The world’s largest asset manager, BlackRock, has submitted a detailed 17-page formal response to the Office of the Comptroller of the Currency (OCC) asking regulators to drop a 20% proposed limit on tokenized reserves.
The request comes as part of ongoing rulemaking under the GENIUS Act, a new U.S. law designed to regulate stablecoins.
Why BlackRock Opposes the 20% Limit
Last year, President Trump signed the GENIUS Act, which was designed to bring federal structure and clear rules to the stablecoin industry in the United States.
The OCC is one of several agencies responsible for writing the detailed rulebook. Its proposed rulebook was published on March 2, 2026, opening a 60-day window for businesses, institutions, and the public to share their thoughts.
One key rule suggests a 20% limit on tokenized reserves. This means if a company has $1 billion, only $200 million can be in tokenized assets, while the rest must stay in traditional forms like cash or Treasury bills.
BlackRock submitted its letter on the very last day of that window.
According to BlackRock, the proposed 20% cap is unnecessary and could slow down innovation. The firm argues that risk in reserve assets depends on factors like credit quality, liquidity, and duration, not whether the asset is tokenized on a blockchain.
BlackRock’s BUIDL Fund at the Center of the
A key reason behind BlackRock’s push is its tokenized Treasury fund, known as BUIDL. Meanwhile, the fund holds about $2.6 billion and helps support stablecoins like USDtb.
BlackRock says that, if the 20% cap is applied, it could limit how much tokenized assets like BUIDL can be used in reserves, slowing their growth even if the assets are safe.
As of now, around $27.65 billion in real-world assets are already tokenized. Experts believe this market could grow to $16 trillion by 2030, but strict rules like this could slow that growth.
Other Key Requests BlackRock Asked For
Along with removing the cap, BlackRock has also asked regulators to:
- Allow Treasury ETFs to qualify as reserve assets
- Include two-year U.S. Treasury floating-rate notes as eligible reserves
These changes aim to give more flexibility in how stablecoin reserves are structured.
BlackRock Wasn’t the Only One Responding
While BlackRock asked for fewer limits on tokenized assets, not everyone agreed.
The Brookings Institution, a well-known policy group, submitted its own response on the same day, asking the OCC to increase safety rules for reserves. This is the opposite of BlackRock’s view.
The OCC’s final decision will be important for the future of stablecoins and tokenized assets. With a deadline set for January 2027, regulators now need to balance growth and safety.
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