What is the impact of prior criminal convictions on a defendant's criminal history category?

Chunza distinguishes his situation from United States v. Mayo, 14 F.3d 128, 131 (2d Cir.1994), where we held that the district court did not err in increasing the defendant's criminal history category based on similar prior conduct. We recognized that while "prior conduct need not have been of an identical type" for an upward departure, it must have been similar. Id. We found that the defendant's prior arsons committed to prevent the auditing of his financial records were fraudulent conduct that was similar to the frauds underlying the convictions and that this warranted an upward departure, because "the difference between a fraud designed to obtain loans in the first place and a fraud designed to avoid their repayment is a

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