See id. § 3B1.3 cmt. n.3 (explaining that the enhancement should apply because “the defendant assumes a position of trust, relative to the victim, that provides the defendant with the same opportunity to commit a difficult-to-detect crime”). This understanding is confirmed by the cases cited with approval in the application note, each of which involved a direct relationship of trust between the defendant and the victim. See Gill, 99 F.3d at 489 (applying enhancement to defendant posing as licensed psychologist, explaining that “in real life terms, [the defendant] occupied a position of trust relative to his counseling patients, and that [the defendant] took advantage of the patients’ reliance on his claimed status as a psychologist to further his fraud scheme”); Queen, 4 F.3d at 929 (<HOLDING>). Application Note 3 is therefore consistent
recognizing that the imposter investment advisorbroker in that case assumed a position of trust with his victims holding that abuse of trust enhancement applied where defendant had discretion to engage in commodities transactions on victims behalf without victims supervision holding that jury may consider victims mental capacity in determining whether defendant acted with victims knowledge and consent holding that employer controlled the victims will at least in part by using his position as the victims employer holding that assistant principal used position of authority to gain the trust of the victims to obtain the opportunity to touch the victims and to cause them to submit to his unlawful touching