Section I: Introduction

Battle Bank, N.A. (“Battle Bank” or “Bank”) is a nationally chartered bank established on [OPENING DATE] (the “Opening Date”) that maintains its headquarters in Eagle County, Colorado. The Bank is a subsidiary of Battle Financial, Inc. and is regulated by the Office of the Comptroller of the Currency (“OCC”).  As a federally insured depository institution, Battle Bank is subject to the Community Reinvestment Act (“CRA”), which requires banks to help meet the credit needs of their entire community, including low and moderate-income (“LMI”) neighborhoods. The Bank’s CRA strategic plan will be evaluated under 12 CFR 25.21 and 12 CFR 25.27. The Bank has prepared this CRA Strategic Plan for 2023-2026 (“Strategic Plan” or “2023-2026 Plan”).

After the Opening Date, the remainder of 2023 will be used to refine our evaluation of the needs of our assessment area while we bring the bank into operation. During 2023, the first calendar year in which there are operations, the Bank will seek traditional CRA opportunities for loans, investments, and community development and use our experiences and additional research to help refine the tactics to ensure the plan properly addresses the needs of the communities served by Battle Bank. The Strategic Plan will then be used to guide our efforts during the years 2024-2026 of the plan period.