. This condition shall remain in effect throughout the Bank's in organization period and during the Bank's first three years of operation. 4. The Bank must maintain a minimum of $60 million in tier 1 capital of which the greater of at least 50 percent of its tier 1 capital or $30 million must be held in Eligible Liquid Assets.23 The Bank must assess the appropriateness of its level of capital and liquidity on a quarterly basis and hold such higher amounts of capital and liquidity as it determines necessary to support the bank's risk profile, business strategies, and future growth prospects, and to provide a cushion against unexpected losses. This condition will remain in effect during the Bank's first three years of operation. 5. The Bank must maintain 180 days of operating expenses24 in Eligible Liquid Assets. This amount must not be double counted with the Eligible Liquid Assets held to comply with the foregoing condition. This condition will remain in effect during the Bank's first three years of operation. 23 The term "Eligible Liquid Assets" means only Liquid Assets that exceed the aggregate amount of all deposits, borrowed funds, and other liabilities on the Bank's balance sheet that reflect an obligation to repay funds to any party. The term Eligible Liquid Assets shall not include any assets that are pledged in any manner, nor any assets that are not free and kept free from any lien, encumbrance, charge, right of set off, credit or preference in connection with any claim against the Bank. The term "Liquid Assets" means: (i) unencumbered cash; (ii) deposits at insured depository institutions with a maturity of 90 days or less; (iii) United States government obligations maturing within 90 days or less; and (iv) such other assets as to which the Bank has obtained a written nonobjection from the OCC. The term Eligible Liquid Assets shall not include any obligation of any affiliate. 24 The minimum 180 days of operating expenses must include all fixed and variable operating expenses that would apply in a distressed, wind-down scenario and need not include expenses that would apply only in a normal operating scenario, such as expenses related to research and development. 7 Michael Nonaka, Esq. 2025-Charter-343449 2025-Waiver-343506 6. Prior to the appointment of any individual to the position of "senior executive officer," as defined in 12 CFR 5.51(c)(4), or the appointment of any individual to the board of directors, the proposed Bank must submit to the OCC the information described in the "Changes in Directors and Senior Executive Officers" booklet of the Comptroller's Licensing Manual, and receive a letter of no objection from the OCC. For purposes of this condition, "senior executive officer" also includes the Chief Compliance Officer, the Bank Secrecy Act Officer, the Chief Technology Officer, the Chief Information Security Officer, the Chief Trust Officer, and any fiduciary officers or employees designated for that purpose. This information is required by the authority of 12 USC 1818(b) and 12 CFR 5.20(g) and does not require the OCC to review or act on any such information within ninety (90) days. This condition will remain in effect throughout the Bank's in organization period and during the Bank's first three years of operation. The conditions of this approval are conditions "imposed in writing by a Federal banking agency in connection with any action or any application, notice, or other request" within the meaning of 12 USC 1818. As such, the conditions are enforceable under 12 USC 1818. As a de novo national bank, the Bank must also meet the following requirements prior to requesting its preopening examination and befor

subject to the following condition(s): 1. The Bank must limit its operations to those of a trust company and activities related thereto, as specifically stated in the business plan. The Bank must not meet the definition of "bank" as defined in section 2(c)(1)-(2) of the Bank Holding Company Act. 2. The Bank: (i) must give Novel Bank Supervision at least sixty (60) days prior written notice of the proposed Bank's intent to significantly deviate or change from its business plan or operations (if such deviation is the subject of an application filed with the OCC, no separate notice to the supervisory office is required); and (ii) shall obtain the OCC's written determination of no objection before the proposed Bank engages in any significant deviation or change from its business plan or operations. For the avoidance of doubt, a significant deviation includes changes to the proposed Bank's risk and operating limits, as detailed in its business plan. The OCC may impose additional conditions it deems appropriate in a written determination of no objection to the Bank's notice. This condition will remain in effect throughout the Bank's in organization period and during the Bank's first three years of operation. 3. The Bank must maintain a minimum of $15 million in tier 1 capital, of which the greater of at least 50 percent or $7.5 million must be held in Eligible Liquid Assets.23 The Bank must assess the appropriateness of its level of capital and liquidity on a quarterly basis and hold such higher amounts of capital and liquidity as it determines necessary to support the Bank's risk profile, business strategies, and future growth prospects, and to provide a cushion against unexpected losses. This condition shall remain in effect during 22 Under 12 U.S.C. § 92a, fiduciary capacity may include "any other fiduciary capacity in which State banks, trust companies, or other corporations which come into competition with national banks are permitted to act under the laws of the State in which the national bank is located," which is colloquially referred to as the "bootstrap" provision. 23 The term "Eligible Liquid Assets" means only Liquid Assets that exceed the aggregate amount of all deposits, borrowed funds, and other liabilities on the Bank's balance sheet that reflect an obligation to repay funds to any party. The term Eligible Liquid Assets shall not include any assets that are pledged in any manner, nor any assets that are not free and kept free from any lien, encumbrance, charge, right of set off, credit or preference in connection with any claim against the Bank. The term "Liquid Assets" means: (i) unencumbered cash; (ii) deposits at insured depository institutions with a maturity of 90 days or less; (iii) United States government obligations maturing within 90 days or less; and (iv) such other assets as to which the Bank has obtained a written nonobjection from the OCC. The term Eligible Liquid Assets shall not include any obligation of any affiliate. 7 Mr. Daniel Nunez Cohen 2025-Charter-343659 2025-Waiver-343920 the Bank's first three years of operation. 4. The Bank must maintain 180 days of operating expenses24 in Eligible Liquid Assets. This amount must not be double counted with the Eligible Liquid Assets held to comply with the foregoing condition. This condition shall remain in effect during the Bank's first three years of operation. 5. Prior to the appointment of any individual to the position of "senior executive officer," as defined in 12 CFR 5.51(c)(4), or the appointment of any individual to the board of directors, the proposed Bank shall submit to the OCC the information described in the "Changes in Directors and Senior Executive Officers" booklet of the Comptroller's Licensing Manual, and receive a letter of no objection from the OCC. For purposes of this condition, "senior executive officer" includes the Chief Compliance Officer, the Bank Secrecy Act Officer, the Chief Technology Officer, the Chief Information Security Officer, the Treasurer, the Chief Trust Officer and any fiduciary officers or employees designated for that purpose. This information is required by the authority of 12 USC 1818(b) and 12 CFR 5.20(g) and does not require the OCC to review or act on any such information within ninety (90) days. This condition will remain in effect throughout the Bank's in organization period and during the Bank's first three years of operation. These conditions of this approval are conditions "imposed in writing by a Federal banking agency in connection with any action or any application, notice, or other request" within the meaning of 12 USC 1818. As such, the conditions are enforceable under 12 USC 1818. As a de novo national bank, the proposed Bank must also meet the following requirements prior to requesting its preopening examination and

subject to the following conditions: 1. The Bank must limit its operations to those of a trust company and activities related thereto, as specifically stated in the business plan. The Bank must not meet the definition of "bank" under section 2(c)(1)-(2) of the Bank Holding Company Act. 2. If and to the extent necessary, the Bank must conform, cease, or divest its proposed collateral trustee structure and any other activities to comply with the GENIUS Act (12 USC 5901 et seq.), any implementing regulations, and any other applicable laws and regulations that take effect in the future, such compliance to be determined in the sole discretion of the OCC. 3. The Bank: (i) must give the Novel Bank Supervisory Office at least sixty (60) days prior written notice of the Bank's intent to significantly deviate or change from its business plan or operations (if such deviation is the subject of an application filed with the OCC, no separate notice to the supervisory office is required); and (ii) must obtain the OCC's written determination of no objection before the Bank engages in any significant deviation or change from its business plan or operations. For the avoidance of doubt, a significant deviation includes changes to the Bank's risk and operating limits, as detailed in its business plan. The OCC may impose additional conditions it deems appropriate in a written determination of no objection to the Bank's notice. This condition will remain in effect throughout the Bank's in-organization period and during the Bank's first three years of operation. 4. The Bank must maintain a minimum of $45 million in tier 1 capital of which the greater of at least 50 percent of its tier 1 capital or $27.5 million must be held in 9 Mrs. Paris Cribben 2025-Charter-342299 2025-Waiver-342964 Eligible Liquid Assets.37 The Bank must assess the appropriateness of its level of capital and liquidity on a quarterly basis and hold such higher amounts of capital and liquidity as it determines necessary to support the bank's risk profile, business strategies, and future growth prospects, and to provide a cushion against unexpected losses. This condition will remain in effect during the Bank's first three years of operation. 5. The Bank must develop and implement an appropriate Capital Adequacy and Liquidity Management Policy (CALM) that will be adopted by the Bank prior to the effective date of commencing operations as detailed in the Application. 6. The Bank must maintain 180 days of operating expenses38 in Eligible Liquid Assets. This amount must not be double counted with the Eligible Liquid Assets held to comply with the foregoing condition. This condition will remain in effect during the Bank's first three years of operation. 7. Prior to the appointment of any individual to the position of "senior executive officer," as defined in 12 CFR 5.51(c)(4), or the appointment of any individual to the board of directors, the Bank must submit to the OCC the information described in the "Changes in Directors and Senior Executive Officers" booklet of the Comptroller's Licensing Manual, and receive a letter of no objection from the OCC. For purposes of this condition, "senior executive officer" also includes the Chief Compliance Officer, the Bank Secrecy Act Officer, the Chief Technology Officer, the Chief Information Security Officer, the Chief Trust Officer, and any fiduciary officers or employees designated for that purpose. This information is required by the authority of 12 USC 1818(b) and 12 CFR 5.20(g) and does not require the OCC to review or act on any such information within ninety (90) days. 37 The term "Eligible Liquid Assets" means only Liquid Assets that exceed the aggregate amount of all deposits, borrowed funds, and other liabilities on the Bank's balance sheet that reflect an obligation to repay funds to any party. The term Eligible Liquid Assets shall not include any assets that are pledged in any manner, nor any assets that are not free and kept free from any lien, encumbrance, charge, right of set off, credit or preference in connection with any claim against the Bank. The term "Liquid Assets" means: (i) unencumbered cash; (ii) deposits at insured depository institutions with a maturity of 90 days or less; (iii) United States government obligations maturing within 90 days or less; and (iv) such other assets as to which the Bank has obtained a written nonobjection from the OCC. The term Eligible Liquid Assets shall not include any obligation of any affiliate. 38 The minimum 180 days of operating expenses must include all fixed and variable operating expenses that would apply in a distressed, wind-down scenario and need not include expenses that would apply only in a normal operating scenario, such as expenses related to research and development. 10 Mrs. Paris Cribben 2025-Charter-342299 2025-Waiver-342964 This condition will remain in effect throughout the Bank's in-organization period and during the first three years of operation. The conditions of this approval are conditions "imposed in writing by a Federal banking agency in connection with any action on any application, notice, or other request" within the meaning of 12 USC 1818. As such, the conditions are enforceable under 12 USC 1818. As a de novo national bank, the Bank must also meet the following requirements prior to requesting its preopening examination and befor

subject to the following conditions: 1. MSDTNA must limit its operations to those of a trust company and activities related thereto, as specifically stated in the business plan. MSDTNA must not meet the definition of "bank" under section 2(c)(1) to (c)(2) of the Bank Holding Company Act, 12 USC 1841(c)(1) to (c)(2). 2. If and to the extent necessary, MSDTNA must conform its proposed activities to comply with the GENIUS Act (12 USC 5901 et seq.), any implementing regulations, and any other applicable laws and regulations that take effect in the future, such compliance to be determined in the sole discretion of the OCC. 3. MSDTNA shall: (i) give the respective OCC's Large and Global Financial Institutions (LGFI) Supervisory Office at least sixty (60) days prior written notice of its intent to significantly deviate or change from its business plan or operations; 11 and (ii) obtain the OCC's written determination of no objection before MSDTNA engages in any significant deviation or change from its business plan or operations. For the avoidance of doubt, a significant deviation includes changes to MSDTNA's risk and operating limits, as detailed in its business plan. The OCC may impose additional conditions it deems appropriate in a written determination of no objection to MSDTNA's notice. This condition will remain in effect throughout MSDTNA's in-organization period and during MSDTNA's first three years of operation. 4. MSDTNA must maintain a minimum of $50 million in tier 1 capital, of which the greater of at least 50 percent or $25 million must be held in Eligible Liquid Assets. 12 MSDTNA must assess the appropriateness of its level of capital and liquidity on a quarterly basis and hold such higher amounts of capital and liquidity as it determines necessary to support the bank's risk profile, business strategies, and future growth prospects, and to provide a cushion against unexpected losses. This condition shall remain in effect during MSDTNA's first three years of operation. 11 If such deviation is the subject of an application filed with the OCC, no separate notice to the supervisory office is required. 12 The term "Eligible Liquid Assets" means only Liquid Assets that exceed the aggregate amount of all deposits, borrowed funds, and other liabilities on the Bank's balance sheet that reflect an obligation to repay funds to any party. The term Eligible Liquid Assets shall not include any assets that are pledged in any manner, nor any assets that are not free and kept free from any lien, encumbrance, charge, right of set off, credit or preference in connection with any claim against the Bank. The term "Liquid Assets" means: (i) unencumbered cash; (ii) deposits at insured depository institutions with a maturity of 90 days or less; (iii) United States government obligations maturing within 90 days or less; and (iv) such other assets as to which the Bank has obtained a written nonobjection from the OCC. The term Eligible Liquid Assets shall not include any obligation of any affiliate. 4 Managing Director Bindra 2026-Charter-344925 2026-Waiver-345072 5. MSDTNA must maintain 180 days of operating expenses 13 in Eligible Liquid Assets. This amount must not be double counted with the Eligible Liquid Assets held to comply with the foregoing condition. This condition will remain in effect during MSDTNA's first three years of operation. 6. Prior to the appointment of any individual to the position of "senior executive officer," as defined in 12 CFR 5.51(c)(4), or the appointment of any individual to the board of directors, MSDTNA must submit to the OCC the information described in the "Changes in Directors and Senior Executive Officers" booklet of the Comptroller's Licensing Manual, and receive a letter of no objection from the OCC. For purposes of this condition, "senior executive officer" also includes the Chief Compliance Officer, the Bank Secrecy Act Officer, the Chief Technology Officer, the Chief Information Security Officer, the Chief Trust Officer, and any fiduciary officers or employees designated for that purpose. This information is required by the authority of 12 USC 1818(b) and 12 CFR 5.20(g) and does not require the OCC to review or act on any such information within ninety (90) days. This condition will remain in effect throughout MSDTNA's in-organization period and during MSDTNA's first three years of operation. These conditions of this approval are conditions "imposed in writing by a Federal banking agency in connection with any action or any application, notice, or other request" within the meaning of 12 USC 1818. As such, the conditions are enforceable under 12 USC 1818. In addition, as a de novo national bank, MSDTNA must also meet the following requirements prior to requesting its preopening examination an

subject to the following condition(s): 1. The Bank must limit its operations to those of a trust company and activities related thereto, as specifically stated in the business plan. The Bank must not meet the definition of "bank" under section 2(c)(1)-(2) of the Bank Holding Company Act. 2. If and to the extent necessary, the Bank must conform its proposed activities to comply with the GENIUS Act (12 USC 5901 et seq.), any implementing regulations, and any other applicable laws and regulations that take effect in the future, such compliance to be determined in the sole discretion of the OCC. 3. The Bank shall: (i) give the Specialty Asset Supervisory Office at least sixty (60) days prior written notice of its intent to significantly deviate or change from its business plan or operations;16 and (ii) obtain the OCC's written determination of no objection before the Bank engages in any significant deviation or change from its business plan or operations. For the avoidance of doubt, a significant deviation includes material changes to the Bank's products and services as well as changes to its risk and operating limits, as detailed in its business plan. The OCC may impose additional conditions it deems appropriate in a written determination of no objection to the Bank's notice. This condition shall remain in effect throughout the Bank's in-organization period and during the Bank's first three years of operation. 4. The Bank must maintain a minimum of $6.50 million in tier 1 capital of which the greater of at least 50 percent or its tier 1 capital or $3.25 million must be held in Eligible Liquid Assets.17 The Bank must assess the appropriateness of its level of capital and liquidity on a quarterly basis and hold such higher amounts of capital and liquidity as it determines necessary to support the Bank's risk profile, business strategies, and future growth 16 If such deviation is the subject of an application filed with the OCC, no separate notice to the supervisory office is required. 17 The term "Eligible Liquid Assets" means only Liquid Assets that exceed the aggregate amount of all deposits, borrowed funds, and other liabilities on the Bank's balance sheet that reflect an obligation to repay funds to any party. The term Eligible Liquid Assets shall not include any assets that are pledged in any manner, nor any assets that are not free and kept free from any lien, encumbrance, charge, right of set off, credit or preference in connection with any claim against the Bank. The term "Liquid Assets" means: (i) unencumbered cash; (ii) deposits at insured depository institutions with a maturity of 90 days or less; (iii) United States government obligations maturing within 90 days or less; and (iv) such other assets as to which the Bank has obtained a written nonobjection from the OCC. The term Eligible Liquid Assets shall not include any obligation of any affiliate. 5 Purvi Maniar 2026-Charter-344710 2026-Waiver-345277 prospects, and to provide a cushion against unexpected losses. This condition will remain in effect during the Bank's first three years of operation. 5. The Bank must maintain 180 days of operating expenses 18 in Eligible Liquid Assets. This amount must not be double counted with the Eligible Liquid Assets held to comply with the foregoing condition. This condition will remain in effect during the Bank's first three years of operation. 6. Prior to the appointment of any individual to the position of "senior executive officer," as defined in 12 CFR 5.51(c)(4), or the appointment of any individual to the board of directors, the Bank must submit to the OCC the information described in the "Changes in Directors and Senior Executive Officers" booklet of the Comptroller's Licensing Manual, and receive a letter of no objection from the OCC. For purposes of this condition, "senior executive officer" also includes the Chief Compliance Officer, the Bank Secrecy Act Officer, the Chief Technology Officer, the Chief Information Security Officer, the Chief Trust Officer, and any fiduciary officers or employees designated for that purpose. This information is required by the authority of 12 USC 1818(b) and 12 CFR 5.20(g) and does not require the OCC to review or act on any such information within ninety (90) days. This condition will remain in effect throughout the Bank's in-organization period and during the Bank's first three years of operation. The conditions of this approval are conditions "imposed in writing by a Federal banking agency in connection with any action or any application, notice, or other request" within the meaning of 12 USC 1818. As such, the conditions are enforceable under 12 USC 1818. As a de novo national bank, the Bank must also meet the following requirements prior to requesting its preopening examination and befor

— conditions section could not be located in this document —

subject to the following conditions: 1. The Bank must limit its operations to those of a trust company and activities related thereto, as specifically stated in the business plan. The Bank must not meet the definition of "bank" under section 2(c)(1)-(2) of the Bank Holding Company Act. 2. If and to the extent necessary, the Bank must conform, cease, or divest its proposed activities to comply with the GENIUS Act (12 USC 5901 et seq.), any implementing regulations, and any other applicable laws and regulations that take effect in the future, such compliance to be determined in the sole discretion of the 22 See 12 USC 4807. 23 See, e.g., Interpretive Letters No. 1026 (Apr. 27, 2005) and No. 380 (Dec. 29, 1986) and Banking Circular No. 196 (May 7, 1985) (affirming the authority of national banks to engage in securities lending activities, including in a fiduciary capacity). 7 Mr. Greg Gilman 2025-Charter-342009 2025-Waiver-343370 OCC. 3. The Bank: (i) must give the Novel Bank Supervisory Office at least sixty (60) days prior written notice of the Bank's intent to significantly deviate or change from its business plan or operations (if such deviation is the subject of an application filed with the OCC, no separate notice to the supervisory office is required); and (ii) must obtain the OCC's written determination of no objection before the Bank engages in any significant deviation or change from its business plan or operations. For the avoidance of doubt, a significant deviation includes changes to the Bank's risk and operating limits, as detailed in its business plan. The OCC may impose additional conditions it deems appropriate in a written determination of no objection to the Bank's notice. This condition will remain in effect throughout the Bank's in-organization period and during the Bank's first three years of operation. 4. The Bank must maintain a minimum of $15 million in tier 1 capital of which the greater of at least 50 percent of its tier 1 capital or $7.5 million must be held in Eligible Liquid Assets.24 The Bank must assess the appropriateness of its level of capital and liquidity on a quarterly basis and hold such higher amounts of capital and liquidity as it determines necessary to support the Bank's risk profile, business strategies, and future growth prospects, and to provide a cushion against unexpected losses. This condition will remain in effect during the Bank's first three years of operation. 5. The Bank must maintain 180 days of operating expenses25 in Eligible Liquid Assets. This amount must not be double counted with the Eligible Liquid Assets held to comply with the foregoing condition. This condition will remain in effect during the Bank's first three years of operation. [footnote] 24 The term "Eligible Liquid Assets" means only Liquid Assets that exceed the aggregate amount of all deposits, borrowed funds, and other liabilities on the Bank's balance sheet that reflect an obligation to repay funds to any party. The term Eligible Liquid Assets shall not include any assets that are pledged in any manner, nor any assets that are not free and kept free from any lien, encumbrance, charge, right of set off, credit or preference in connection with any claim against the Bank. The term "Liquid Assets" means: (i) unencumbered cash; (ii) deposits at insured depository institutions with a maturity of 90 days or less; (iii) United States government obligations maturing within 90 days or less; and (iv) such other assets as to which the Bank has obtained a written nonobjection from the OCC. The term Eligible Liquid Assets shall not include any obligation of any affiliate. [footnote] 25 The minimum 180 days of operating expenses must include all fixed and variable operating expenses that would apply in a distressed, wind-down scenario and need not include expenses that would apply only in a normal operating scenario, such as expenses related to research and development. 8 Mr. Greg Gilman 2025-Charter-342009 2025-Waiver-343370 6. Prior to the appointment of any individual to the position of "senior executive officer," as defined in 12 CFR 5.51(c)(4), or the appointment of any individual to the board of directors, the Bank must submit to the OCC the information described in the "Changes in Directors and Senior Executive Officers" booklet of the Comptroller's Licensing Manual, and receive a letter of no objection from the OCC. For purposes of this condition, "senior executive officer" also includes the Chief Compliance Officer, the Bank Secrecy Act Officer, the Chief Technology Officer, the Chief Information Security Officer, the Chief Trust Officer, and any fiduciary officers or employees designated for that purpose. This information is required by the authority of 12 USC 1818(b) and 12 CFR 5.20(g) and does not require the OCC to review or act on any such information within ninety (90) days. This condition will remain in effect throughout the Bank's in-organization period and during the Bank's first three years of operation. These conditions are conditions "imposed in writing by a federal banking agency in connection with any action or any application, notice, or other request" within the meaning of 12 USC 1818. As such, the conditions are enforceable under 12 USC 1818. In addition, the Bank must also meet the following requirements prior to requesting its preopening examination and before the OCC will grant final charter approval pursuant to 12 USC 27(a): 1. The Bank's financial statements must be prepared on an accrual basis according to generally accepted accounting principles. 2. The Bank must engage an independent, external auditor to perform an audit according to generally accepted auditing standards of sufficient scope to enable the auditor to render an opinion on the financial statements of the Bank taken as a whole. The audit period shall commence on the date that the organizing group forms a body corporate and may end on any calendar quarter-end no later than 12 months after the Bank opens. The OCC expects that such audits will be performed annually for at least three years following commencement of operations. Engagement of an auditor will be verified during the preopening examination (see the "Charters" booklet, Internal and External Audits discussion). 3. The directors of the Bank must own qualifying shares in conformance with 12 USC 72 and 12 CFR 7.2005. 4. The Bank must have adequate fidelity bond coverage in accordance with 12 CFR 7.2013, which lists four factors the directors should consider to determine adequacy (see the "Charters" booklet, Fidelity and Other Insurance discussion). 5. The President, or the person serving in the function of President, of the Bank must serve as a member of the board of directors. 9 Mr. Greg Gilman 2025-Charter-342009 2025-Waiver-343370 6. Each person who, together with his or her related interests, subscribes to 10 percent or more of the initial stock offering must submit a biographical and financial report for review to the Chartering,

subject to the following conditions: 1. The Bank must limit its operations to those of a trust company and activities related thereto, as specifically stated in the business plan. The Bank must not meet the definition of "bank" under section 2(c)(1)-(2) of the BHC Act. 2. If and to the extent necessary, the Bank must conform, cease, or divest its proposed activities, including stablecoin issuance and redemption activities, to comply with the GENIUS Act (12 USC 5901 et seq.), any implementing regulations, and any other applicable laws and regulations that take effect in the future, such compliance is to be determined in the sole discretion of the OCC. 3. The Bank shall: (i) give the Specialty Asset Supervisory Office at least sixty (60) days prior written notice of its intent to significantly deviate or change from its business plan or operations;23 and (ii) obtain the OCC's written determination of no objection before the Bank engages in any significant deviation or change from its business plan or operations. For the avoidance of doubt, a significant deviation includes material changes to the Bank's products and services as well as changes to its risk and operating limits, as detailed in its business plan. The OCC may impose additional conditions it deems appropriate in a written determination of no objection to the Bank's notice. This condition shall remain in effect throughout the Bank's in-organization period and during the Bank's first three years of operation. 4. The Bank must maintain a minimum of $20 million in tier 1 capital of which the greater of at least 50 percent of its tier 1 capital or $10 million must be held in Eligible Liquid Assets.24 The Bank must assess the appropriateness of its level of [footnote] 23 If such deviation is the subject of an application filed with the OCC, no separate notice to the supervisory office is required. [footnote] 24 The term "Eligible Liquid Assets" means only Liquid Assets that exceed the aggregate amount of all deposits, borrowed funds, and other liabilities on the Bank's balance sheet that reflect an obligation to repay funds to any party. The term Eligible Liquid Assets shall not include any assets that are pledged in any manner, nor any assets that are not free and kept free from any lien, encumbrance, charge, right of set off, credit or preference in connection with any claim against the Bank. The term "Liquid Assets" means: (i) unencumbered cash; (ii) deposits at insured depository institutions with a maturity of 90 days or less; (iii) United States government obligations maturing within 90 days or less; and (iv) such other assets as to 8 Brandi Reynolds 2026-Charter-344521 capital and liquidity on a quarterly basis and hold such higher amounts of capital and liquidity as it determines necessary to support the Bank's risk profile, business strategies, and future growth prospects, and to provide a cushion against unexpected losses. This condition shall remain in effect during the Bank's first three years of operation. 5. The Bank must maintain 180 days of operating expenses 25 in Eligible Liquid Assets. This amount must not be double counted with the Eligible Liquid Assets held to comply with the foregoing condition. This condition will remain in effect during the Bank's first three years of operation. 6. Prior to the appointment of any individual to the position of "senior executive officer," as defined in 12 CFR 5.51(c)(4), or the appointment of any individual to the board of directors, the Bank must submit to the OCC the information described in the "Changes in Directors and Senior Executive Officers" booklet of the Comptroller's Licensing Manual, and receive a letter of no objection from the OCC. For purposes of this condition, "senior executive officer" also includes the Chief Compliance Officer, the Bank Secrecy Act Officer, the Chief Technology Officer, the Chief Information Security Officer, the Chief Trust Officer, and any fiduciary officers or employees designated for that purpose. This information is required by the authority of 12 USC 1818(b) and 12 CFR 5.20(g) and does not require the OCC to review or act on any such information within 90 days. This condition will remain in effect throughout the Bank's in-organization period and during the Bank's first three years of operation. 7. The Bank shall designate and retain a qualified Bank employee or other individual to serve as the Bank's internal audit manager and primary internal audit liaison. The internal audit manager shall be independent of the activities audited and shall not have responsibility for managing, performing, or overseeing day-to-day operational, compliance, risk management, or internal control functions that are subject to audit review. The internal audit manager shall have sufficient expertise, authority, and stature within the Bank to oversee the outsourced internal audit function, including approval of the audit risk assessment, audit plan, audit scope, review of audit reports, and monitoring of corrective actions.