BlackRock Pushes OCC to Drop Tokenized Reserve Cap in GENIUS Act Rulemaking
Talik Evans
- 2 min read
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Key Takeaways
- BlackRock called the OCC’s proposed 20% cap on tokenized reserve assets “extraneous,” arguing that risk is defined by credit quality and liquidity, not ledger format.
- The firm has a direct commercial stake in the outcome: its BUIDL fund holds $2.6 billion in assets and backs reserves for Ethena’s USDtb and Jupiter’s JupUSD.
- BlackRock backed the principles-based Option A reserve standard and asked the OCC to confirm that Treasury ETFs qualify as eligible reserve assets under the GENIUS Act.
BlackRock filed a 17-page comment letter with the Office of the Comptroller of the Currency on May 2, the final day of the agency’s 60-day comment window, urging regulators to scrap a proposed 20% ceiling on tokenized reserve assets and expand the list of eligible instruments backing federally chartered stablecoins.
BlackRock Calls Tokenized Reserve Cap “Extraneous” to Regulatory Goals
The rules govern federally chartered stablecoin issuers under the GENIUS Act, which President Trump signed in July 2025. The firm’s central request is that the OCC abandon its proposed 20% cap on tokenized reserve assets.
BlackRock described the restriction as “extraneous” to the agency’s objectives, arguing that risk is determined by credit quality, duration, and liquidity rather than by whether an asset is held on a distributed ledger. The comment window opened when the OCC’s proposal was published in the Federal Register on March 2, 2026.
BlackRock also recommended adding U.S. Treasury floating-rate notes with up to two years of remaining maturity to the eligible reserve asset list, citing their limited price volatility and weekly coupon resets. The letter was signed by Roland Villacorta, BlackRock’s global head of liquidity and financing, and Benjamin Tecmire, head of U.S. regulatory affairs.
BUIDL Fund Holds $2.6 Billion, Backs Reserves for USDtb and JupUSD
BlackRock’s BUIDL fund holds nearly $2.6 billion in assets, according to RWA.xyz data, and provides more than 90% of the reserves backing Ethena’s USDtb and Solana-based Jupiter’s JupUSD. A 20% cap on tokenized reserves would directly constrain BUIDL’s role as a qualifying reserve asset under the new federal framework.
The firm also asked the OCC to confirm that exchange-traded funds investing solely in eligible reserve assets qualify as reserves under Section 4 of the GENIUS Act. BlackRock said that ambiguity in the current proposal could discourage issuers from holding Treasury ETFs in their reserve portfolios.
BlackRock Backs Principles-Based Reserve Standard Over Mandatory Daily Minimums
BlackRock asked the agency to extend the same quantitative safe harbor treatment, meaning automatic compliance without additional review, that government money market funds already receive. BlackRock restructured its Select Treasury Based Liquidity Fund in October 2025 into a GENIUS-compliant product with a Treasury-heavy mandate aimed at stablecoin reserve use.
On reserve diversification requirements, BlackRock backed the OCC’s “Option A” over “Option B.” Option A pairs a principles-based standard with an optional quantitative safe harbor, while Option B would impose those same requirements as mandatory daily minimums for all issuers. BlackRock argued that Option A better accommodates the range of reserve management approaches across the stablecoin market.
Other Agencies File Concurrent Rules Ahead of January 2027 Deadline
The OCC’s 376-page proposal is one of several concurrent federal rulemakings targeting a January 2027 compliance deadline. The FDIC advanced its own draft rules in early April 2026, and Treasury, FinCEN, and OFAC have filed separate proposals covering anti-money laundering programs and sanctions compliance. The Brookings Institution also submitted a letter on May 2, taking a different position from BlackRock and arguing the OCC should require higher capital charges for uninsured demand deposits held as reserves.
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Talik Evans
Journalist and Financial Analyst
Talik Evans is a financial writer and crypto researcher with a growing focus on digital assets, Bitcoin markets, and blockchain innovation. Since 2021, she has been exploring the world of cryptocurrency, writing about everything from exchange comparisons to regulatory updates and security practices.