BlackRock backs GENIUS Act, seeks wider reserve rules
BlackRock told the U.S. OCC it supports the GENIUS Act payment stablecoin framework and urged wider reserve eligibility, removal of a 20% tokenized cap and ETF parity.
BlackRock filed a comment letter with the U.S. Office of the Comptroller of the Currency on May 7 endorsing the OCC’s GENIUS Act framework for permitted payment stablecoin issuers and proposing seven specific changes to the draft rule. The OCC published the proposal on March 2.
The firm said it prefers the agency’s “Option A,” a principles-based approach paired with an optional quantitative safe harbor. The OCC described the safe harbor with 10% daily and 30% weekly liquidity thresholds, a 40% concentration limit and a 20-day weighted average maturity cap.
In the letter, BlackRock asked the OCC to allow same-day settling government money market funds to count toward the weekly liquidity floor, citing the size of that market and its use in institutional cash management. The firm noted more than $6.2 trillion in such funds under management as context for the recommendation.
BlackRock also urged regulators to treat qualifying exchange-traded funds the same as other cash-equivalent instruments and to drop a proposed 20% cap on tokenized forms of eligible reserves. The firm argued a cap based on tokenization would focus on an asset’s form rather than its underlying risk profile.
The letter requested explicit inclusion of U.S. Treasury Floating Rate Notes with maturities up to two years as eligible reserve assets and asked that separately managed accounts remain available for professional reserve management. Robert Mitchnick, BlackRock’s head of digital assets, was one of five executives who signed the submission.
BlackRock included a social post attached to the filing that said, “With the right regulatory framework in place, stablecoins can improve the payments system and drive new forms of financial utility, including real-time settlement.” The firm described the optional safe harbor as a workable path to compliance while keeping a principles-based regime for firms that prefer it.
The OCC proposal sets standards for reserve assets, diversification, concentration, capital and supervision for permitted payment stablecoin issuers. The agency opened a formal comment period that allows asset managers and other market participants to offer feedback before final rules are adopted.
BlackRock’s recommendations focus on reserve composition, liquidity treatment and the regulatory status of tokenized assets as regulators consider final standards for payment stablecoin issuers.



