On March 18, 2015 WLF submitted comments applauding the Commission for recognizing the pressing need to reform the current Guidelines for white-collar defendants convicted of economic crimes. In past submissions to the Commission, WLF has identified troubling aspects of the Guidelines that produce sentences that are greater than necessary for many low-level, non-violent fraud offenses. WLF agrees with those practitioners, scholars, and judges who have long argued that § 2B1.1’s narrow focus on monetary loss, when combined with the use of numerous overlapping enhancements (which are often an inappropriate measure of culpability), has resulted in unusually long sentences for first-time criminal defendants convicted of economic crimes.