The biggest player in global finance has stepped onto the scene with a move that could change the fate of stablecoin regulation. BlackRock, in a comprehensive 17-page commentary letter submitted to the U.S. Office of the Comptroller of the Currency (OCC), requested the complete removal of the proposed 20% cap on tokenized reserve assets under the GENIUS Act. This development is not merely a company's reflex to protect its own product; it represents one of the strongest corporate battles yet for the integration of tokenized real-world assets (RWAs) into the backbone of the financial system.

✨ The OCC's 376-Page Proposal and the Anatomy of the 20% Cap

🔹Remember: The GENIUS Act, signed into law by President Trump on July 18, 2025, created the first federal regulatory framework for payment stablecoins. The law, which passed the Senate with an overwhelming majority of 68 to 30 and the House of Representatives with a majority of 308 to 122, restricts stablecoin issuance to federally licensed entities called "Licensed Payment Stablecoin Issuers" (PPSIs).

🔹On February 25, 2026, the OCC published a 376-page draft rule for the implementation of this law. The draft was published in the Federal Register on March 2, initiating a 60-day public comment period. One of the most controversial provisions of this draft, which was shaped by more than 200 questions, was the imposition of a 20% cap on tokenized assets that PPSIs could hold in their reserves.

🔹On Friday, May 2, the last day of this 60-day period, BlackRock submitted a 17-page comment letter to the OCC's public filing.

✨ BlackRock's Key Argument: Risk Lies in the Asset Itself, Not the Blockchain

🔹The most striking statement in BlackRock's letter is its clear assertion that the proposed 20% limit is "extraneous" from the perspective of the OCC's regulatory objectives.

🔹The firm's argument rests on the premise that a reserve asset's risk profile is determined by fundamental financial metrics such as credit quality, maturity, and liquidity. Whether or not the asset is held on a distributed ledger does not change the level of risk. As BlackRock states in the letter: "Risk profiles depend on credit quality, maturity, and liquidity, not on whether the asset is held on a distributed ledger or transferred."

🔹This stance actually advocates a deeper principle: Regulations should target risk, not technology. Whether a Treasury bond is held on traditional ledgers or on a blockchain, it carries the same credit risk. Therefore, the regulatory framework should also be the same.

✨ The BUIDL Factor: A $2.6 Billion Tokenized Treasury Fund

🔹To understand why BlackRock is fighting this battle so fiercely, just look at the size of the BUIDL fund. According to RWA data, BlackRock's BUIDL tokenized Treasury fund has reached approximately $2.6 billion in assets.

🔹Even more critical is the fund's strategic position in the stablecoin ecosystem:

· It provides over 90% of the reserves for Ethereum's USDtb stablecoin.
· It covers over 90% of the reserves for Solana-based Jupiter's JupUSD.

🔹A 20% cap represents a bottleneck that will directly limit the scaling capacity of federal stablecoin issuers' reserves. Circle’s USYC currently leads the tokenized Treasury space with $2.9 billion in assets, and the regulatory framework will be a determining factor in this competition.

🔹Another indication of BlackRock’s commitment in this area was the transformation of its Select Treasury Based Liquidity Fund (BSTBL) into a GENIUS Act compliant product last October, specifically designed to serve stablecoin reserves.

✨Other Critical Demands in the Letter

🔹BlackRock’s demands to the OCC are not limited to the removal of the 20% limit. Other key points highlighted in the letter include:

🔹Recognition of ETFs as Reserve Assets: BlackRock requests clarification on whether Treasury ETFs that invest only in eligible reserve assets qualify as reserve assets under Section 4 of the GENIUS Act. It also argues that these ETFs should receive the same quantitative safe-haven treatment as government money market funds.

🔹 🔹Two-Year Variable Rate Treasury Bonds: Due to their weekly coupon reset feature and limited price volatility, BlackRock recommends adding U.S. Treasury variable rate bonds with maturities of up to two years to the list of eligible reserve assets.

🔹Support and Revision of Option A: BlackRock supports Option A, one of the two options offered by the OCC for reserve diversification, which combines a principle-based standard with optional quantitative safe haven. In contrast, it notes that Option B, which imposes strict daily requirements such as a 40% single-institution concentration limit and a 20-day weighted average maturity cap, lacks flexibility.

🔹More Transparent Approval Process: BlackRock requests the establishment of a formal and transparent evaluation process for new instruments to be added to the list of eligible reserve assets in the future.

✨ The Critical Timeline and Simultaneous Rule-Making Process of the GENIUS Act

🔹The implementation timeline for the GENIUS Act is rapidly advancing. Under the Act, regulators such as the OCC, FDIC, Treasury (FinCEN and OFAC), and the Federal Reserve are required to publish their final implementing regulations by July 18, 2026. The effective date of the Act is set as January 18, 2027, or 120 days after the publication of the final regulations.

🔹There has been a noticeable intensification of regulatory activity in the last two months. On April 8, FinCEN and OFAC published a joint rule proposal incorporating PPSIs into their anti-money laundering and enforcement compliance framework. In April, the FDIC submitted two separate rule proposals covering both licensing and reporting and auditing standards.

🔹This multi-layered regulatory architecture will determine the future structure of the stablecoin market. BlackRock's letter is at the very heart of this critical shaping process.

✨ Global Expansion of BUIDL: Exchance and Standard Chartered Partnership

🔹BlackRock’s aggressive defense of OCC parallels the momentum BUIDL is gaining globally. Announced on April 29th, the partnership between Exchance, BlackRock, and Standard Chartered is the first global systemically important bank (G-SIB) participating framework to integrate BUIDL into institutional collateral workflows.

🔹Under this framework, Exchance VIP and institutional clients can hold BUIDL as over-the-counter collateral in Standard Chartered’s regulated custody service while simultaneously trading on Exchance. BUIDL can also be used as on-exchange collateral providing yield.

🔹As BlackRock Global Head of Market Development Samara Cohen stated: “BUIDL is designed to bring the benefits of tokenizing short-term Treasury risk to qualified investors on blockchain rails.”

✨ Significance and Potential Outcomes for the Markets

🔹How the OCC responds to BlackRock's request is one of the most critical variables determining the future of the tokenized RWA market. If the request is accepted:

🔹First Outcome: Tokenized funds like BUIDL could become a standard component in the reserve structure of stablecoins issued by banks. This could trigger explosive growth in the tokenized Treasury market.

🔹Second Outcome: The adoption of BlackRock's principle-based approach could set a precedent for future regulations to "target risk, not technology."

🔹Third Outcome: Recognizing ETFs as reserve assets could lead to a shift in the stablecoin reserve composition from sovereign money market funds to ETFs.

🔹On the other hand, in a scenario where the 20% limit is maintained, the role of tokenized assets in stablecoin reserves will remain a limited complement, and products like BUIDL will have to seek alternative growth paths.

🔹The decision-making process is expected to become clearer in the coming months. For now, the only thing known is that the world's largest asset manager will not quietly accept this challenge.


✨ Regulation is wise not when it shackles technology, but when it truly recognizes the risk. Smart capital thrives on rules that understand, not prohibit.

⚠️Don't forget to mark stop-loss and manage risk properly.
👉NFA
👉 DYOR

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