After peaking in 1998 (57 offerings), the number of completed Regulation A offerings has significantly declined to just one offering in 2011.

While multiple factors contributed to this decline, a major factor was the increased attractiveness of Regulation D which, unlike Regulation A, preempts state blue sky laws. These laws may require an issuer to go through a costly and time-consuming review process in multiple states, in addition to "mini-registration" with the SEC required by Regulation A. In addition, while Regulation A can only be relied on for offerings of up to $5 million per issuer, per year, Rule 506 of Regulation D has no maximum offering size.

Stakeholders interviewed by the GAO had differing opinions on whether simply raising the $5 million per issuer, per year limit for Regulation A offerings to $50 million would increase its use. While stakeholders believed that the current $5 million offering limitation was deterring the use of Regulation A, some believed that other factors would continue to make Regulation D and other options more attractive than Regulation A regardless of the Regulation A offering cap.