TLDR
BlackRock is urging the U.S. banking regulator OCC not to impose a hard percentage cap on tokenized assets used as stablecoin reserves.
- BlackRock asked the OCC to drop a proposed 20% limit on tokenized reserve assets under new GENIUS Act stablecoin rules.
- The firm argues tokenized Treasuries like its BUIDL fund should be treated like regular Treasuries, which could be important for bank-issued stablecoins and RWA growth.
- The OCC has not decided yet, and its final stance will shape how easily tokenized Treasuries can scale inside regulated dollar stablecoins.
Deep Dive
1. What BlackRock Is Pushing For
In a 17-page comment letter, BlackRock asked the Office of the Comptroller of the Currency to remove a potential 20% cap on tokenized reserve assets in its draft GENIUS Act rules for permitted payment stablecoin issuers.
The OCC floated the idea of limiting how much of a stablecoin's reserves can be held in tokenized form, even when the underlying is safe collateral like short-dated U.S. Treasuries. BlackRock calls that cap "extraneous" and says risk should be based on credit quality, duration, and liquidity, not whether the asset sits on a distributed ledger.
The letter also asks the OCC to confirm that Treasury ETFs and certain two-year floating-rate notes can count as eligible reserves if they meet safety and liquidity standards, as described in coverage of the comment letter and the GENIUS draft rules.
2. Why It Matters For Stablecoins And RWAs
BlackRock's tokenized Treasury fund BUIDL has about $2.6 billion in assets and reportedly supplies over 90% of reserves for Ethena's USDtb and Jupiter's JupUSD on Solana, while Circle's USYC leads the tokenized reserve market with around $2.9 billion AUM. A strict 20% cap would make it harder for BUIDL-like products to become core reserve assets for regulated issuers.
If the OCC treats tokenized Treasuries the same as traditional ones, banks issuing GENIUS-compliant stablecoins could hold a much larger share of reserves in tokenized funds that plug directly into onchain collateral systems. That would be a tailwind for real-world asset (RWA) tokenization, especially tokenized Treasuries.
The more permissive the final rule is on tokenized reserves, the easier it becomes to connect bank-grade stablecoins and onchain money markets using the same underlying Treasury collateral.
3. What To Watch Next
The OCC's draft is one piece of a broader GENIUS Act implementation, alongside other agencies and a compliance horizon around 2027, so nothing changes immediately for stablecoin users.
Key signals to watch:
- Whether the final OCC rule includes a numeric tokenization cap or keeps things principles-based.
- How explicitly the rules bless Treasury ETFs and tokenized Treasury funds as reserves.
- Follow-up moves by large banks or issuers to launch GENIUS-compliant, bank-supervised stablecoins that lean on tokenized Treasuries as collateral.
The regulatory outcome will not move prices by itself overnight, but it will largely determine whether tokenized Treasuries become a niche DeFi tool or a core building block of regulated dollar stablecoins.
Conclusion
BlackRock is trying to ensure that future U.S. bank-issued stablecoins can fully tap tokenized Treasuries and ETFs as reserves instead of being capped for purely technical reasons. How the OCC responds will shape the bridge between regulated banking balance sheets and onchain collateral, influencing the long-term growth path for stablecoins and tokenized RWA markets.
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