(18)    Commitments and Contingencies

On  October 24, 2024, the Company received a letter from the staff of the Boston Regional Office of the SEC informing the Company that the staff had made a preliminary determination to recommend that the SEC file an action against the Company for violating certain sections of the federal securities laws (the “Wells Notice”). The staff has indicated that the Wells Notice relates to the Company’s disclosures regarding loans that the Company made to companies engaged in the mining of cryptocurrency – a line of business the Company ceased originating new loans in as of  October 2022. The Wells Notice indicates that the staff’s recommendation to the SEC  may involve a civil injunction action or other action allowed by law, and  may seek remedies that include an injunction, disgorgement, pre-judgment interest, civil money penalties, and such other relief as  may be available.

The Company is pursuing the Wells Notice process and continues to explore a potential resolution with the SEC staff. As of June 30, 2025, the Bank has recorded a contingency of $350,000 in connection with this matter. However, the ultimate outcome, including the results, timing, costs, and other potential consequences, remains uncertain and could differ significantly from current estimates. Associated legal costs are expensed as incurred.