Exhibit 159 — In re Bank of America California Unemployment Benefits Litigation (Dkt. 378-4, S.D. Cal. No. 3:21-md-02992)

Record facts

U.S. District Court for the Southern District of California · No. 3:21-md-02992-GPC-MSB · Doc. 378-4 · 2024-11-21 · Docket on CourtListener

Full text

Exhibit 159 
Case 3:21-md-02992-GPC-MSB     Document 378-4     Filed 11/21/24     PageID.14270 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF CALIFORNIA 
IN RE BANK OF AMERICA  
CALIFORNIA UNEMPLOYMENT 
BENEFITS LITIGATION 
Case No. 3:21-md-02992-GPC-MSB 
EXPERT REBUTTAL REPORT OF J. DANIEL KREIS 
November 21, 2024 
REDACTED PUBLIC VERSION 
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i 
Table of Contents 
Page 
 
I. 
ASSIGNMENT ............................................................................................................... 1 
II. 
QUALIFICATIONS ..................................................................................................... 2 
III. FACTS AND DATA CONSIDERED ...................................................................... 3 
IV. 
HOURLY RATE ............................................................................................................ 4 
V. 
SUMMARY OF OPINIONS ...................................................................................... 4 
VI. STATEMENT AND EXPLANATION OF OPINIONS ................................... 5 
A. The Bank’s regulators would not have accepted the Claim Fraud Filter 
and the opinion that it was “reasonable” for the Bank to believe they 
would have, is incorrect ............................................................................ 5 
B. Safety and Soundness Requirements Did Not Support the 
Implementation of CFF-1.......................................................................... 9 
C. My report did not ignore the Bank’s position during unprecedented 
circumstances. .........................................................................................10 
D. The Number of Claims and Volume of Fraud does not Excuse the Bank 
from its Obligations under EFTA and Regulation E. ..............................13 
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1 
I. 
ASSIGNMENT 
1. 
I have been retained by Plaintiffs’ counsel in In re Bank of America 
California Unemployment Benefits Litigation, Case No. 3-21-md-02992-LAB-
MSB, to rebut specific opinions contained in the Declarations of Russell Cronan 
(DX 3) and Teresa A. Pesce (DX 2) provided by Bank of America’s (the “Bank”) 
counsel in their opposition to Plaintiffs’ motion for class certification. On August 
29, 2024 I submitted an expert report to this Court to which Mr.  Cronan and Ms. 
Pesce’s reports respond.  
2. 
My rebuttal addresses the following opinions from Mr. Cronan and Ms. 
Pesce:  
a. Section V. from Mr. Cronan’s report  
i. “It was Reasonable for Bank of America to Believe that Its 
Response to the Explosion of Pandemic-Era Prepaid Card 
Fraud Would have been Acceptable to the Bank’s 
Regulators” 
b. Section VII.  from Mr. Cronan’s report and Section VII. from Ms. 
Pesce’s report  
i. “The Kreis Report Ignores the Reality of the Bank’s Position 
During Unprecedented Circumstances”  
ii. “MR. KRIES IGNORES THE REALITIES OF THE 
BANK’S 
POSITION 
DURING 
UNPRECEDENTED 
CIRCUMSTANCES” 
c. Section VI. from Ms. Pesce’s report  
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2 
i. “THE BANK MUST ADMINISTER THE PROGRAM 
FACING BOTH AN UNPRECEDENTED NUMBER OF 
CLAIMS AND AN UNPRECEDENTED VOLUME OF 
FRAUD” 
II. 
QUALIFICATIONS 
3. 
The bulk of my qualifications can be found in my original expert report, 
attached as Exhibit 1 to Plaintiffs’ motion for class certification.  
4. 
For the purposes of this rebuttal, I have several additional qualifications 
of note.  
5. 
During my career, I directly managed the planning, solution 
development, business document development execution and rapid scaling of two 
financial institutions’ capabilities over short periods of time in response to extreme 
external pressures. These two operations involved many business challenges similar 
to those faced by Bank of America during the coronavirus pandemic.  
6. 
First, at First Omni Bank, I personally managed all aspects of the 
scaling of a Credit Operation, moving the bank from a manual process capable of 
handling fewer than 90 new accounts per day in August of 1985, to a semi-automated 
process capable of handling over 10,000 per day by December of 1985. In other 
words, I have direct experience scaling a bank operation by 11,000% in just four 
months.  
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3 
7. 
Second, working with the FDIC, I oversaw an operation that closed 
several hundred thousand accounts in a single day, and developed the call center 
expansion to handle the resulting dramatic increase in calls.  
8. 
Third, I have personal experience working with a FinTech company 
“Upstart1” that sought and obtained a No-Action Letter (“NAL”) from the CFPB 
prior to implementing an AI driven financial application processing system.2 
9. 
Fourth, I have personal experience working with large-scale 
professional services staffing projects using Accenture, one of the largest 
professional services staffing firms on the planet.  
III. 
FACTS AND DATA CONSIDERED 
10. 
In preparing this report, I relied on my knowledge, training, experience, 
and expertise accumulated during my 42-year career in consumer payment systems 
and operations. I also relied on the Plaintiffs’ complaint, documents and information 
produced in discovery in this case, documents provided in Defendants’ opposition 
to Plaintiff’s motion for class certification and documents and information that are 
publicly available. The specific materials I relied upon are cited in this report and in 
the list attached as Appendix B. 
 
1 https://www.upstart.com/ 
2 https://www.consumerfinancemonitor.com/2020/12/10/cfpb-issues-new-no-action-letter-to-
upstart/ 
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4 
IV. 
HOURLY RATE 
11. 
I am being paid for my work on this case at the rate of $450 per hour, 
which is not contingent on the opinions I express or the outcome of this matter.  
V. 
SUMMARY OF OPINIONS3 
12. 
Mr. Cronan’s opinion that it was reasonable for the Bank to believe that 
the Bank’s implementation of the Claim Fraud Filter and specifically the Bank’s 
implementation of the Fraud Filter with Indicator 1, (automatically denying every 
unauthorized-transaction claim submitted by an EDD cardholder that involved an 
ATM withdrawal) (“CFF-1”) in response to pandemic-era prepaid card fraud would 
have been acceptable to the Bank’s regulators is unfounded and ignores the reality 
of the Bank’s access to and relationship with its regulators.  
13. 
Mr. Cronan and Ms. Pesce’s nearly identical opinions, that my previous 
report ignored “the Bank’s position during unprecedented circumstances,” 
inaccurately characterize my report, are unfounded, and are not plausible given the 
Bank’s tremendous resources and capabilities.  
14. 
Ms. Pesce’s opinion that the Bank was facing an unprecedented number 
of claims and an unprecedented volume of fraud and therefore had to implement the 
Claim Fraud Filter because the Bank could not verify that EDD prepaid cardholders 
 
3 All opinions stated in this report, including all opinions about what is consistent with or 
contrary to industry standards or contrary to industry standards, apply to the Class Period, unless 
otherwise indicated. 
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5 
were who they said they were, conflates Enrollment fraud with Transaction fraud, 
ignores the information the Bank did have, and is otherwise unfounded.  
VI. 
STATEMENT AND EXPLANATION OF OPINIONS 
A. 
The Bank’s regulators would not have accepted the Claim Fraud 
Filter and the opinion that it was “reasonable” for the Bank to 
believe they would have, is incorrect  
15. 
Mr. Cronan claims in his report that it was reasonable for the Bank to 
deviate from its usual conduct regarding Regulation E investigations and implement 
the CFF and CFF-1 because of the extraordinary circumstances that existed in the 
summer of 2020, and that the Bank’s regulators would likely have found this 
deviation acceptable. Mr. Cronan opines that during that time, the Bank was forced 
to modify its pre-pandemic investigation approach because of “unprecedented” 
levels of fraud, including the “new” fraud scenario of “double dipping. 4” I do not 
disagree that the Bank faced substantial amounts of fraud during the relevant time 
period, but I strongly disagree with Mr. Cronan’s assertion that the CFF was a 
response that its regulators reasonably would have approved of.  
16. 
As stated in my opening report, the 
 
 
 
4 The phenomenon of “double-dipping” has been around as long as EFTA has been around.  It is 
a known risk in the financial services industry, which EFTA-compliant manual investigation 
protocols, such as the Bank's 
 are designed to identify.  In my opinion if the Bank had 
continued to utilize the 
 to manually investigate unauthorized transaction claims on the 
scale that was necessary, it would have succeeded in identifying most of the transactions that 
involved double-dipping. 
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6 
.5 
In my experience, manual reviews like the 
 which include mandatory 
procedures and supplemental procedures, are extremely effective in achieving what 
they are designed to do, i.e., identify whether the disputed transaction was 
unauthorized as the customer claimed, or authorized, whether as the result of first-
party fraud or an innocent mistake by the customer. 
17. 
In my opinion, the Bank’s statement in its opposition brief that Claim 
Fraud Filter Indicator 1 was based on “
 
 
” is unsupportable.6  In my experience, transaction fraud based on an 
unauthorized ATM transaction is very common in the financial services industry 
where mag-stripe-only cards are involved.  It is for this reason that it is an industry 
standard for investigation protocols, like the Bank’s 
 to include instructions 
for investigating unauthorized ATM withdrawals.  
18. 
Nowhere in Mr. Cronan’s report, or elsewhere in the record, is there 
any indication that the Bank approached its regulators for any kind of pre-approval 
 
5  See Kreis Report § B, ¶¶31-41 (“The Bank’s 
 and related training materials for claims 
analysts provide sensible procedures for EFTA/Reg E compliance that are consistent with well-
established industry standards for investigating unauthorized transaction claims.”). 
6 Opp. to Pls.’s Mot for Class Cert. 2:16-17. 
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7 
(or post-approval) of the Bank’s plan to implement the CFF. The Bank’s 
representative testified to the same.: 
Q. 
 
 
A. 
 
Q. 
 
A. 
 
Q. 
 
 
A. 
 
Q. 
 
 
A. 
 
Q. 
 
 
A. 
.7 
19.
As the second largest bank in the country with over $2 trillion in assets,
the Bank has unparalleled access to its regulators. Given the unprecedented and 
extraordinary nature of CFF-1, the Bank would most certainly have been able to 
approach its regulators to obtain an expedited opinion regarding its plan to 
implement CFF-1. In my experience, even a small financial institution has the ability 
to reach out to regulators to approve the future implementation of automated 
7 Ex. 17 (30(b)(6) Deposition of the Bank by its designee Michael Letson) at 26:5-22. “Ex.” refers to exhibits to the Chan 
Declaration and Supplemental Chan Declaration in support of Plaintiffs’ class certification (“Mot.”); “DX” refers to exhibits 
to the Brys Declaration in support of the Bank’s opposition to class certification (“Opp.”). 
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8 
systems. I have worked with the startup FinTech company “Upstart,” that sought 
and received a No-Action Letter from the CFBP regarding the implementation of an 
automated process. Based on my experience, in my opinion, it is implausible that 
Bank of America, the second largest bank in the country, would have been unable to 
consult its regulators prior to implementing the CFF-1. In my opinion, the Bank’s 
failure to do so indicates that the Bank itself believed that its regulators would not 
have approved the Bank’s implementation of the CFF.  
20. 
As I explained in my original report from ¶¶ 67-75, the Bank’s CFF 
was 
 In supporting his opinion, Mr. Cronan does not address this 
aspect of my report and only asserts that the Bank was justified in “leveraging 
automation and other tools to identify indicia of potential fraud.” Beyond the fact 
that the Bank did not use the CFF to identify fraud as a standard red flag requiring 
follow-up inquiries or investigation, and instead used CFF-1 for the unprecedented 
purpose of decisioning unauthorized transaction claims without any further 
inquiry/investigation, that in fact Mr. Cronan ignores the 
 nature of 
CFF-1 further makes his opinion that the CFF would have been acceptable to 
regulators, unfounded and unreliable. As a general matter, Ms. Pesce and Mr. 
Cronan’s opinions conflate use of automated tools as one step in a bank’s 
investigation, which is not unusual, with what the Bank did here, which was rely on 
the CFF-1 to the exclusion of all other information available to the Bank. 
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9 
B. 
Safety and Soundness Requirements Did Not Support the 
Implementation of CFF-1 
21. 
Mr. Cronan further justifies his opinion that CFF-1 was reasonable by 
positing that “safety and soundness” would not affect the conduct of the Bank’s 
Regulation E investigations in typical circumstances. (Cronan rpt. ¶ 32.) He then 
goes on to say that because of the unusual circumstances, namely the “unprecedented 
spike in fraud” during the pandemic, safety and soundness considerations could have 
made it reasonable for the Bank to believe that its deviation from its longstanding 
and usual Reg E investigation procedures by implementing CFF-1 would be 
acceptable to its regulators. Id. However, this opinion is directly contradicted by Mr. 
Cronan’s concession in ¶ 18 of his report that “
 
.” It is my 
opinion that Mr. Cronan’s statement at ¶ 18 is correct, and that safety and soundness 
considerations would not have caused the Bank to reasonably believe that its 
regulators would have approved of the Bank implementing CFF Indicator 1. To the 
contrary, the absence of any actual threat to the safety and soundness of the Bank 
supports the likely outcome of such a request for advice from the Bank’s regulators 
(which was never made); i.e., that CFF-1 is an unacceptable departure from the 
 and would be unduly harmful 
to consumers.  
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10 
22. 
Lastly, in paragraph 43 of his report, Mr. Cronan admits that he is aware 
of the consent orders with the Bank’s regulators, making specific factual findings 
regarding the impropriety of the Bank’s unilateral actions and fining the Bank $225 
million in connection with the Bank’s implementation of the CFF, making his 
opinion that the regulators would have found it acceptable, even more perplexing.  
C. 
My report did not ignore the Bank’s position during 
unprecedented circumstances. 
23. 
Both Mr. Cronan and Ms. Pesce assert that my opinions that the Bank 
could have prioritized higher-dollar-value claims and hired more staff in response to 
the spike of claims are “fatally flawed” because they assert my report ignores the 
unprecedented circumstances surrounding the Bank’s implementation of the CFF. 
These opinions are unfounded and mischaracterize my report. 
24. 
While the challenges presented by the pandemic were substantial, so 
too are the resources, experience and abilities of Bank of America, the second largest 
Bank in the United States. In my experience, the Bank had ample resources and 
ability to address the challenges created by the pandemic without resorting to 
implementing CFF-1. 
25. 
First, as articulated above, Mr. Cronan admits in paragraph 18 of his 
report that it was “
 
” It does not follow then that my report 
and opinions are flawed because I did not “appropriately consider how pandemic 
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11 
circumstances and safety-and-soundness obligations can affect a financial 
institution’s Regulation E investigative processes.” (Cronan ¶ 57) As discussed 
above, Mr. Cronan agrees that safety and soundness was not threatened by the EDD 
program, so my original opinion that higher dollar value claims could have been 
prioritized for review continues to be correct. Ms. Pesce opines that this option 
would not “solve the problem that the Bank was facing. (Pesce ¶ 53) Ms. Pesce is 
simply incorrect. Increasing the dollar value threshold would alleviate some of the 
burden the Bank faced in investigating claims and would have provided an 
opportunity to triage the Bank’s exposure to fraud by ensuring it was focused on the 
most significant claims. Additionally, in my experience, low-dollar-value claims are 
the least likely to be fraudulent, as fraudsters typically are trying to extract maximum 
value in each fraudulent transaction. Notably, this strategy would also ensure that 
legitimate EDD cardholders were timely receiving their funds in their time of 
extreme need during the height of the pandemic.  
26. 
Second, both Cronan and Pesce’s assertions that hiring additional 
claims analysts was “unrealistic” and “challenging” are unfounded. Cronan asserts 
that hiring sufficient analysts would have taken “months to properly onboard and 
train” and Pesce nakedly asserts that “the Bank could not have just hired masses of 
workers from a temp agency.”  
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12 
27. 
I have direct experience working with Accenture and using its large 
scale professional staffing services. It is my opinion that Bank of America could 
have hired sufficient numbers of highly trained claims analysts in the relevant time 
from this or another highly specialized global professional services company.  
28. 
I have personally managed an engagement with Accenture, where it 
provided human resources to support the development of enhanced customer service 
operations for a leading US lender. Accenture alone operates with approximately 
774,000 people serving clients in over 120 countries.8 
29. 
As I stated in my original report, utilizing the services of such an 
operation (or multiple) would have been expensive, but would have been realistic 
given the enormous resources of the second largest bank in the country. The Bank 
even boasted of its profitability during this same period. According to the Bank’s 
Chief Financial Officer Paul Donofrio in a statement in the Bank’s 3Q20 press 
release:  
"The past nine months have tested us and I’m proud to say that our teammates 
have responded extraordinarily well – continuing to deliver for our customers, 
our communities and our shareholders. In addition to providing billions of 
dollars in credit and liquidity to clients, and committing billions more to the 
communities in which we live and work, we have earned more than twice our 
dividend in every quarter since the crisis began. Equally important, our 
capital position and credit reserves increased this quarter, which 
 
8 https://newsroom.accenture.com/fact-sheet 
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13 
positions us to continue to be a source of strength for all of our 
stakeholders."9  
D. 
The Number of Claims and Volume of Fraud does not Excuse the 
Bank from its Obligations under EFTA and Regulation E. 
30. 
Ms. Pesce’s opinion that the Bank was facing an unprecedented number 
of claims and an unprecedented volume of fraud consistently confuses Enrollment 
fraud with Transaction fraud. My opinions are relevant to transaction fraud, (i.e., 
fraudsters withdrawing funds from legitimate cardholder accounts at ATMs) and Ms. 
Pesce’s conflation of enrollment fraud with transaction fraud (i.e. EDD providing 
benefits to fraudsters) mischaracterizes and fails to respond to my opinions.  
31. 
These two distinct types of fraud are important to distinguish as the 
losses from transactional fraud ATMs are borne by the Bank under EFTA. In my 
opinion, the Bank implemented the CFF to protect itself from these losses.10  
32. 
In contrast, Ms. Pesce opines that the Bank needed to implement the 
CFF partly because 
 
 (Pesce rpt. ¶ 50.)  This opinion is unfounded 
 
 
 
9Bank of America Q3-2020 Press Release: 
https://d1io3yog0oux5.cloudfront.net/_bbf0ea09eaf78598eeac640a10954783/bankofamerica
/db/806/8687/earnings_release/3Q20+Press+Release.pdf (emphasis added) 
 
10 With the CFF, 
 
. (Letson Tr.) 239:3-243:5. 
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14 
,11 
.12 This is further borne out by the 
fact that in March 2021, the Bank 
.13 
Required procedures 
.14  It is my understanding based 
on the Bank’s records that the Bank applied its 
.15 
11 Kreis report ¶ 36(5), (citing Ex. 14 (Daniels Tr.) 155:23-156:21). 
12 Kreis report ¶ 36(2), (citing Ex. 14 (Daniels Tr.) 90:1-91:5 (
) 
13 Ex. 91 at -125921; Ex. 16 (Martin Tr.) 301:18-302:25. 
14 See, e.g., Ex. 47 at -100663 (Bank instructing analysts to “
.” See also, 
Kreis report ¶ 36 (6) ”
”  
15 Id. See also, Opp. to Pls.’s Mot for Class Cert. 20:19-23:8.  
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15 
33. 
Ms. Pesce’s opinion even includes some of this evidence where she 
agrees 
 
. (Pesce ¶ 43) 
34. 
In my experience, the Bank also had other methods to ascertain 
customer information that would not have required them to resort to implementing 
the CFF. Namely, the Bank could have conducted a third-party automated screening 
of EDD accounts with an organization like LexisNexis or Trulioo. For example, in 
addition to “
” and “
,” the Bank’s “
 
” list other “
” including “
 
 
,” 
“
,” “
 
” “
 
” and 
 
16 
These and other tools could have been used to segment individuals with inconsistent 
information from other accountholders. The Bank’s representative Martin 
 
 in his 30(b)6 deposition. According to Martin, 
 
 
16 Ex. 64 at -90723 
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.17 
Executed on November 21, 2024 
J. DANIEL KREIS 
17 Ex. 16 (Manin Tr.) 21.7:20-220:7 
16 
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APPENDIX B 
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Date
Doc Type
Title/Desciption
Bates Range
4/1/2020
PowerPoint
(Training Slide Deck)
BANA_EDD_MDL-00100530
4/1/2020
PowerPoint
(Training Slide Deck)
BANA_EDD_MDL-00006482 - 6535
4/24/2020
Email
BANA_EDD_MDL-00228914
6/1/2020
PowerPoint
(Training Slide Deck)
BANA_EDD_MDL-00100741
8/18/2020
Email
BANA_EDD_MDL-00455617
8/19/2020
Email
BANA_EDD_MDL-00218256
8/31/2020
Letter
Moore_S_0000367
9/1/2020
PowerPoint 
(Training Slide Deck)
BANA_EDD_MDL-00004535-4580
9/1/2020
PowerPoint
(Training Slide Deck)
BANA_EDDMDL-00003912 - 3937
9/2/2020
Letter
PLFF00000011
9/16/2020
Document
 
9/22/2020
Email
BANA_EDD_MDL-00104526 - 104527
9/23/2020
Email
BANA_EDD_MDL-00225047-225048
9/23/2020
Email
 
BANA_EDDMDL-00570333 - 570334
9/24/2020
Email
BANA_EDD_MDL-00129437-129440
9/24/2020
PowerPoint
(Training Slide Deck)
BANA_EDDMDL-00003887 - 3911
9/28/2020
Email
BANA_EDD_MDL-00125177-125179
9/28/2020
Email
BANA_EDD_MDL-00450516-450518
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10/1/2020
PowerPoint 
(Training Slide Deck)
 
 
BANA_EDD_MDL-00005509-5545
10/5/2020
Email
BANA_EDD_MDL-00592192-592194
10/6/2020
Email
BANA_EDD_MDL-00863943-863948
10/9/2020
Document
BANA_EDD_MDL-00592324-592330
10/13/2020
Excel
BANA_EDD_MDL-00181896
10/14/2020
Email
 
BANA_EDD_MDL-00090135-90137
10/22/2020
PowerPoint
(Training Slide Deck)
BANA_EDD_MDL-00100506-529
10/26/2020
PowerPoint
(Training Slide Deck)
 
BANA_EDD_MDL-00100634-100679
10/28/2020
PowerPoint
(Training Slide Deck)
BANA_EDD_MDL-00100616-00100633
10/30/2020
Excel
BANA_EDD_MDL-00225867
10/30/2020
Email
BANA_EDD_MDL-00057504-57506
11/2/2020
Email
BANA_EDD_MDL-00163307-163308
12/3/2020
Email
BANA_EDD_MDL-00100390; 
BANA_EDD_MDL-00100634 -100679 
12/29/2020
Email
BANA_EDD_MDL-00090640-90647
12/31/2020
Letter
BANA_EDD_MDL-00411205, 
-005560, -00556122, -00556152, 
-00556324, -00558991, -00558996, 
-00559094, -00559101; 
PLFF00000008; 
Yuan—A-0000003, -0000004
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1/1/2021
PowerPoint
(Training Slide Deck)
BANA_EDD_MDL-00004535-4580
1/12/2021
Email
BANA_EDD_MDL-00417487-417490
1/13/2021
PowerPoint
BANA_EDD_MDL-00571310
1/14/2021
Email
 
BANA_EDD_MDL-00090695-90698
1/14/2021
Email
BANA_EDD_MDL-00107327-107335
1/26/2021
Email
BANA_EDD_MDL-00090721-90724
3/10/2021
Email
BANA_EDD_MDL-00125919-125923
4/5/2021
Email
 
BANA_EDD_MDL-00028946-28949
4/7/2021
Email
BANA_EDD_MDL-00273305-273307
4/12/2021
Document
(
)
BANA_EDD_MDL-00559693-559980
4/23/2021
Email
BANA_EDD_MDL-00297295
5/11/2021
Email
BANA_EDD_MDL-00159469-159474
5/11/2021
Email
BANA_EDD_MDL-00510141-510148
5/17/2021
Court Filing
6/2/2021
Court Filing
7/7/2021
Email
BANA_EDD_MDL-00406128-406130
7/21/2021
PowerPoint
BANA_EDD_MDL-00517105-517126
8/25/2021
Document
BANA_EDD_MDL-00001312
10/29/2021
Email
BANA_EDD_MDL-00077223-77225
7/14/2022
Consent Order
5/25/2023
Court Filing
6/13/2023
Court Filing
10/20/2023
Organizational Charts
BANA_EDD_MDL-00057837-57878
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2/2/2024
Discovery Response
 
2/2/2024
Discovery Response
 
2/4/2024
Deposition Notice
2/6/2024
Deposition Transcript
2/8/2024
Deposition Transcript
2/14/2024
Deposition Transcript
2/16/2024
Deposition Transcript
2/22/22024
Deposition Transcript
4/23/2024
Discovery Response
 
 
N/A
PowerPoint
 
BANA_EDD_MDL-00556536-556537
N/A
Letter
BANA_MDD_MDL-00012790
N/A
Document
BANA_EDD_MDL-00718756-718770
N/A
Document
BANA_EDD_MDL-00012738-12739
N/A
PowerPoint
 
BANA_EDD_MDL-00572766-572770
10/24/2024
Court Filing
10/24/2024
Court Filing
10/24/2024
Court Filing
Defendant's Memorandum of Points and Authorities in 
Opposition to Plaintiffs' Motion for Class Certification
8/29/2024
Court Filing
Expert Class Certification Report of J. Daniel Kreis
N/A
Press Release
Bank of America Q3-2020 Press Release
Case 3:21-md-02992-GPC-MSB     Document 378-4     Filed 11/21/24     PageID.14293 
Page 24 of 25

12/10/2020
Article
Alan S. Kaplinsky, "CFPB issues new no-action letter to Upstart"
Case 3:21-md-02992-GPC-MSB     Document 378-4     Filed 11/21/24     PageID.14294 
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