BlackRock Urges OCC to Drop 20% Cap on Tokenized Reserves in GENIUS Act Comment

According to The Block, BlackRock submitted a 17-page comment letter to the Office of the Comptroller of the Currency on Friday (May 2), urging the agency to reject a proposed 20% quantitative cap on tokenized reserve assets in the GENIUS Act implementation rules. BlackRock argued that such limits are "extraneous" to the OCC's objectives and that risk profiles depend on credit quality and liquidity, not whether assets are held on a distributed ledger.

BlackRock's BUIDL fund, a tokenized Treasury product with $2.6 billion in assets, provides over 90% of reserves backing Ethena's USDtb stablecoin and Jupiter's JupUSD. A 20% cap would significantly constrain BUIDL's growth as a reserve asset under the federal framework. BlackRock also pushed the OCC to explicitly confirm that Treasury ETFs qualify as eligible reserves and recommended adding U.S. Treasury floating-rate notes to the approved asset list.