In a recent move, BlackRock has called on the Office of the Comptroller of the Currency to reconsider certain aspects of the proposed GENIUS Act regulations. The financial giant is pushing for the removal of a suggested limit on tokenized reserve assets that stablecoin issuers can hold. Instead, BlackRock advocates for a risk-based approach, where the safety of reserves is determined by factors such as liquidity, credit quality, and maturity, rather than the technology used to represent them.
The GENIUS Act, enacted in mid-2025, established a federal framework for payment stablecoins. The OCC’s draft proposal aims to implement this framework for issuers it oversees, outlining requirements for reserves, redemptions, custody, and reporting. Specifically, it mandates that stablecoin issuers maintain diversified reserve assets to mitigate credit, liquidity, interest rate, and price risks, and avoid over-reliance on a single financial institution or custodian.
BlackRock’s comment letter argues that treating tokenized assets differently from their traditional counterparts is unwarranted. The asset manager also seeks clarity on whether Treasury exchange-traded funds that meet safety and liquidity standards can qualify as eligible stablecoin reserves. The OCC’s current list of eligible assets includes cash, Federal Reserve balances, demand deposits, Treasury bills, notes, and bonds with short maturities, as well as certain repo and money market instruments. The draft leaves open the possibility of a 20% cap on tokenized reserves, a limit BlackRock firmly opposes.
This push comes as BlackRock’s tokenized Treasury fund, BUIDL, gains traction in crypto markets. Recently, OKX integrated BUIDL into its institutional collateral system in partnership with Standard Chartered. Eligible clients can use BUIDL as trading margin, with Standard Chartered holding the collateral off-exchange while OKX manages margining and liquidation. BUIDL invests in cash, U.S. Treasury bills, and repurchase agreements, allowing clients to retain ownership and yield while leveraging it within OKX’s margin system.