BlackRock Challenges OCC's 20% Tokenized Reserve Cap
BlackRock submitted a formal comment letter to the Office of the Comptroller of the Currency (OCC) opposing a proposed 20% cap on tokenized assets held in stablecoin reserves. A stablecoin is a digital currency designed to maintain a fixed value, usually pegged to the US dollar. Its reserve is the pool of assets that backs that fixed value. The OCC is the US federal agency that supervises national banks and sets rules for financial products including stablecoins.
Cap is part of GENIUS Act draft rulesThe OCC published its proposed rule on 25 February 2026 as part of implementing the GENIUS Act, a US law that establishes a regulatory framework for stablecoin issuers. The rule targets Permitted Payment Stablecoin Issuers (PPSIs) and includes over 200 questions for public comment. The 20% figure is one specific option the OCC raised for limiting how much of a stablecoin reserve can be held in tokenized form.
BlackRock argues risk depends on asset qualityIn its 17-page letter, BlackRock argued that a fixed percentage threshold does not reflect how financial risk works. The firm stated that an asset's risk profile depends on its credit quality, maturity, and liquidity — not on whether it is held on a blockchain. Credit quality measures the likelihood that a borrower repays a debt. Maturity refers to the length of time until an asset's value is returned. Liquidity describes how quickly an asset can be sold without losing value.
BUIDL fund backs major stablecoin reserve structuresBlackRock's BUIDL fund, valued at $2.6 billion as of May 2026, holds 90% of the reserves backing Ethena's USDtb stablecoin and over 90% of the reserves backing Jupiter's JupUSD stablecoin on the Solana blockchain. BlackRock cited this reserve role directly in its objection to the proposed cap. A hard limit on tokenized reserves would force these stablecoin issuers to replace BUIDL with other asset types to remain compliant.
Comment period follows public rulemaking processBlackRock's letter was submitted to OCC Docket ID OCC-2025-0372 during the formal public comment period for the GENIUS Act notice of proposed rulemaking (NPRM). Other institutions, including Anchorage Digital and joint trade groups, also filed comment letters during the same period. The OCC will review all submissions before issuing a final rule. No final rule has been published as of the date of this article. The OCC published its proposed rule on 25 February 2026 as part of implementing the GENIUS Act, a US law that establishes a regulatory framework for stablecoin issuers. The rule targets Permitted Payment Stablecoin Issuers (PPSIs) and includes over 200 questions for public comment. The 20% figure is one specific option the OCC raised for limiting how much of a stablecoin reserve can be held in tokenized form.
BlackRock argues risk depends on asset qualityIn its 17-page letter, BlackRock argued that a fixed percentage threshold does not reflect how financial risk works. The firm stated that an asset's risk profile depends on its credit quality, maturity, and liquidity — not on whether it is held on a blockchain. Credit quality measures the likelihood that a borrower repays a debt. Maturity refers to the length of time until an asset's value is returned. Liquidity describes how quickly an asset can be sold without losing value.
BUIDL fund backs major stablecoin reserve structuresBlackRock's BUIDL fund, valued at $2.6 billion as of May 2026, holds 90% of the reserves backing Ethena's USDtb stablecoin and over 90% of the reserves backing Jupiter's JupUSD stablecoin on the Solana blockchain. BlackRock cited this reserve role directly in its objection to the proposed cap. A hard limit on tokenized reserves would force these stablecoin issuers to replace BUIDL with other asset types to remain compliant.
Comment period follows public rulemaking processBlackRock's letter was submitted to OCC Docket ID OCC-2025-0372 during the formal public comment period for the GENIUS Act notice of proposed rulemaking (NPRM). Other institutions, including Anchorage Digital and joint trade groups, also filed comment letters during the same period. The OCC will review all submissions before issuing a final rule. No final rule has been published as of the date of this article. In its 17-page letter, BlackRock argued that a fixed percentage threshold does not reflect how financial risk works. The firm stated that an asset's risk profile depends on its credit quality, maturity, and liquidity — not on whether it is held on a blockchain. Credit quality measures the likelihood that a borrower repays a debt. Maturity refers to the length of time until an asset's value is returned. Liquidity describes how quickly an asset can be sold without losing value.
BUIDL fund backs major stablecoin reserve structuresBlackRock's BUIDL fund, valued at $2.6 billion as of May 2026, holds 90% of the reserves backing Ethena's USDtb stablecoin and over 90% of the reserves backing Jupiter's JupUSD stablecoin on the Solana blockchain. BlackRock cited this reserve role directly in its objection to the proposed cap. A hard limit on tokenized reserves would force these stablecoin issuers to replace BUIDL with other asset types to remain compliant.
Comment period follows public rulemaking processBlackRock's letter was submitted to OCC Docket ID OCC-2025-0372 during the formal public comment period for the GENIUS Act notice of proposed rulemaking (NPRM). Other institutions, including Anchorage Digital and joint trade groups, also filed comment letters during the same period. The OCC will review all submissions before issuing a final rule. No final rule has been published as of the date of this article. BlackRock's BUIDL fund, valued at $2.6 billion as of May 2026, holds 90% of the reserves backing Ethena's USDtb stablecoin and over 90% of the reserves backing Jupiter's JupUSD stablecoin on the Solana blockchain. BlackRock cited this reserve role directly in its objection to the proposed cap. A hard limit on tokenized reserves would force these stablecoin issuers to replace BUIDL with other asset types to remain compliant.
Comment period follows public rulemaking processBlackRock's letter was submitted to OCC Docket ID OCC-2025-0372 during the formal public comment period for the GENIUS Act notice of proposed rulemaking (NPRM). Other institutions, including Anchorage Digital and joint trade groups, also filed comment letters during the same period. The OCC will review all submissions before issuing a final rule. No final rule has been published as of the date of this article. BlackRock's letter was submitted to OCC Docket ID OCC-2025-0372 during the formal public comment period for the GENIUS Act notice of proposed rulemaking (NPRM). Other institutions, including Anchorage Digital and joint trade groups, also filed comment letters during the same period. The OCC will review all submissions before issuing a final rule. No final rule has been published as of the date of this article. Cryptocurrencies are highly volatile and involve significant risk. You may lose part or all of your investment. All information on Coinpaprika is provided for informational purposes only and does not constitute financial or investment advice. Always conduct your own research (DYOR) and consult a qualified financial advisor before making investment decisions. Coinpaprika is not liable for any losses resulting from the use of this information.