Despite the brevity of the discussion, it is apparent that Congress intended to expand the federal government’s prosecutorial power to encompass significant misapplication of federal funds at a local level. The phrase “significant acts of theft” implies that Congress did not intend the statute to reach theft of minimal amounts or theft aggregated over long periods of time. The temporal limitation requirement, in conjunction with the monetary threshold requirement, meets that stated objective. The government’s construction of the statute, on the other hand, would nullify the limitation desired by Congress. Although this issue is one of first impression, inferential support can be found in United States v. Urlacher, 784 F.Supp. 61, 63 (W.D.N.Y.), aff'd, 979 F.2d 935 (2d Cir.1992) (<HOLDING>). In that case, the district court concluded
holding that the source of the federal funds was not a relevant factor in determining the number of violations recognizing that the supremacy clause is not a source of any federal rights holding that sophistication of investor is relevant factor in determining when plaintiff placed on inquiry notice holding that the passage of time was a relevant factor when determining custody issues recognizing the dol opinion letter as the source of the nonstatutory factor