U.S. v. Snow, -- F.3d --, 2011 WL 6318850 (10th Cir. 12/19/11) - the Tenth affirms Mr. Snow's sentence for wire fraud and conspiracy to commit wire fraud, which involved more than forty home loans through at least twelve different financial institutions. The district court used appropriate methodology to calculate the amount of the loss and properly applied two-level enhancements for role in the offense and level of sophistication. Where the properties in question had been sold, the net loss was properly calculated by subtracting the sales price from the outstanding balance on the loan. On one property, on which no actual sales price was available, the district court properly estimated the fair market value of the property loss based on the certified assessor's current valuation of the property. The two-level enhancement under § 3B1.1(c) for being an organizer or leader of the mortgage fraud scheme did not require that Mr. Snow led others. He qualified as an "organizer" by exercising decision-making authority and actively participating in planning or organizing all stages of the scheme; he provided cash and knowledge and coordinated and oversaw the implementation of the conspiracy. The two-level enhancement under § 2B1.1(b)(9)(C) for conduct through sophisticated means applied because Mr. Snow orchestrated a vast and complex fraud scheme and also demonstrated complex conduct in concealing the scheme.