BlackRock urges OCC to scrap 20% cap on tokenized reserves

BlackRock filed a 17-page comment with the Office of the Comptroller of the Currency on the final day of the agency’s 60-day public comment period. The period began when the OCC published draft rules for the GENIUS Act in the Federal Register on March 2.

The letter called the proposed 20% cap extraneous to the OCC’s objectives and argued that reserve risk should be assessed by credit quality, duration and liquidity rather than by whether an asset is recorded or transferred on a distributed ledger.

BlackRock’s BUIDL fund holds nearly $2.6 billion and supplies more than 90% of the reserves behind Ethena’s USDtb and Jupiter’s JupUSD on the Solana blockchain. The filing warned a 20% ceiling would limit how quickly BUIDL can scale in permitted payment stablecoin issuer reserves and could constrain banks’ use of tokenized assets in stablecoin reserves.

The firm also asked the OCC to confirm that exchange-traded funds qualify as reserves under Section 4 of the proposed rules, which would cover Treasury ETFs invested solely in eligible assets. BlackRock urged adding two-year U.S. Treasury floating-rate notes to the list of eligible assets, noting those notes carry weekly coupon resets and limited price volatility.

The comment was signed by Roland Villacorta and Benjamin Tecmire. It joined other responses to the OCC’s 376-page proposal; the Brookings Institution filed separately on the final comment day, urging higher capital charges on uninsured deposits held as reserves.

The OCC proposal sits alongside parallel rulemakings from the FDIC, the Treasury Department, FinCEN and OFAC. Agencies set a January 2027 compliance deadline for the rules.