Samarah

MEMORANDUM **

Husam Samarah appeals his jury trial conviction and 41-month prison sentence for fourteen counts of bank fraud, in violation of 18 U.S.C. § 1344 . We have jurisdiction pursuant to 18 U.S.C. § 3742 and 28 U.S.C. § 1291 , and we affirm.

Samarah first contends that there was insufficient evidence for a jury to conclude that he made material false representations to the financial institution in furtherance of the scheme to defraud. 1 Reviewing de novo, we conclude that a rational trier of fact could find the essential elements of the crime beyond a reasonable doubt. United States v. Hernandez, 105 F.3d 1330, 1332 (9th Cir.1997). The false representations need not have preceded the deposit of the fraudulent check, see United States v. Bonallo, 858 F.2d 1427, 1433-34 (9th Cir.1988), and the government need not have proven an actual loss. See United States v. Mason, 902 F.2d 1434, 1442 (9th Cir.1990). Additionally, any alleged errors on the part of the financial institution are not a defense to the charges. See United States v. Ciccone, 219 F.3d 1078, 1083 (9th Cir.2000) (rejecting defendant’s argument that the government had to prove that the scheme was *971 calculated…