The firm described the cap as "extraneous" to the OCC's objectives, arguing that risk is determined by credit quality, duration, and liquidity.
Crypto News
BlackRock filed a 17-page comment letter with the Office of the Comptroller of the Currency (OCC) on May 2, pushing back on several proposed restrictions in the agency's draft rules for the GENIUS Act. The submission arrived on the final day of the OCC's 60-day comment window, which opened when the proposal was published in the Federal Register on March 2, 2026.
The letter addresses rules governing permitted payment stablecoin issuers (PPSIs), the federally chartered entities authorized to issue stablecoins under the GENIUS Act signed by President Trump in July 2025. BlackRock's central request was that the OCC abandon a proposed 20% cap on tokenized reserve assets. The firm described the cap as "extraneous" to the OCC's objectives, arguing that risk is determined by credit quality, duration, and liquidity, not by whether an asset is held on a distributed ledger.
BUIDL Fund Exposure Shapes BlackRock's Position
The firm's stake in the outcome is direct. BlackRock's BUIDL fund holds nearly $2.6 billion in assets, according to RWA(dot)xyz data, and provides over 90% of the reserves backing Ethena's USDtb and Solana (SOL)-based Jupiter's JupUSD. A 20% cap on tokenized reserves would limit BUIDL's role as a reserve asset under the new federal framework.
BlackRock also asked the OCC to confirm that exchange-traded funds (ETFs) investing solely in eligible reserve assets qualify as reserves under Section 4 of the GENIUS Act. The firm warned that ambiguity in the current proposal could deter issuers from holding Treasury ETFs in their portfolios. It asked the agency to extend the same quantitative safe harbor treatment to qualifying ETFs that government money market funds already receive.
On reserve diversification, 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 said Option A better accommodates the range of reserve management approaches across the stablecoin market.
The firm also recommended adding US 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 US regulatory affairs.
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. The OCC's 376-page proposal is one of several 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 filed a letter on May 2, arguing the OCC should require higher capital charges for uninsured demand deposits held as reserves.
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