BlackRock pushes OCC to rethink tokenized reserve limits

BlackRock has urged the Office of the Comptroller of the Currency to revise parts of its proposed GENIUS Act rules. 

The request centers on tokenized reserve assets and the assets that stablecoin issuers may hold.

BlackRock filed a comment letter asking the OCC to drop a proposed limit on tokenized reserve assets. The firm opposed a possible 20% cap under draft rules for permitted payment stablecoin issuers.

The asset manager argued that risk should depend on credit quality, maturity, and liquidity. It said the use of a distributed ledger should not decide whether an asset qualifies as safe or unsafe. The argument raises doubts around treating tokenized Treasury products differently from traditional versions.

GENIUS Act reserve rules face debate

The GENIUS Act created a federal framework for payment stablecoins in July 2025. The OCC’s proposal seeks to apply that framework to issuers under its supervision, including rules for reserves, redemptions, custody, and reporting.

The OCC proposal says stablecoin issuers must hold reserve assets that are diverse enough to manage credit, liquidity, interest rate, and price risks. It also says issuers should not rely too much on one financial institution or a small group of custodians.

BlackRock also asked the OCC to expand eligible reserve assets. Reports said the firm wants clarity that Treasury exchange-traded funds can qualify as stablecoin reserves when they meet safety and liquidity standards.

The OCC draft already lists several reserve assets. These include U.S. cash, Federal Reserve balances, demand deposits, Treasury bills, Treasury notes, Treasury bonds with 93 days or less to maturity, repo assets, reverse repo assets, and certain government money market funds.

The draft also allows some approved reserves in tokenized form. However, it asks whether the OCC should limit tokenized reserves to a set percentage, including a possible 20% cap.

BUIDL use grows in crypto markets

The comment letter comes as BlackRock’s tokenized Treasury fund, BUIDL, gains wider use in crypto market infrastructure. OKX recently added BUIDL to its institutional collateral system with Standard Chartered.

Eligible institutional and VIP clients can use BUIDL as trading margin. Standard Chartered will hold the collateral off-exchange, while OKX handles margining and liquidation.

BUIDL invests in cash, U.S. Treasury bills, and repurchase agreements. Crypto.news reported that clients keep ownership of the fund and its yield while using it inside OKX’s margin system.