The North American Securities Administrators Association, Inc. (NASAA) is requesting public comments regarding proposed updates to the SCOR Statement of Policy and the SCOR Form (Form U-7).

The SCOR Statement of Policy was last updated in 1996 and the SCOR Form was last updated in 1999. Since that time, the internet has been embraced as a method of raising capital in small offerings to retail investors through crowdfunding and the formatting tools available for offering documents have evolved. In addition, the offering amount limitation under federal Rule 504 was increased from $1 million to $5 million. NASAA is proposing updates to the SCOR Statement of Policy to increase the offering limit from $1 million to $5 million and to incorporate many of the investor protections that have been put in place under state and federal crowdfunding laws, including investment limits, sales report requirements, and ongoing reporting requirements. Other existing provisions from the SCOR Statement of Policy have been updated and modernized in the interests of both investor protection and capital formation.

NASAA is also seeking comments on a comprehensive update of the SCOR Form. The updated SCOR Form includes updates drawn from intrastate crowdfunding forms, federal Form C, word processing features, and changes in federal law. Summaries of the proposed changes to the SCOR Statement of Policy and SCOR Form are discussed in further detail below.

Comments on the proposed changes are due by December 3, 2018.

To facilitate consideration of comments, please send comments to Lisa Hopkins (, Chair of the Corporation Finance Section; Faith Anderson (, Chair of the Small Business/Limited Offerings Project Group; Christopher Staley (, Assistant General Counsel, NASAA; and Mark Stewart (, Counsel, NASAA.

We encourage, but do not require, comments to be submitted by e-mail. Hard copy comments may be submitted at the address below.

NASAA Legal Department
Mark Stewart, Counsel
750 First Street, NE, Suite 1140
Washington, DC 20002

Note: After the comment period has closed, NASAA will post to its website the comments it receives as submitted by the authors. Parties should therefore only submit information that they wish to make publicly available. Further, the following notice will appear on NASAA’s website where comments are posted: NASAA, its agents, and employees accept no responsibility for the content of the comments posted on this webpage. The views, expressions, and opinions expressed in the comments are solely those of the author(s).