Statute of limitations: when does the clock begin to tick? Use of the “discovery rule”? In this case: investment: Investment Advisers Act: the Investment Advisers Act makes it illegal for investment advisers to defraud their clients, 15 U. S. C. §§80b–6(1), (2), and authorizes the Securities and Exchange Commission to bring enforcement actions against investment advisers who violate the Act, or against individuals who aid and abet such violations, §80b–9(d). If the SEC seeks civil penalties as part of those actions, it must file suit “within five years from the date when the claim first accrued,” pursuant to a general statute of limitations that governs many penalty provisions throughout the U. S. Code, 28 U. S. C. §2462; the “discovery rule” (…) meaning that the statute of limitations did not begin to run until the SEC discovered or reasonably could have discovered the fraud; held: the five-year clock in §2462 begins to tick when the fraud occurs, not when it is discovered; this is the most natural reading of the statute. “In common parlance a right accrues when it comes into existence.” United States v. Lindsay, 346 U. S. 568, 569. The “standard rule” is that a claim accrues “when the plaintiff has ‘ “a complete and present cause of action.” ’ ” Wallace v. Kato, 549 U. S. 384, 388; discovery rule: that doctrine is an “exception” to the standard rule, and delays accrual “until a plaintiff has ‘discovered’ ” his cause of action. Merck & Co. v. Reynolds, 559 U. S. ___, ___. It arose from the recognition that “something different was needed in the case of fraud, where a defendant’s deceptive conduct may prevent a plaintiff from even knowing that he or she has been defrauded.” Ibid. Thus “where a plaintiff has been injured by fraud and ‘remains in ignorance of it without any fault or want of diligence or care on his part, the bar of the statute does not begin to run until the fraud is discovered.’ ” Holmberg v. Armbrecht, 327 U. S. 392, 397. This Court, however, has never applied the discovery rule in this context, where the plaintiff is not a defrauded victim seeking recompense, but is instead the Government bringing an enforcement action for civil penalties; emphasizing the importance of time limits on penalty actions, Chief Justice Marshall admonished that it “would be utterly repugnant to the genius of our laws” if actions for penalties could “be brought at any distance of time.” Adams v. Woods, 2 Cranch 336, 342 (U.S. S. Ct., 27.02.13, Gabelli v. SEC, C. J. Roberts, unanimous).