Excerpt: The proposed regulation on the nonqualified deferred compensation rules of Code section 409A ... is not a page turner (though it's a lot of pages to turn, at 238 pages); but that didn't stop this reader from furiously (if wearily) turning its pages to search for the grandfather rules that I had found so elusive in December when the initial official guidance under the statute ... was released by the Service ... Alas, my search of the just-proposed regs has proved unenlightening.