1. Description of the Plan

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The following description of the Metropolitan Commercial Bank 401(k) Plan (the Plan) is provided only for general information. Participants should refer to the Plan document for a more complete description of the Plan’s provisions.

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General

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The Plan is a defined contribution plan, which is sponsored by Metropolitan Commercial Bank (the Company or Employer) covering substantially all employees of the Company. The Plan was effective August 2, 1999, and was recently amended and restated effective May 21, 2021. The Plan is subject to the provisions of the Employee Retirement Income Security Act of 1974 (ERISA), as amended.

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Administration

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The Plan is administered by a designated Plan Administrator (the “Administrator”), which has been appointed by the 401(k) Plan Investment Committee of the Employer. The Administrator is responsible for oversight of the Plan. The 401(k) Plan Investment Committee, which has been appointed by the Board of Directors of the Employer, determines the appropriateness of the Plan’s investment offerings, monitors investment performance, and reports to the Plan’s Administrator. Fidelity Management Trust Company (“Fidelity”) serves as the trustee, and Fidelity Workplace Services LLC serves as the recordkeeper of the Plan.

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Plan Eligibility

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Employees become eligible to participate in the Plan upon completing two months of service. Participation begins on the first day of the month following the date on which the employee satisfies the eligibility requirements.

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Participant Accounts

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Individual accounts are maintained for each Plan participant. Each participant’s account is credited with the participant’s voluntary contribution, any Company matching contribution, any discretionary profit-sharing contribution, and Plan earnings, and is charged for withdrawals, administrative expenses, and any allocation of Plan losses. Allocations are based on participant earnings, deferrals, account balances, or specific participant transactions as defined in the Plan document. The benefit to which a participant is entitled is the benefit that can be provided from the participant’s vested account.

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Employee Contributions

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Participants may contribute on a pre-tax and after-tax basis 1% to 90% of annual compensation subject to annual limitations set forth in Section 402(g) of the Internal Revenue Code (IRC). Participants who have attained age 50 before the end of the Plan year are eligible to make catch-up contributions.

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Participants may also contribute amounts representing rollover distributions from other qualified defined benefit or defined contribution plans. Additional voluntary contributions are not permitted.

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Newly eligible employees are automatically enrolled in the Plan with a 6% deferral rate unless they affirmatively elect not to participate in the Plan or elect a different deferral percentage and are invested in a designated fund until changed by the participant.

2. Summary of Significant Accounting Policies

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3. Related Party and Party-In-Interest Transactions

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Certain Plan investments are shares of registered investment companies managed by affiliates of Fidelity. At December 31, 2025 and 2024, the Plan held 10,435.053 and 9,028.498 shares of Metropolitan Commercial Bank common stock fund (Employer Stock fund) valued at $797,925 and $528,157, respectively. For the year ended December 31, 2025, the Plan purchased 2,824.175 shares and sold 1,417.620 shares and received dividends in the amount of $3,028. These transactions and notes receivable from participants qualify as exempt party-in-interest transactions.

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Certain mutual fund companies share their management fees with the trustee. The agreement between the trustee and the Plan includes a revenue sharing arrangement whereby the trustee shares this revenue with the Plan. These deposits are included in the net appreciation in fair value of investments amount in the statement of changes in net assets available for benefits. At December 31, 2025 and 2024, the revenue credit balance was $706 and $0, respectively. During 2025, $1,121 in revenue credit was allocated to participants.

4. Fair Value Measurement

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The framework for measuring fair value provides a fair value hierarchy that prioritizes the inputs to valuation techniques used to measure fair value. The hierarchy assigns the highest priority to unadjusted quoted prices in active markets for identical assets and liabilities (Level 1 measurement) and lowest priority to unobservable inputs (Level 3 measurement). The three levels of fair value hierarchy are described as follows:

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Level 1 - Unadjusted quoted prices in active markets that are accessible at the measurement date for identical, unrestricted assets or liabilities. An active market asset or liability is a market in which the transaction for the asset or liability occurs with sufficient frequency and volume to provide pricing information on an ongoing basis.

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Level 2 - Observable inputs other than Level 1 prices, such as a quoted price for similar assets or liabilities; quoted market prices in markets that are active; or model-derived valuation or other inputs that are observable or can be corroborated by observable market data for substantially the full terms of the assets or liabilities.

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5. Plan Termination

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Although it has not expressed any intention to do so, the Company has the right under the Plan to discontinue its contributions at any time and to terminate the Plan subject to the provisions set forth in ERISA. In the event the Plan is terminated, participants would become 100% vested in their account balances and such balances shall be distributed to participants and beneficiaries based on their individual accounts in the Plan as of the termination date.

6. Income Tax Status

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The Plan has adopted a Non-Standardized Pre-Approved Profit Sharing Plan with CODA (Pre-Approved Plan) sponsored by FMR LLC, doing business as Fidelity Institutional Asset Management (FMR). The Internal Revenue Service (IRS) has opined and informed FMR by a letter dated June 30, 2020, stating that the form of the pre-approved plan document was in compliance with the applicable requirements of the IRC. Although the Plan has been amended since adopting the pre-approved plan document, the Plan administrator believes the Plan is designed, and is currently being operated, in compliance with the applicable requirements of the IRC and, therefore, believes the Plan is qualified, and the related trust is tax-exempt.

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GAAP requires Plan management to evaluate the tax positions taken by the Plan and recognize a tax liability if the Plan has taken an uncertain position that more likely than not would not be sustained upon examination by the IRS. The Plan is subject to routine audits by taxing jurisdictions; however, there are currently no audits for any tax periods in progress.

7. Risks, Uncertainties, and Concentrations

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The Plan invests in various investment securities. Investment securities are exposed to various risks such as interest rate, market, and credit risks. Market risks include global events which could impact the value of investment securities, such as a pandemic or international conflict. Due to the level of risk associated with certain investment securities, it is at least reasonably possible that changes in the values of investment securities will occur in the near term and that such changes could materially affect participants’ account balances and the amounts reported in the statements of net assets available for benefits.

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The Plan’s investments include certain individual investments that represent significant concentrations as a percentage of net assets available for benefits. As of December 31, 2025 and 2024, such concentrations included four investments totaling $22,942,549 and three investments totaling $13,471,197, respectively.

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8. SECURE Act 2.0

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On December 23, 2022, Congress passed the Consolidated Appropriations Act of 2023 which included SECURE Act 2.0. SECURE Act 2.0 contains over 90 new retirement provisions, with varying effective dates through 2027. Since SECURE Act 2.0 provisions include both required and optional elements, the plan administrator will determine the optional provisions to elect and amend the Plan document accordingly. Most of the significant provisions became effective in 2024 and thereafter. Accordingly, there is no material impact to the Plan’s 2025 financial statements.

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