Quick Take
  • BlackRock called the proposed cap “extraneous” to the agency’s objectives in its letter, filed in the public docket.
  • The firm argued that reserve risk depends on credit quality, duration, and liquidity.
  • It does not matter whether an asset moves on a distributed ledger.
  • The firm’s BUIDL fund holds nearly $2.6 billion in assets, according to RWA.xyz data.

What Happened

BlackRock filed a 17-page comment letter asking the Office of the Comptroller of the Currency (OCC) to scrap a proposed 20% cap on tokenized reserve assets in its draft rules for the GENIUS Act.

BlackRock called the proposed cap “extraneous” to the agency’s objectives in its letter, filed in the public docket.

“[The limit is] extraneous [to the OCC’s objectives…risk profiles are driven by credit quality, duration, and liquidity]…not whether the asset is held or transferred on a distributed ledger,” read an excerpt in the comment letter.

The firm pressed the OCC to confirm that ETFs qualify as reserves under Section 4 of the law. The treatment would extend to Treasury ETFs invested solely in eligible assets.

Roland Villacorta and Benjamin Tecmire signed the letter on behalf of BlackRock. The Brookings Institution filed separately Friday, urging higher capital charges on uninsured deposits held as reserves.

Market Context

Why a Tokenized Reserve Cap Threatens BUIDL

The firm argued that reserve risk depends on credit quality, duration, and liquidity. It does not matter whether an asset moves on a distributed ledger.

It also urged the agency to add two-year US Treasury floating-rate notes to the eligible asset list. The notes carry weekly coupon resets and limited price volatility.

The post BlackRock Signals OCC Tokenized Reserve Cap Would Threaten BUIDL Growth appeared first on BeInCrypto.

Why It Matters

The world’s largest asset manager submitted the filing on the final day of the agency’s 60-day comment window, which opened when the OCC’s proposal was published in the Federal Register on March 2.

That position carries commercial weight. The firm’s BUIDL fund holds nearly $2.6 billion in assets, according to RWA.xyz data.

Details

It supplies more than 90% of the reserves behind Ethena’s USDtb and Jupiter’s JupUSD on Solana.

A 20% ceiling would restrict how aggressively BUIDL can scale inside permitted payment stablecoin issuer reserves.

Circle’s USYC currently leads the tokenized field with $2.9 billion in assets under management.

Other Asks in the Letter

The 376-page proposal sits alongside parallel rulemakings from the FDIC, Treasury, FinCEN, and OFAC. All face a January 2027 compliance deadline.

How the OCC handles tokenization will shape how quickly BUIDL becomes a fixture in bank-issued stablecoin reserves.