BlackRock filed a 17-page remark letter asking the Workplace of the Comptroller of the Forex (OCC) to scrap a proposed 20% cap on tokenized reserve belongings in its draft guidelines for the GENIUS Act.
The world’s largest asset supervisor submitted the submitting on the ultimate day of the company’s 60-day remark window, which opened when the OCC’s proposal was revealed within the Federal Register on March 2.
Why a Tokenized Reserve Cap Threatens BUIDL
BlackRock known as the proposed cap “extraneous” to the company’s goals in its letter, filed within the public docket.
The agency argued that reserve danger depends upon credit score high quality, length, and liquidity. It doesn’t matter whether or not an asset strikes on a distributed ledger.
That place carries industrial weight. The agency’s BUIDL fund holds practically $2.6 billion in belongings, in accordance with RWA.xyz information.
It provides greater than 90% of the reserves behind Ethena’s USDtb and Jupiter’s JupUSD on Solana.
“[The limit is] extraneous [to the OCC’s objectives…risk profiles are driven by credit quality, duration, and liquidity]…not whether or not the asset is held or transferred on a distributed ledger,” learn an excerpt within the remark letter.
A 20% ceiling would prohibit how aggressively BUIDL can scale inside permitted fee stablecoin issuer reserves.
Circle’s USYC at the moment leads the tokenized subject with $2.9 billion in belongings beneath administration.
Different Asks within the Letter
The agency pressed the OCC to substantiate that ETFs qualify as reserves beneath Part 4 of the legislation. The remedy would lengthen to Treasury ETFs invested solely in eligible belongings.
It additionally urged the company so as to add two-year US Treasury floating-rate notes to the eligible asset record. The notes carry weekly coupon resets and restricted worth volatility.
Roland Villacorta and Benjamin Tecmire signed the letter on behalf of BlackRock. The Brookings Establishment filed individually Friday, urging increased capital expenses on uninsured deposits held as reserves.
The 376-page proposal sits alongside parallel rulemakings from the FDIC, Treasury, FinCEN, and OFAC. All face a January 2027 compliance deadline.
How the OCC handles tokenization will form how rapidly BUIDL turns into a fixture in bank-issued stablecoin reserves.
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