BlackRock is pushing back against a proposed OCC limit that could cap tokenized reserve assets at 20% of a permitted payment stablecoin issuer’s total reserves, a rule that would directly affect the growth path for its BUIDL tokenized Treasury fund.
The asset manager filed a 17-page comment letter asking the Office of the Comptroller of the Currency to remove the cap idea from draft rules implementing the GENIUS Act. The filing argues that reserve risk should be judged by credit quality, duration, liquidity, custody, and monetization capacity, not by whether an eligible asset is represented on a distributed ledger.
That argument lands inside a live rulemaking process. The OCC’s GENIUS Act proposal asks whether tokenized forms of reserve assets should be limited to a set percentage, including a possible 20% ceiling. The comment window closed on May 1, a deadline that had already turned the OCC stablecoin process into a key lobbying fight for banks, stablecoin issuers, asset managers, and crypto infrastructure firms.
Why BUIDL Is In The Middle
BUIDL sits at the center of the dispute because tokenized Treasuries have moved from a niche RWA product into reserve, collateral, and settlement infrastructure. RWA.xyz data places the BlackRock USD Institutional Digital Liquidity Fund at about $2.58 billion in total asset value, with U.S. Treasury debt as the underlying distributed asset.
Ethena’s USDtb also connects BUIDL to the stablecoin market. USDtb is backed by high-quality short-duration Treasury assets, including BlackRock’s BUIDL, while the product is designed for onchain minting, redemption, DeFi collateral use, and institutional access. If federal rules sharply restrict tokenized reserve assets, products that rely on tokenized Treasury funds may need to rebalance toward non-tokenized cash equivalents, traditional Treasury instruments, or government money market funds.
The commercial issue is scale. A 20% ceiling would not ban tokenized reserves, but it would prevent them from becoming the dominant reserve layer for federally supervised payment stablecoins. That could limit BUIDL’s role even if the underlying assets are short-duration Treasuries with daily liquidity characteristics that look similar to traditional reserve products.
Tokenized Reserves Become A Market Structure Test
The rule debate now turns on whether tokenization is treated as an added operational risk or as a wrapper around assets that should be assessed on familiar reserve principles. The OCC proposal already focuses on segregation, custody, redemption capacity, reserve monetization, concentration limits, and monthly reporting. BlackRock’s position is that those controls can address the real risks without a blunt tokenization cap.
The decision will also shape the broader RWA market. Tokenized Treasuries remain one of the most important categories in real-world assets moving onchain, and recent market growth has shown how quickly Treasuries can dominate the tokenized asset stack when institutions want yield, transparency, and programmable settlement.
BlackRock also wants the OCC to clarify that Treasury ETFs invested solely in eligible reserve assets can qualify as reserves, and it has pushed for two-year U.S. Treasury floating-rate notes to be included because of their weekly coupon resets and lower price sensitivity. Those requests point to the same theme: stablecoin reserve rules will decide whether the next phase of tokenized finance is built around flexible institutional cash products or narrower, bank-style reserve boxes.
The final rule will determine whether BUIDL can keep expanding as a reserve building block for regulated stablecoins, or whether tokenized Treasury funds remain a capped side sleeve inside a much more traditional reserve framework.
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