IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

MARIA BROMLEY and KLEBER §

PAUTA, on behalf of themselves and all §

others similarly situated, §

§

Plaintiffs, §

§

v. § Civil Action No. 1:20-CV-439-LY

§

SXSW LLC, and, §

SXSW HOLDINGS, INC., §

§

Defendants. §

DECLARATION OF JOSEPH G. SAUDER IN SUPPORT OF 

PLAINTIFFS’ MOTION FOR PRELIMINARY APPROVAL OF SETTLEMENT, 

CERTIFICATION OF A SETTLEMENT CLASS, 

APPOINTMENT OF CLASS COUNSEL AND RELATED RELIEF

Case 1:20-cv-00439-LY Document 29-1 Filed 09/24/21 Page 1 of 19
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I, Joseph G. Sauder, declare as follows:

1. I am a partner of the law firm of Sauder Schelkopf LLC in Berwyn, Pennsylvania, 

one of the proposed Class Counsel in this Action. I submit this declaration based on my personal 

knowledge and in support of Plaintiffs’ Motion for Preliminary Approval of Settlement, 

Certification of a Settlement Class, Appointment of Class Counsel and Related Relief.

2. I was named by The American Lawyer to its 2021 Northeast Trailblazers. The 

honor recognizes 60 lawyers who are “truly agents of change.” It “recognizes professionals in the 

Northeast who have moved the needle in the legal industry.” The Northeast includes Maine, New 

York, New Jersey, Vermont, Massachusetts, Rhode Island, Connecticut, New Hampshire, and 

Pennsylvania. I was named by The Legal Intelligencer to its 2020 Pennsylvania Trailblazers list 

recognizing 31 lawyers who “have taken extra measures to contribute to positive outcomes . . . and 

who are truly agents of change.” The Legal highlights my innovative work on advocacy as class 

counsel in large institutional sex abuse cover-ups, women's, and children's rights. I have been 

repeatedly recognized by my peers. Since 2011, I have been selected as a Pennsylvania 

SuperLawyer, a distinction held by the top 5% of attorneys in Pennsylvania, as chosen by their 

peers and through the independent research of Law & Politics. 

3. After the 2020 South by Southwest Festival (the “Festival”) was cancelled, Sauder 

Schelkopf LLC and its co-counsel, Cafferty Clobes Meriwether & Sprengel LLP (“Cafferty 

Clobes”), commenced an investigation into reports that SXSW refused to issue refunds for Festival 

Credentials. Consumers reported that SXSW uniformly declined refund requests on grounds its 

Participation & Credential Terms and Conditions (“PCT&C”) included a “no refund” provision. 

SXSW instead offered consumers the right to defer their Credentials to a subsequent year in 

exchange for purportedly releasing all claims arising from the Festival’s cancellation. 

Case 1:20-cv-00439-LY Document 29-1 Filed 09/24/21 Page 2 of 19
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4. After speaking with dozens of consumers whose refund requests SXSW denied and 

analyzing the PCT&C and applicable law, Sauder Schelkopf, Cafferty Clobes, and Howry, Breen 

& Herman, LLP (“Howry Breen” and, collectively with Cafferty Clobes and Sauder Schelkopf, 

“Proposed Class Counsel”) filed this Action on April 24, 2020. My firm has been actively involved 

in all stages of this litigation, and in conjunction with Proposed Class Counsel, has advanced the 

litigation on behalf of Plaintiffs and the proposed Class. 

5. Among other things, Proposed Class Counsel have taken considerable discovery 

conducted in this case, and reviewed and analyzed critical sales and deferral data and exemplar 

Class Member communications and releases, all of which greatly informed our eventual settlement 

discussions and mediation, and which proved invaluable in reaching the proposed Settlement. 

6. On December 17, 2020, I and other co-counsel participated in a full-day mediation 

before mediator Dean Kilgore through the Zoom videoconferencing platform. After more than 

ten hours of arm’s-length negotiations the Parties reached an agreement on the material terms of 

the Settlement. Since then, I have been actively involved in our ongoing discussions aimed at 

memorializing the Settlement Agreement now before the Court, and my firm has assisted in 

drafting the Settlement Agreement, its exhibits, and the other papers in support of Plaintiffs’ 

Motion for Preliminary Approval of Settlement, Certification of a Settlement Class, Appointment 

of Class Counsel, and Related Relief.

7. Based on my experience in this case and in similar class litigation, I respectfully

and unequivocally recommend that this Court find that the proposed Settlement is fair, reasonable, 

and adequate, and grant preliminary approval. I believe this settlement to be an excellent result 

for the Class, particularly at this stage of the litigation and when balanced against the risks of 

continued litigation.

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8. I base this conclusion on my extensive background in litigation on behalf of 

consumers, and I am currently serving, and have served, as lead or co-lead counsel in class actions 

in courts across the country. See, e.g., Jackson v. Viking Group, Inc., No. 8:18-cv-02356-PJM, 

ECF No. 46 (D. Md.) (class action settlement valued between $30.45 million and $50.75 million 

that provided a free replacement program to replace the allegedly defective sprinklers with nondefective sprinklers, and a claims program to reimburse those who experienced non-fire 

activations); Cole v. NIBCO, Inc., No. 13-7871, ECF No. 227 (D.N.J. April 12, 2019) ($43.5 

million settlement related to allegedly defective plumbing products in which Sauder Schelkopf 

served as class counsel); Amborn, et al. v. Behr Process Corp., et al., No. 17-cv-4464 (N.D. Ill.) 

(settlement on behalf of purchasers of allegedly defective deck resurfacing product; In re Checking 

Account Overdraft Litig., MDL No. 2036 (S.D. Fla.) ($55 million class action settlement with US 

Bank and $14.5 million class action settlement with Comerica); McCoy v. North State Aviation, 

LLC and NSA Holdings, Inc., No. 1:17-CV-346 ($1.5 million settlement on behalf of hundreds of 

employees in North Carolina whose WARN Act rights were violated when they were abruptly 

fired without notice); Klug v. Watts Regulator Co., No. 8:15-cv-61 (D. Neb.) and Ponzo v. Watts 

Regulator Co., No. 8:16-200 (D. Neb.) ($14 million settlement on behalf of homeowners with 

defective toilet connectors and water heater connectors manufactured by Watts); Ajose, et al. v. 

Interline Brands, Inc., No. 14-cv-01707, (M.D. Tenn.) ($16.5 million nationwide class action 

settlement related to defective DuraPro plumbing supply lines.); Physicians of Winter Haven v 

Steris Corp., 1:10-cv-00264 (N.D. Ohio) ($20 million nationwide class action settlement on behalf 

of surgical centers to recoup out of pocket expenses related to a recalled medical device); Traxler 

v. PPG Indus., Inc., No. 1:15-cv-00912-DAP (N.D. Ohio); ($6.5 million class action settlement on 

behalf of homeowners who purchased and used defective deck resurfacer). Attached as Exhibit 

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A is a true and correct copy of the firm resume of Sauder Schelkopf LLC. 

9. This experience, coupled with the experience of co-counsel in this case, enabled 

our firms to undertake this matter and to successfully combat the resources of Defendants and their 

capable and experienced counsel

I declare under penalty of perjury under the laws of the United States of America that the 

foregoing facts are true and correct and that this declaration was executed on September 24, 2021.

/s/ Joseph G. Sauder

Joseph G. Sauder

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EXHIBIT A

Case 1:20-cv-00439-LY Document 29-1 Filed 09/24/21 Page 6 of 19
Telephone: 888.711.9975

Facsimile: 610.421.1326

1109 Lancaster Avenue

Berwyn, PA 19312

www.sauderschelkopf.com

 

Case 1:20-cv-00439-LY Document 29-1 Filed 09/24/21 Page 7 of 19
Attorneys Joseph G. Sauder 

 Matthew D. Schelkopf 

 Lori G. Kier 

 Joseph B. Kenney 

 Sonjay C. Singh 

 

Practice Areas Automobile Defects and False Advertising 

 Consumer Fraud Class Actions 

 Sexual Misconduct and Gender Discrimination 

 Employee Rights Class Actions 

 General Complex Litigation 

 

Case Highlights 

 

 

 

 

 

Case 1:20-cv-00439-LY Document 29-1 Filed 09/24/21 Page 8 of 19
 

Joseph G. Sauder, Partner

Joseph G. Sauder handles complex cases on behalf 

of individuals, sexual misconduct victims, 

consumers, small businesses and employees. Mr. 

Sauder currently serves as court appointed lead 

counsel in state and federal courts across the country. 

He has successfully litigated cases against some of the 

largest companies in the world.

The Legal Intelligencer named Mr. Sauder in its 2020 Pennsylvania Trailblazers list 

recognizing 31 lawyers who “have taken extra measures to contribute to positive 

outcomes . . . and who are truly agents of change.” The Legal highlights Joe’s 

innovative work on advocacy as class counsel in large institutional sex abuse cover-ups, 

women's, and children's rights. Since 2012, Mr. Sauder has been selected by the

National Trial Lawyers Association as one of the Top 100 Trial Lawyers in 

Pennsylvania. Since 2011, Mr. Sauder has been selected as a Pennsylvania 

SuperLawyer, a distinction held by the top 5% of attorneys in PA, as chosen by their 

peers and through the independent research of Law & Politics. The American Lawyer 

Media, publisher of The Legal Intelligencer and the Pennsylvania Law Weekly, 

named Mr. Sauder as one of the “Lawyers on the Fast Track” a distinction that 

recognized thirty-five Pennsylvania attorneys under the age of 40 who show

outstanding promise in the legal profession and make a significant commitment to 

their community.

From 1998 to 2003, Mr. Sauder was a prosecutor in the Philadelphia District

Attorney’s Office where he tried hundreds of criminal cases to verdict. Mr. Sauder

received his Bachelor of Science, magna cum laude in Finance from Temple 

University in 1995. He graduated from Temple University School of Law in 1998, 

where he was a member of Temple Law Review.

Mr. Sauder is admitted to practice before the Supreme Courts of Pennsylvania and 

New Jersey, the United States Court of Appeals for the Third Circuit, the United 

States District Courts for the Eastern District of Pennsylvania, the Middle District of 

Pennsylvania, the District of New Jersey and the District of Colorado. Mr. Sauder 

currently serves as a lead counsel in numerous class actions related to product, 

construction and automotive defect cases pending throughout the country.

Case 1:20-cv-00439-LY Document 29-1 Filed 09/24/21 Page 9 of 19
Matthew D. Schelkopf, Partner

Matthew D. Schelkopf has extensive trial and

courtroom experience throughout the United States, 

with an emphasis on class actions involving 

automotive defects, consumer protection, defective 

products and mass torts litigation.

The Legal Intelligencer named Mr. Schelkopf in 

its 2020 Pennsylvania Trailblazers list recognizing 31 lawyers who “have taken extra 

measures to contribute to positive outcomes . . . and who are truly agents of 

change.” The Legal highlights Matthew’s work on behalf of clients who have been 

victimized by corporations. Since 2010, Mr. Schelkopf has been selected by

Pennsylvania Super Lawyers as a Rising Star (a distinction held by the top 2.5% of 

attorneys in PA) and then a Pennsylvania Super Lawyer, as chosen by their peers and 

through the independent research of Law & Politics. In 2012, The American Lawyer 

Media, publisher of The Legal Intelligencer and the Pennsylvania Law Weekly, 

named Mr. Schelkopf as one of the “Lawyers on the Fast Track” a distinction that 

recognized thirty-five Pennsylvania attorneys under the age of 40 who show

outstanding promise in the legal profession and make a significant commitment to 

their community. Mr. Schelkopf was also selected as a Top 40 under 40 by the 

National Trial Lawyers in 2012-2015. 

Mr. Schelkopf began his legal profession as a criminal prosecutor with the District 

Attorney’s Office of York County. He quickly progressed to Senior Deputy 

Prosecutor where he headed a trial team responsible for approximately 300 felony 

and misdemeanor cases each quarterly trial term. 

In 2004, Mr. Schelkopf then associated with a suburban Philadelphia area law firm, 

litigating civil matters throughout Pennsylvania and New Jersey. In 2006, he was cocounsel in a Philadelphia County trial resulting in a $30,000,000.00 jury verdict in 

favor of his clients – the largest state verdict recorded for that year. Mr. Schelkopf

currently serves as a lead and co-lead counsel in numerous class actions related to 

product and automotive defect cases pending throughout the country.

Outside of the office, Mr. Schelkopf enjoys spending time with his family, mountain 

and road biking, skiing and restoring classic automobiles. Three of his auto

restorations have been featured in nationally circulated automotive publications.

Case 1:20-cv-00439-LY Document 29-1 Filed 09/24/21 Page 10 of 19
Lori Kier, Counsel

With a broad litigation background, Lori G. Kier 

serves as Of Counsel to the firm. For nearly 25 years, 

Ms. Kier served as senior attorney at the U.S. 

Environmental Protection Agency in Philadelphia. 

Prior to her time at EPA, Ms. Kier was a staff 

attorney at the U.S. Court of Appeals for the Third 

Circuit and a Law Clerk to U.S. District Judge Fred 

I. Parker (D. Vt.). 

At EPA, Ms. Kier developed and prosecuted enforcement cases (administrative and 

judicial) under multiple state and federal environmental statutes, and participated in 

all aspects of litigation, both as primary counsel and in support of the U.S. Department 

of Justice. She led various teams in developing enforcement initiatives, most 

prominently in the areas of municipal and industrial stormwater. Other statutory areas 

covered included: Clean Water Act, Emergency Planning and Community Right-toKnow Act, Federal Insecticide, Fungicide, and Rodenticide Act National Historic 

Preservation Act, Resource Conservation and Recovery Act, Safe Drinking Water 

Act, and Toxic Substances Control Act. 

As an active participant in her local community, Ms. Kier is currently a member of 

the East Goshen Township Zoning Hearing Board and previously served on the 

Township’s Planning Commission. She serves as a Democratic Committee Person 

and has also been a mock trial coach for two local high schools as well as a judge for 

high school, college, and law school mock trial and moot court competitions

Case 1:20-cv-00439-LY Document 29-1 Filed 09/24/21 Page 11 of 19
Joseph B. Kenney, Associate

Joseph B. Kenney has experience representing

consumers in class actions involving defective

products, automotive defects, false and misleading 

advertising, and other consumer protection litigation.

Joe received his J.D., cum laude, from Villanova

University School of Law in 2013. He was elected 

as a Managing Editor of Student Works for the Jeffrey S. Moorad Journal of Sports 

Law for his third year of law school. As a staff writer, his comment was selected for

publication in the Spring 2012 Volume of the Journal. Prior to law school, Joe 

attended Ursinus College where he was a member of the men’s varsity soccer team.

Joe is admitted to practice before the Supreme Courts of Pennsylvania and New Jersey 

and the United States District Courts for the Eastern District of Pennsylvania and the 

District of New Jersey. In 2017 and 2018, Joe was distinguished as a Pennsylvania 

SuperLawyer Rising Star.

Case 1:20-cv-00439-LY Document 29-1 Filed 09/24/21 Page 12 of 19
Sonjay C. Singh, 

Associate

Through his law school studies and clerkships, Sonjay 

worked with litigators across the country to achieve 

optimal client outcomes in the areas of personal injury, 

products liability, medical malpractice, and 

employment discrimination. He is excited to continue 

fighting for plaintiffs with Sauder Schelkopf.

Sonjay received his J.D. with a certificate in Trial Advocacy and Litigation from the 

Temple University Beasley School of Law in 2020. As a law student, Sonjay was a 

member of the National Trial Team and won accolades at trial competitions 

nationwide. He also served as Vice President of the Student Bar Association and 

interviewed prospective professors as a student member of the Faculty Selection 

Committee. In his final year of law school, Sonjay was named the Stewart J. 

Eisenberg Scholar for his excellence in trial advocacy and received the Trial 

Program Award as the outstanding graduate in the field of civil litigation.

Sonjay enjoys spending time outdoors in his free time, whether hiking, skiing, 

kayaking, or rock climbing. He is active in local politics and served as an elected 

Democratic Committeeperson in Marple Township from 2017 to 2019.

Case 1:20-cv-00439-LY Document 29-1 Filed 09/24/21 Page 13 of 19
Practice Area: Consumer Fraud Class Actions

The attorneys at Sauder Schelkopf have prosecuted and resolved numerous consumer 

fraud class actions on behalf of millions of consumers against nationally known 

corporations for deceptive and unfair business practices. Sauder Schelkopf’s 

experience includes the following types of consumer fraud class action cases:

Automotive Defects – Automobiles are a major expense and consumers expect them 

to provide safe and reliable transportation for themselves and their family and friends. 

Some vehicles, however, may contain manufacturing or design defects that can pose a 

danger to our families and others on the road. Even if these defects do not create a 

potential safety issue, they might result in costly repairs to consumers. 

Construction Defects – When consumers purchase a home, they expect the plumbing 

and other basic functions of the home to work without fail. Certain companies, 

however, are known to cut corners when designing and manufacturing their products. 

When an essential component of the home fails, it can lead to costly repair bills, 

damage to the surrounding property in the home, and high homeowner’s deductibles. 

Consumer Electronics Defects – As technology continues to evolve, more and more 

consumers purchase and depend upon electronic devices in their daily routines. From 

smartphones to state-of-the art drones, many manufacturers rush products to sale to 

take advantage of high consumer demand. As these products are rushed to market, 

consumers often are left between the difficult choice of paying expensive repair bills 

or placing their expensive product on the shelf to gather dust. 

Medical Device Defects – Manufacturers of medical devices are held to high standards 

in the design, manufacturing, and marketing of their products. When a manufacturer 

learns of a defect in their medical device that could cause bodily harm to the end-user, 

the law imposes a strict duty on them to institute a recall immediately. Many times, 

however, manufacturers seek to place profits above the safety of their customers

Case 1:20-cv-00439-LY Document 29-1 Filed 09/24/21 Page 14 of 19
Practice Area: Sexual Misconduct and Gender 

Discrimination 

Sauder Schelkopf has a nationally recognized sexual misconduct practice with 

significant experience fighting for victims. Our former prosecutors have extensive 

experience investigating and trying cases. Sauder Schelkopf currently represents 

victims of clergy sexual abuse in dioceses throughout the country. We have 

numerous class action lawsuits pending throughout the country on behalf of sexual 

abuse survivors including:

• Male students and student-athletes who were victims of sexually misconduct

by The Ohio State University team doctor Richard Strauss.

• Female victims of sexual misconduct as patients of Dr. George Tyndall, a

former gynecologist at the University of Southern California who started in the 

1990s.

• Female patients of gynecologist Dr. Patrick Sutton of Huntington Memorial 

Hospital in Pasadena, California accused of inappropriate sexual conduct and 

comments during examinations and deliveries.

Case 1:20-cv-00439-LY Document 29-1 Filed 09/24/21 Page 15 of 19
Practice Area: Employee Rights Class Actions

The attorneys at Sauder Schelkopf have protected workers’ rights. Employees are 

given numerous protections under state and federal law. The attorneys at Sauder 

Schelkopf has held employers accountable to their obligations under the law when 

hiring, employing, and firing their workers. 

If employees face discrimination based on their race, color, country of origin, religion, 

gender, sexual orientation, the employer is violating the law. In addition, many 

employees do not receive their due compensation as numerous employers engage in 

wage and hour violations. Whether you are a potential whistleblower, or your case is 

associated with any technical or creative legal matter, the attorneys at Sauder Schelkopf 

are available to discuss your potential case.

Case 1:20-cv-00439-LY Document 29-1 Filed 09/24/21 Page 16 of 19
Case Highlights

The attorneys at Sauder Schelkopf have played a lead role in cases throughout the 

country including:

• In re Checking Account Overdraft Litig., (S.D. Fla.) (class action resulting in a 

$55 million settlement with US Bank; $14.5 million settlement with 

Comerica);

• Afzal v. BMW of North America, LLC, (D.N.J.) (class action on behalf of 

purchasers and lessees of BMW M3 vehicles with S65 engines containing an 

alleged rotating assembly defect resulting in engine failure);

• Ajose v. Interline Brands, Inc., (M.D. Tenn.) ($16.5 million nationwide class 

action settlement on behalf of purchasers of defective toilet connectors);

• Rangel v. Cardell Cabinetry, LLC, (W.D. Tex.) ($800,000 settlement on 

behalf of hundreds of former employees of a Texas cabinetry maker for 

Worker Adjustment and Retraining Notification (WARN) violations when 

they were fired without notice);

• In re: Outer Banks Power Outage Litigation (E.D.N.C.) ($10.3 million 

settlement on behalf of businesses impacted by massive power outage and 

evacuation cause by a bridge builder);

• Guill, Jr. v. Alliance Resource Partners, L.P. et al (S.D. Ill) (WARN Act class 

action on behalf of 200 coal miners);

• Bang v. BMW of North America, LLC, (D.N.J.) (nationwide class action

settlement on behalf of hundreds of thousands of purchasers and lessees of 

certain BMW vehicles with N63 engines containing alleged oil consumption 

defect);

• Traxler v. PPG Industries, Inc. (N.D. Ohio) ($6.5 million class action 

settlement on behalf of homeowners who purchased and used defective deck 

stain); 

• Physicians of Winter Haven v. Steris Corp., (N.D. Ohio) ($20 million class 

action settlement on behalf of surgical centers to recoup out-of-pocket 

expenses related to recalled medical device); 

Case 1:20-cv-00439-LY Document 29-1 Filed 09/24/21 Page 17 of 19
• In re Stericycle Inc., Sterisafe Contract Litigation, (N.D. Ill.) ($295 million 

class action settlement on behalf of medical waste disposal customers of 

Stericycle regarding alleged automated price increases in violation of 

contractual terms);

• Desio et al. v. Insinkerator et al. (E.D. WA) ($3.8 million class action 

settlement on behalf of homeowners who purchased defective water filters); 

• Davitt v. Honda North America, Inc., (D.N.J.) (class action nationwide 

settlement on behalf of hundreds of thousands of purchasers and lessees of 

Honda CR-V vehicles with alleged defective door lock actuators);

• McCoy v. North State Aviation, (M.D.NC) ($1.5 million settlement on behalf 

of hundreds of former employees for Worker Adjustment and Retraining 

Notification (WARN) violations when they were fired without notice);

• Henderson v. Volvo Cars of North America LLC, (D.N.J.) (class action 

nationwide settlement on behalf of 90,000 purchasers and lessees of Volvo 

vehicles with defective GM4T65 automatic transmissions);

• Klug v. Watts Regulatory Co., and Ponzo v. Watts Regulatory Co (D. Neb.) 

($14 million settlement on behalf of homeowners with defective toilet 

connectors and water heater connectors manufactured by Watts);

• Lax v. Toyota Motor Corporation (N.D. Cal.) (class action on behalf of 

hundreds of thousands of purchasers and lessees of certain Toyota vehicles 

with alleged oil consumption defect);

• Mendoza v. Hyundai Motor America, Inc., (N.D. Cal.) (class action on behalf 

of hundreds of thousands of purchasers and lessees of certain Hyundai Sonata 

vehicles with alleged connecting rod bearing defect resulting in engine failure);

• Neale v. Volvo Cars of North America LLC, (D.N.J.) (certified class action on 

behalf of hundreds of thousands of purchasers and lessees of certain Volvo 

vehicles with alleged defective sunroof water drainage systems);

• Rivera v. Ford Motor Company, (E.D. Mich.) (class action on behalf of 

hundreds of thousands of purchasers and lessees of certain Ford Focus 

vehicles with alleged defective Evaporative Emission Control (EVAP) systems 

causing sudden and unexpected engine stalling);

Case 1:20-cv-00439-LY Document 29-1 Filed 09/24/21 Page 18 of 19
• Wallis v. Kia Motors America, Inc., (N.D. Cal.) (class action on behalf of 

hundreds of thousands of purchasers and lessees of certain Kia vehicles with 

alleged connecting rod bearing defect resulting in engine failure);

• Whalen v. Ford Motor Co., (N.D. Cal.) (class action on behalf of hundreds of 

thousands of purchasers and lessees of certain Ford and Lincoln vehicles with 

alleged defective MyFord Touch infotainment systems);

• Tolmasoff v. General Motors, (E.D. MI.) ($6 million nationwide class action 

settlement on behalf of purchasers and lessees alleging overstated MPG);

• Yaeger v. Subaru of America, Inc., (D.N.J.) (class action on behalf of 

hundreds of thousands of purchasers and lessees of certain Subaru vehicles 

with alleged oil consumption defect);

• Smith v. Gaiam, (D. Colo.) ($10 million consumer class action settlement, 

which provided full relief to the class).

• International Brotherhood of Electrical Workers Local 98 Pension Fund v 

Encore, (San Diego, CA) (shareholder derivative settlement implemented 

industry-leading reforms to its risk management and corporate governance 

practices, including creating Chief Risk Officer and Chief Compliance Officer 

positions, various compliance committees, and procedures for consumer 

complaint monitoring)

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