Far, far away, from an undisclosed beach location, a friend sent a link to an article which suggests that Sen. Christopher Dodd's financial regulatory reform bill is dead. Check that -- maybe what it really says is that Sen. Dodd will water the bill down as much as he has to, in order to get something passed before he retires at the end of this Congress.

Is the attack on Reg D, taking as it does just a few dozen lines in Sen. Dodd's voluminous, 1200 page bill, politically visible enough to be pushed or pulled one way or another in the partisan struggling? I don't know.

In the meantime, I have heard from a few new sources that the North American Securities Administrators Association (NASAA) is behind, not only the proposal to remove federal preemption of state regulation of securities offerings that are exempt under rule 506 of Reg D, but also the provisions in Sen. Dodd's bill that would raise the qualification thresholds for "accredited investor" status.

A prominent state securities administrator was kind enough to respond to an e-mail I sent him recently, asking for a dialogue. But I haven't had a chance to have a substantive exchange with him yet. If and when we do have that dialogue, I want, first and foremost, to understand the substantive concerns of the NASAA. I also plan to ask him whether the gutting of Reg D, and the raising of the accredited investor thresholds, may be an overbroad solution to a possibly narrower problem. (My working supposition is that, were placement agents and broker dealers banned from Rule 506 offerings, the problems would go away.)

We should also keep our eyes open for proposed legislation in the House. If Sen. Dodd's bill really is going nowhere, perhaps the attack on Reg D will continue from another front.