Section II: Battle Bank’s Commitment to CRA

Battle Bank is committed to excel in delivering on its obligations under the Community Reinvestment Act. Battle Bank expects to fight for the communities that we serve and comply with both the letter and the spirit of the CRA. Battle Bank’s Board of Directors (“Battle Bank Board”) and senior management plan to make a serious and proportional impact on the areas we serve and steadily expand our involvement as the Bank grows. To this end, Battle Bank has established a comprehensive CRA Program that involves participation from the Battle Bank Board, senior management, the Bank’s CRA Coordinator, and Bank employees.

Battle Bank’s CRA Program is under the direction of the Battle Bank Board, with a designated Coordinator (“Coordinator”) who interacts with all other areas of the company on a regular basis. The coordinator is responsible for the implementation and oversight of the CRA activities, any CRA portfolio, and the Bank approved Strategic Plan. The coordinator has extensive experience in community banking with deep ties in the designated area that will be used to determine opportunities to deploy Battle Bank resources to meet community needs in a safe and sound manner.

The CRA Coordinator will ensure that all proposed CRA loans and investments, and approvals follow Battle Bank’s lending policies and guidelines and Battle Bank’s CRA Policy.

As noted below in this document, the business model utilized by Battle Bank is somewhat unique. As a result, in order to make a meaningful impact we have developed this CRA Strategic Plan. In doing so, Battle Bank will be able to act as a community bank in the assessment area (Eagle County, Colorado), and expand the institution nationally through the developed digital channels.

If Battle Bank fails to meet substantially the strategic plan goals for a satisfactory rating, as noted above, we elect to be evaluated under the normal assessment method based on the size of our institution.