Orange Friday

Traveling today. The picture below tells where and why.

I've been thinking about prospective sunshine all week. It was raining in Seattle yesterday. It has been raining in Seattle all week.

Program Notes: Two topics I can't get into today in depth, to which we will return, soon enough:

• The association of state and provincial securities administrators, NASAA, has floated a draft of its proposed crowdfunding securities exception. Kudos to Jim Hamilton for blogging an overview. Thanks also to @JoeWallin for tweeting a heads up about Jim's post. The biggest distinguishing feature of the NASAA proposal appears to be that it would require crowdfunding platforms to register as broker-dealers. That will not go over well with many of the folks commenting on the #Crowdfunding posts on this blog.
• Speaking of @JoeWallin, have you noticed that the approach he's taking on his blog lately is to survey core topics in a way that both revisits the fundamentals and brings them into current debates. Exhibit Number 1 of this method is his most recent post about "general solicitation." My own take is that practice has outrun the prohibition on general solicitation. That is, it's not just that the rule is crimping startup financings; it's that the rule is already being breached on an almost wholesale basis. Something's already toppled, and it behooves the regulators, as much as anyone, to reform the rule to conform to current practice.