BlackRock Signals OCC Tokenized Reserve Cap Would Threaten BUIDL Growth

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BlackRock filed a 17-page comment letter asking the Office of the Comptroller of the Currency (OCC) to scrap a proposed 20% cap on tokenized reserve assets in its draft rules for the GENIUS Act. The world’s largest asset manager submitted the filing on the final day of the agency’s 60-day comment window, which opened when the OCC’s proposal was published in the Federal Register on March 2. Why a Tokenized Reserve Cap Threatens BUIDL BlackRock called the proposed cap “extraneous” to the agency’s objectives in its letter, filed in the public docket. The firm argued that reserve risk depends on credit quality, duration, and liquidity. It does not matter whether an asset moves on a distributed ledger. That position carries commercial weight. The firm’s BUIDL fund holds nearly $2.6 billion in assets, according to RWA.xyz data. It supplies more than 90% of the reserves behind Ethena’s USDtb and Jupiter’s JupUSD on Solana. “[The limit is] extraneous [to the OCC’s objectives…risk profiles are driven by credit quality, duration, and liquidity]…not whether the asset is held or transferred on a distributed ledger,” read an excerpt in the comment letter. A 20% ceiling would restrict how aggressively BUIDL can scale inside permitted payment stablecoin issuer reserves. Circle’s USYC currently leads the tokenized field with $2.9 billion in assets under management. Other Asks in the Letter The firm pressed the OCC to confirm that ETFs qualify as reserves under Section 4 of the law. The treatment would extend to Treasury ETFs invested solely in eligible assets. It also urged the agency to add two-year US Treasury floating-rate notes to the eligible asset list. The notes carry weekly coupon resets and limited price volatility. Roland Villacorta and Benjamin Tecmire signed the letter on behalf of BlackRock. The Brookings Institution filed separately Friday, urging higher capital charges on uninsured deposits held as reserves. The 376-page proposal sits alongside parallel rulemakings from the FDIC, Treasury, FinCEN, and OFAC. All face a January 2027 compliance deadline. How the OCC handles tokenization will shape how quickly BUIDL becomes a fixture in bank-issued stablecoin reserves.

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