In 2010, fraud offenses were the third largest portion of the federal criminal docket, trailing only immigration and drug offenses. And yet, the strong criticisms of the primary advisory guideline governing the sentencing of those offenses, U.S. Sentencing Guideline § 2B1.1, remain unaddressed. Judges, defense lawyers, and commentators have long called for a reassessment of § 2B1.1’s “inordinate emphasis” on the amount of loss caused by an offense.