BlackRock urges tokenized stablecoin reserve flexibility

TLDR

BlackRock is asking US bank regulators to ease proposed limits on how much stablecoin reserves can sit in tokenized assets like onchain Treasury funds.

1. BlackRocks OCC comment letter opposes a suggested 20% cap on tokenized reserve assets and pushes for risk based criteria instead of blanket limits.
2. The change would favor tokenized Treasuries such as BlackRocks BUIDL fund, which already backs major onchain dollars and is used as collateral on OKX.
3. The final GENIUS Act rule set, expected before a 2027 compliance date, will decide how deeply tokenized RWAs can plug into regulated stablecoins.

Deep Dive

1. What BlackRock Is Asking For

BlackRock submitted a 17 page comment letter to the Office of the Comptroller of the Currency (OCC) on its draft GENIUS Act rules for payment stablecoin issuers.

The firm argues that a possible 20% cap on tokenized reserve assets is extraneous and that risk should be judged by credit quality, duration and liquidity, not whether reserves sit on a distributed ledger.

BlackRock also asks the OCC to explicitly allow Treasury ETFs that hold only eligible assets, and to broaden the list of qualifying reserves, including some floating rate Treasury notes, under a more principles based diversification framework.

2. Why This Matters For Stablecoins And RWAs

BlackRocks USD Institutional Digital Liquidity Fund (BUIDL), a tokenized short term Treasury fund, has grown to roughly the mid single billions of dollars and reportedly backs over 90% of reserves for stablecoin like products such as USDtb and JupUSD.

A hard cap on tokenized reserves would directly constrain how much stablecoin supply can be backed by instruments like BUIDL, even if the underlying assets are the same Treasuries regulators already accept.

At the same time, the tokenized real world asset market has surged over 420% to about 30.2 billion dollars, led by tokenized US Treasuries, according to a recent RWA market analysis.

3. What To Watch In Rulemaking

The GENIUS Act, which created a federal framework for payment stablecoins, is being implemented through OCC rules that must be finalized ahead of a January 2027 compliance date.

Bank trade groups are already pushing to slow or reshape related rulemakings, while firms like BlackRock lobby to ensure tokenized funds are not treated as second class reserves.

Watch three signals: the OCCs final decision on any tokenization cap, how broadly it defines eligible ETFs and money market funds, and whether other regulators align with that stance.

Conclusion

BlackRock is trying to steer US stablecoin rules toward substance over form, so that Treasuries on chain count the same as Treasuries in a bank account. The eventual GENIUS Act rulebook will shape whether tokenized funds like BUIDL become core infrastructure for regulated stablecoins or stay capped on the sidelines.