BlackRock opposes OCC cap on tokenized reserves

TLDR

BlackRock is pushing US bank regulators not to limit how much of stablecoin reserves can sit in tokenized assets like onchain Treasury funds.

1. BlackRock asked the OCC to drop a proposed 20% cap on tokenized reserve assets in rules implementing the GENIUS Act.
2. The firm argues that caps would constrain tokenized Treasury funds such as BUIDL, which already back major stablecoins and DeFi collateral.
3. The OCCs final decision, due before a 2027 deadline, will shape how quickly tokenized Treasuries and bank regulated stablecoins can scale.

Deep Dive

1. What BlackRock Is Opposing

Under the GENIUS Act stablecoin framework, the Office of the Comptroller of the Currency (OCC) proposed reserve rules for permitted payment stablecoin issuers that include an optional cap, discussed around 20 percent, on reserves held in tokenized form.

BlackRock filed a 17 page comment letter asking the OCC to remove this cap, calling it extraneous and arguing that reserve risk depends on credit quality, maturity and liquidity, not whether the asset sits on a distributed ledger. This pushback is described in detail in a CoinsKid community summary and a Yahoo overview.

The OCC draft already allows reserves in cash, Fed balances, short dated Treasuries, repos and certain government money market funds, some of which can be tokenized, but it explicitly asks whether a percentage limit on tokenized holdings is needed for safety.

2. Why Tokenized Treasuries And Stablecoins Care

BlackRocks tokenized US Treasury fund BUIDL holds about 2.5 to 2.6 billion dollars and already supplies more than 90 percent of the reserves behind Ethenas USDtb and Jupiters JupUSD on Solana, while Circles USYC tokenized Treasury fund leads the segment with roughly 2.9 billion dollars in assets. These relationships are highlighted in the Yahoo piece.

BUIDL is simultaneously being integrated into market infrastructure as yield bearing collateral on OKX in partnership with Standard Chartered, allowing institutions to post tokenized Treasuries as margin without giving up yield, as described in coverage of the OKX framework.

Separately, the tokenized real world asset market has grown more than 420 percent since early 2025, from 5.8 billion dollars to over 30.2 billion, with tokenized Treasuries rising from 3.9 billion to more than 15 billion, according to RWA market data. A strict cap would directly limit how much of these instruments can sit inside bank regulated stablecoin reserves.

3. Timeline, Scenarios And Risks

The OCC proposal is part of a wider GENIUS Act rulemaking package that also involves Treasury, FDIC, FinCEN and OFAC, all working toward a January 2027 compliance date, as noted in the regulatory coverage. Over 200 industry comment letters are under review, including critical submissions from DeFi players such as Phantom and Consensys on related yield rules.

Three broad outcomes are plausible.

1. The OCC keeps a hard percentage cap, which would limit how central tokenized funds can become in bank stablecoin reserves.
2. It drops the cap but tightens qualitative risk and diversification tests, close to BlackRocks preferred principles based approach.
3. It delays or reworks the rule if pressure from banks and crypto firms leads to further consultation, slowing stablecoin standardization.

Conclusion

BlackRocks opposition is less about one fund and more about whether regulators treat tokenized Treasuries as equivalent to their traditional counterparts inside bank supervised stablecoins.

If the OCC ultimately avoids a strict cap and clarifies that compliant tokenized Treasuries and ETFs qualify fully as reserves, tokenized RWAs could move from niche collateral to core infrastructure for dollar liquidity in crypto markets.