BlockBeats news, on May 3, BlackRock submitted a comment letter to the U.S. Office of the Comptroller of the Currency (OCC), opposing several reserve asset restrictions proposed by the agency in implementing the draft rules of the GENIUS Act. This 17-page response was submitted on the final day of the OCC’s 60-day comment period, which began on March 2 when the draft was published in the Federal Register. The regulator posed over 200 questions covering aspects such as reserve composition, capital requirements, custody, and the earnings prohibition.
BlackRock’s feedback primarily focuses on regulations concerning "Permitted Payment Stablecoin Issuers" (PPSIs)—federally chartered entities authorized to issue stable coins following legislation signed by Trump in July last year. Their core request is that the OCC should not impose a cap on the amount of tokenized reserve assets. Previously, regulators had proposed a potential 20% cap. BlackRock argues that such restrictions are "irrelevant" to the OCC’s regulatory objectives, noting that risk levels depend on the credit quality, duration, and liquidity of the assets, "not whether those assets are held or transferred via a distributed ledger."
This stance is also closely tied to BlackRock’s positioning in the tokenization space. Its BUIDL fund is one of the largest tokenized U.S. Treasury products, with assets under management nearing $2.6 billion according to RWA.xyz, and it provides over 90% of the reserve backing for Ethena’s USDtb and Jupiter’s JupUSD on Solana. Meanwhile, Circle’s USYC currently leads the industry with approximately $2.9 billion in assets under management.