I am writing in response to the Commission's request for comment published in the Federal Register on January 17, 2003. I will address the question of whether the base offense level and/or the loss table of U.S.S.G. § 2B1.1 should be further modified to provide across-the-board sentence increases for economic crime offenders at virtually all loss levels. In my view, no case for doing so has yet been made.
Frank O. Bowman III, A Challenge To The Rationale For General Economic Crime Sentence Increases Following Sarbanes-Oxley: Letter Of Frank Bowman To U.S. Sentencing Commission February 10, 15 Fed. Sent. R. 284 (2003)