Declaration of William M. Martin in Support of Defendants Memorandum — In re BofA Unemployment Litigation (Dkt. 350-8)

Summary

Document 350-8 filed October 24, 2024 in Case 3:21-MD-02992-GPC-MSB (S.D. Cal.) is the Declaration of William M. Martin in support of the opposition to class certification, marked Exhibit 7 and filed provisionally under seal with redactions under the Stipulated Protective Order. Martin states he is Bank of America, N.A.'s Senior Vice President of Fraud Operations and a Prepaid Fraud Operations Executive. He describes leading the prepaid fraud operations team and analyzing fraud tied to unauthorized transaction claims. He says he is familiar with the authentication EDD cardholders needed to unblock cards, BANA's decision to block rather than freeze suspected cards, and its implementation of regulators' consent orders. The remainder of the declaration is blank in the scan.

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EXHIBIT 7
FILED 
PROVISIONALLY 
UNDER SEAL WITH 
REDACTIONS 
PURSUANT TO 
STIPULATED 
PROTECTIVE ORDER
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HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY 
MARTIN DECL ISO OPP. TO CLASS CERT.  
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CASE NO. 3:21-MD-02992-GPC-MSB  
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I, William M. Martin, hereby declare as follows: 
1.
I am employed by Bank of America, N.A. (“BANA”) as Senior Vice
President of Fraud Operations and a Prepaid Fraud Operations Executive.  I make 
this declaration based upon personal knowledge and belief, upon BANA’s records 
maintained in the ordinary course and scope of business, and upon information 
gathered from other Bank employees.  If called to testify as to any of the matters set 
forth in this declaration, I could and would competently testify thereto 
2.
In my capacity as Program Management Executive in Prepaid
Unemployment, and in my prior role as Senior Fraud Policy Manager in Prepaid 
Unemployment, my responsibilities include leading the prepaid fraud operations 
team, analyzing fraud associated with unauthorized transaction claims, and 
identifying characteristics of those claims in order to detect and prevent future fraud. 
In my current role, I also function as the Head of the Prepaid Fraud Operations team. 
In the past, I was also responsible for commercial, prepaid, and treasury fraud 
operations, which included similar responsibilities but for commercial and treasury 
products in addition to prepaid. 
3.
In my current and prior roles, I have been directly and personally
involved in the development and implementation of BANA’s fraud detection 
capabilities and efforts, including its use of anti-fraud strategies in State 
unemployment insurance (“UI”) programs, including California’s Employment 
Development Department (“EDD”) UI program.  Specifically, I am familiar with the 
level of authentication EDD cardholders had to provide to unblock cards that were 
blocked as a result of suspected fraudulent activity, as well as BANA’s decision to 
block, rather than freeze, EDD prepaid cards suspected of fraudulent activity.  I am 
also familiar with certain aspects of BANA’s implementation of the regulators’ 
consent orders and the Remediation Plans and Addenda in connection with BANA’s 
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