BlackRock formally opposed the Workplace of the Comptroller of the Foreign money’s draft guidelines for the $GENIUS Act, arguing that proposed limits on reserve property are pointless.
On Friday, the asset administration firm submitted a 17-page remark letter addressing the OCC’s 20% cap on tokenized property. It argues that the proposal would choke its BUIDL fund and comparable improvements. The agency’s letter additionally sought formal clarification on which Treasury-based devices can be thought of eligible reserves.
As an alternative of inflexible limits, BlackRock is advocating a principles-based diversification framework. This proposal permits issuers to handle reserves primarily based on threat traits slightly than arbitrary thresholds.
What does BlackRock want the OCC to implement?
In its letter to the OCC, BlackRock largely targeted on guidelines for permitted fee stablecoin issuers (PPSIs), the very group of federal stablecoin issuers. One in all BlackRock’s largest requests to the company was to scrap the proposed 20% restrict on tokenized reserves.
It characterised the restriction as utterly unrelated to the OCC’s objectives, and likewise defined that the true dangers of a reserve asset aren’t essentially about it being “tokenized” however about its liquidity, length, and creditworthiness.
BlackRock is a dominant drive in tokenized Treasuries; its $2.6 billion BUIDL fund presently backs 90% of the shares of each Jupiter’s JupUSD and Ethena’s USDtb. If this 20% cap goes by means of, it could materially inhibit BUIDL’s means to scale as a main backing of federal stablecoins.
A key a part of the letter additionally asks the OCC to formally verify if Treasury ETFs are qualifying property underneath the $GENIUS Act. The agency warned that, with out clearer tips, issuers received’t threat holding ETFs and thus requested that these funds obtain the identical remedy as authorities cash market funds.
Moreover, BlackRock supported the company’s Choice A method for diversifying reserves however famous that Choice B would impose strict day by day focus and maturity limits. Choice B would primarily impose day by day compliance with a 40% single-entity publicity cap and a 20-day weighted maturity restriction throughout all issuers.
The corporate additionally really useful updating Choice A to exempt self-managed cash market shares from the 40% threshold and allow same-day settlement funds to assist liquidity mandates.
It additionally proposed including Treasury floating-rate notes with shorter maturities, which mirror regular pricing and common coupon resets, to the reserve checklist, alongside a extra structured and clear asset approval course of.
BlackRock will not be the primary firm to offer commentary on the OCC’s proposal. The Brookings Establishment submitted its personal suggestions, pushing the OCC to set greater capital necessities for reserve holdings held in uninsured demand deposit accounts.
The FDIC additionally proposed a framework for stablecoin issuers
Apart from the OCC, the Federal Deposit Insurance coverage Company additionally proposed guidelines in April to ascertain a regulatory framework for stablecoin issuers consistent with the $GENIUS Act.
Chantal Hernandez, counsel on the FDIC, even famous on the time that the principles would “make clear deposit insurance coverage protection of deposits that function reserve property.”
The US Treasury, FinCEN, and OFAC additionally proposed a rule to counter the financing of terrorism (CFT) and to implement anti-money laundering (AML) measures.
Treasury Secretary Scott Bessent had famous, “This proposal will shield the US monetary system from nationwide safety threats with out hindering American firms’ means to forge forward within the fee stablecoin ecosystem.”
After the $GENIUS Act was signed into legislation in July, some firms needed to revamp their funds and methods, together with BlackRock. BlackRock redesigned its BlackRock Choose Treasury-Based mostly Liquidity Fund (BSTBL) to align with the laws and safely home stablecoin reserves.
The revamped fund now operates with a 5 p.m. ET deadline and maintains a conservative, Treasury-centric funding combine. Although with all the brand new proposals, if accredited, crypto-related firms must think about extra redesign.

