What is the statute of limitations for a conspiracy to defraud?

The last overt act doctrine prevents the statute of limitations from beginning to run in certain cases, "even after the fraud is discovered ...," until the commission of the last overt act pursuant to the conspiracy. (Id., 24 Cal.3d at p. 788, 157 Cal.Rptr. 392, 598 P.2d 45, emphasis in original; accord Agnew v. Parks (1959) 172 Cal.App.2d 756, 766, 343 P.2d 118.) However, the Wyatt court also recognized that the statute of limitations for a conspiracy to defraud is otherwise governed by section 338(d). (24 Cal.3d at p. 786 and fn. 2, 157 Cal.Rptr. 392, 598 P.2d 45.) In cases in which it is alleged the fraud was not discovered until less than three years prior to the filing of suit, section 338(d) directs the action may be timely despite the fact that the last overt act is more than three years old. Any other rule would simply repeal the three year discovery rule of section 338(d), which is applicable in fraud and conspiracy to defraud cases, and replace it with a straight three year statute measured from the last fraudulent act.