Regulatory Feedback and Core Concerns
BlackRock has formally requested that the Office of the Comptroller of the Currency abandon a proposed 20 percent limit on tokenized reserve assets within its draft regulations for the GENIUS Act. The asset management giant submitted a 17-page comment letter on Friday, marking the final day of a 60-day feedback period that began on March 2. The OCC’s proposal included over 200 questions addressing reserve composition, capital requirements, custody arrangements, and restrictions on yield generation.
Central to BlackRock’s submission is its opposition to the quantitative threshold on tokenized holdings. The firm argued that restricting such assets is unnecessary for achieving the agency’s regulatory goals, emphasizing that investment risk depends on credit quality, maturity duration, and liquidity rather than the settlement mechanism. This stance carries significant weight given the firm’s current footprint in the tokenized asset space. Its BUIDL fund, which manages approximately $2.6 billion in assets according to RWA.xyz data, currently supplies more than 90 percent of the backing reserves for Ethena’s USDtb and Jupiter’s JupUSD on Solana. For industry context, Circle’s USYC product currently holds the largest market share at $2.9 billion.
Proposed Adjustments to Reserve Framework
The company also advocated for explicit regulatory clarity regarding exchange-traded funds. BlackRock urged the OCC to confirm that Treasury-focused ETFs meet the reserve criteria outlined in Section 4 of the GENIUS Act, warning that current ambiguity could discourage stablecoin issuers from utilizing them. Additionally, the firm requested that qualifying ETFs receive the same quantitative safe harbor treatment currently granted to government money market funds.
On diversification standards, BlackRock supported the OCC’s “Option A,” which combines a principles-based framework with an optional safe harbor, rather than “Option B,” which would mandate a 40 percent concentration limit per institution and cap the weighted average maturity at 20 days. The firm proposed several modifications to the safe harbor, including exempting self-custodied government money market fund shares from the concentration cap, eliminating the need to look through fund holdings to assess custodian risk, and permitting same-day-settlement government money market funds to satisfy the 30 percent weekly liquidity threshold.
Furthermore, BlackRock recommended the inclusion of U.S. Treasury floating-rate notes with maturities of up to two years, citing their minimal price volatility and weekly coupon adjustments. The letter also called for a transparent, established process to evaluate future eligible reserve assets.
Industry Context and Compliance Timeline
The submission was authored by Roland Villacorta, BlackRock’s global head of liquidity and financing, and Benjamin Tecmire, the firm’s head of U.S. regulatory affairs. This regulatory engagement aligns with BlackRock’s broader strategy to support the stablecoin ecosystem under the new federal framework, which President Trump signed into law last July. In October, the company converted its Select Treasury Based Liquidity Fund (BSTBL) into a GENIUS-compliant product featuring a 5 p.m. ET trading cutoff and a Treasury-heavy portfolio tailored for stablecoin reserves.
The OCC’s 376-page rulemaking is part of a coordinated push to meet a January 2027 compliance deadline. The FDIC released its own draft regulations in early April, while the Treasury Department, FinCEN, and OFAC have advanced separate proposals addressing state oversight, anti-money laundering protocols, and sanctions compliance. Meanwhile, other industry participants have also submitted feedback. The Brookings Institution filed a separate letter advocating for stricter capital charges on uninsured demand deposits held as stablecoin reserves.
