Court filing
Declaration of William M. Martin in Support of Defendants Memorandum — In re BofA Unemployment Litigation (Dkt. 350-8)
Filed October 24, 2024 in In re Bank of America California Unemployment Benefits Litigation; one of 1415 filings from this case.
Record facts
| Court | U.S. District Court for the Southern District of California |
|---|---|
| Filed | 2024-10-24 |
U.S. District Court for the Southern District of California · No. 3:21-md-02992-GPC-MSB · Doc. 350-8 · 2024-10-24 · Docket on CourtListener
Full text
EXHIBIT 7 FILED PROVISIONALLY UNDER SEAL WITH REDACTIONS PURSUANT TO STIPULATED PROTECTIVE ORDER Case 3:21-md-02992-GPC-MSB Document 350-8 Filed 10/24/24 PageID.11103 Page 1 of 12 Case 3:21-md-02992-GPC-MSB Document 350-8 Filed 10/24/24 PageID.11104 Page 2 of 12 HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY MARTIN DECL ISO OPP. TO CLASS CERT. 2 CASE NO. 3:21-MD-02992-GPC-MSB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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 Case 3:21-md-02992-GPC-MSB Document 350-8 Filed 10/24/24 PageID.11105 Page 3 of 12 Case 3:21-md-02992-GPC-MSB Document 350-8 Filed 10/24/24 PageID.11106 Page 4 of 12 Case 3:21-md-02992-GPC-MSB Document 350-8 Filed 10/24/24 PageID.11107 Page 5 of 12 Case 3:21-md-02992-GPC-MSB Document 350-8 Filed 10/24/24 PageID.11108 Page 6 of 12 Case 3:21-md-02992-GPC-MSB Document 350-8 Filed 10/24/24 PageID.11109 Page 7 of 12 Case 3:21-md-02992-GPC-MSB Document 350-8 Filed 10/24/24 PageID.11110 Page 8 of 12 Case 3:21-md-02992-GPC-MSB Document 350-8 Filed 10/24/24 PageID.11111 Page 9 of 12 Case 3:21-md-02992-GPC-MSB Document 350-8 Filed 10/24/24 PageID.11112 Page 10 of 12 Case 3:21-md-02992-GPC-MSB Document 350-8 Filed 10/24/24 PageID.11113 Page 11 of 12 Case 3:21-md-02992-GPC-MSB Document 350-8 Filed 10/24/24 PageID.11114 Page 12 of 12
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- gov.uscourts.casd.709615.350.8.pdf
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- 1,759,057 bytes
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- bc26eb7121abc3cab0c4f36fdb3cb3ad12f0522d697bd5deba74c7e69ece7897
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