Whether 18 U.S.C. 514(a) prohibits the use of fake versions of actual, existing types of documents and instruments

QUESTION PRESENTED 18 U.S.C. 514(a) prohibits the use of “any false or fictitious instrument, document, or other item appearing, representing, purporting, or contriving through scheme or artifice, to be an actual [government] security or other financial instrument.” The question presented is whether Section 514(a) prohibits only the use of nonexistent types of documents and instruments (as the Fifth, Sixth, Eighth, and Ninth Circuits have held), or whether it also covers the use of fake versions of actual, existing types of documents and instruments (as the Eleventh Circuit and the Second Circuit in this case have held). (I)