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BlackRock Pushes OCC to Drop 20% Tokenized Reserve Cap in GENIUS Act Comments

economy-finance · 2026-05-04

On May 1, 2025, BlackRock, the largest asset manager globally, sent a 17-page letter to the U.S. Office of the Comptroller of the Currency (OCC), advocating against a proposed 20% limit on tokenized reserve assets for stablecoin issuers. This correspondence addresses regulations stemming from the GENIUS Act, a federal stablecoin law enacted by President Trump in July 2024. BlackRock contends that the cap is unwarranted, as risk is determined by credit quality, duration, and liquidity rather than tokenization. The firm manages BUIDL, a $2.6 billion tokenized Treasury fund supporting Ethena's USDtb and Jupiter's JupUSD. It seeks confirmation that Treasury ETFs are lawful reserves and favors Option A for diversification. The letter was authored by Roland Villacorta and Benjamin Tecmire, amid a regulatory initiative with a January 2027 compliance deadline involving the FDIC, Treasury, FinCEN, and OFAC.

Key facts

  • BlackRock submitted a 17-page comment letter to the OCC on May 1, 2025.
  • The letter opposes a proposed 20% cap on tokenized reserve assets for stablecoin issuers.
  • The rules implement the GENIUS Act, signed by President Trump in July 2024.
  • BlackRock argues risk is based on credit quality, duration, and liquidity, not tokenization.
  • BlackRock operates BUIDL, a $2.6 billion tokenized Treasury fund.
  • BUIDL backs Ethena's USDtb and Jupiter's JupUSD stablecoins.
  • BlackRock wants Treasury ETFs explicitly confirmed as lawful reserves.
  • BlackRock supports Option A (principles-based) over Option B (mandatory quantitative limits) for diversification.
  • BlackRock recommends adding Treasury floating-rate notes with up to two years maturity to eligible assets.
  • The letter was signed by Roland Villacorta and Benjamin Tecmire.
  • The OCC's rulemaking is part of a broader regulatory push with a January 2027 compliance deadline.

Entities

Institutions

  • BlackRock
  • U.S. Office of the Comptroller of the Currency (OCC)
  • Ethena
  • Jupiter
  • Brookings Institution
  • FDIC
  • Treasury Department
  • Financial Crimes Enforcement Network (FinCEN)
  • Office of Foreign Assets Control (OFAC)
  • NFT Plazas

Locations

  • United States

Sources