BlackRock has urged the Office of the Comptroller of the Currency to reconsider elements of its proposed rules under the GENIUS Act, particularly those governing tokenized reserve assets.
BlackRock challenges proposed reserve cap
In a formal comment letter, BlackRock called on the OCC to eliminate a potential 20% cap on tokenized reserve assets for stablecoin issuers. The firm argued that such limits are unnecessary and that risk should instead be assessed based on factors like liquidity, credit quality, and maturity.
According to BlackRock, the use of distributed ledger technology should not determine whether an asset is considered safe. This stance questions why tokenized versions of U.S. Treasury instruments would be treated differently from their traditional counterparts.
Debate over GENIUS Act reserve framework
The GENIUS Act, introduced in July 2025, established a federal structure for regulating payment stablecoins. The OCC’s proposal builds on this framework by outlining requirements for reserves, redemptions, custody, and reporting.
Under the draft rules, stablecoin issuers must maintain diversified reserves to manage risks tied to liquidity, credit, interest rates, and pricing. The OCC also cautioned against over-reliance on a single financial institution or a limited group of custodians.
While the proposal permits certain tokenized assets, it raises the possibility of capping their share within reserve portfolios—an idea BlackRock strongly opposes.
Push to broaden eligible assets
BlackRock also requested greater clarity and flexibility around what qualifies as reserve assets. The firm suggested that Treasury-based exchange-traded funds should be eligible, provided they meet strict standards for safety and liquidity.
Currently, the OCC draft includes assets such as U.S. cash, Federal Reserve balances, demand deposits, short-term Treasury securities, repurchase agreements, and select government money market funds.
BUIDL gains traction in crypto markets
The discussion comes as BlackRock’s tokenized Treasury fund, BUIDL, sees growing adoption across crypto infrastructure. Platforms like OKX have integrated the fund into institutional collateral systems in partnership with Standard Chartered.
This setup allows eligible clients to use BUIDL as trading margin while maintaining ownership and yield. The fund primarily invests in cash, U.S. Treasury bills, and repurchase agreements, positioning it as a bridge between traditional finance and digital asset markets.
