Whether the execution of a bank fraud scheme is complete upon disbursal of funds or subsequent cover-up efforts constitute a separate execution that extends the statute of limitations

QUESTION PRESENTED Whether, in a bank fraud prosecution, the execution of a scheme to defraud is complete upon disbursal of funds, thereby starting the clock for statute of limitations purposes, or whether subsequent efforts to “cover-up” a prior execution of a scheme constitute a separate execution of that scheme that extends the statute of limitations.