That's what I've suspected for a long while. My guess is that's what Glenn was called in to "fix". But of course Urbie kept on issuing shares, and I don't think he told Roger about it till he had to.
Yes, you can do one Reg D placement every year for up to $5 million worth of stock, register that stock in one state, and then it can be traded unless states in which it isn't registered halt it individually. There've been some problems of that nature with CMKX: if you recall, people from several states said Wells Fargo wouldn't let them trade CMKX because of Blue Skies problems.
And yes, you can issue as much stock as you want for that $5 million price. Still, I just don't think Urbie could have got off between 800 billion and 1.8 trillion that way.