The world's largest asset manager, BlackRock, has formally requested that the Office of the Comptroller of the Currency (OCC) eliminate a proposed 20% cap on tokenized reserve assets under the GENIUS Act. In a detailed 17-page response submitted on the final day of the public comment window, BlackRock argued that the risk of reserve assets depends on quality and liquidity, not the method of issuance.
The GENIUS Act and the Proposed 20% Cap
The GENIUS Act, signed into law by President Trump last year, is designed to establish a federal regulatory framework for stablecoins in the United States. As part of this process, the OCC published its proposed rulebook on March 2, 2026, opening a 60-day period for public feedback. A central component of the proposal is a 20% limit on tokenized reserves, meaning that for every $1 billion in reserves, only $200 million can be held in tokenized assets, with the remainder in traditional forms like cash or Treasury bills.
BlackRock's Core Argument
BlackRock’s submission opposes this cap as unnecessary and potentially detrimental to innovation. The firm contends that the risk profile of a reserve asset is determined by factors such as credit quality, liquidity, and duration—not by whether it is tokenized on a blockchain. According to BlackRock, applying a blanket percentage cap fails to account for the quality of individual tokenized assets and could restrict the growth of safe and efficient products.
The BUIDL Fund at the Center of the Debate
A key motivation behind BlackRock’s push is its tokenized Treasury fund, BUIDL, which currently holds approximately $2.6 billion in assets. This fund supports stablecoins like USDtb. A 20% cap would limit how much BUIDL and similar tokenized assets can be used as reserves, potentially slowing adoption even for high-quality, liquid assets. The tokenized real-world asset (RWA) market is currently valued at around $27.65 billion, with projections suggesting it could reach $16 trillion by 2030.
Additional Requests and Opposing Views
Beyond removing the cap, BlackRock has asked regulators to allow Treasury ETFs and two-year U.S. Treasury floating-rate notes to qualify as eligible reserve assets. Meanwhile, the Brookings Institution submitted a response on the same day, urging stricter safety rules for reserves—a position directly opposing BlackRock’s. The OCC’s final decision, expected before the GENIUS Act’s implementation deadline in January 2027, will be crucial for the future of both stablecoins and tokenized assets.
