This question gets asked 2 to 3 times a week. Just use the search function of the forums for the answer. It isn't a simple yes or no answer. We're talking about the legal gray area of U.S law. It's better suited to contact an attorney of financial law to be certain.
The Securities & Exchange commission, purposefully leave a bleak amount of detail concerning ICO's, most likely to discourage people from proceeding further into this legal gray area, until they decide to provide further regulatory instruction. ICO's are like securities, thats all I'll say.
Best of luck! Read this thread.
https://bitcointalk.org/index.php?topic=2040467.msg20310664#msg20310664