Actionable intelligence on Regulation D and the regulatory perimeter of private placements
Missouri now stands alongside Ohio as one of two state editions in this publication’s series whose Securities Commissioner currently holds a national-level NASAA leadership role. In December 2025, NASAA appointed Missouri Securities Commissioner Michael O’Donnell as co-chair of its newly established Uniform Securities Act Committee, alongside Wisconsin’s Leslie Van Buskirk. The Committee is conducting a comprehensive review of the model law—the 2002 Uniform Securities Act—that approximately 28 states have adopted in some form. Missouri’s regulatory posture during this review period carries policy-influence weight beyond its operational reach, and counsel advising on Missouri touching offerings should treat positions articulated by Commissioner O’Donnell on questions of model law interpretation and modernization as having reach beyond Missouri itself.
