BlackRock filed a formal comment letter with the U.S. Office of the Comptroller of the Currency on May 1, 2026, endorsing the GENIUS Act’s proposed structure for payment stablecoin issuers while pressing for targeted changes to implementation. The firm supports a stablecoin regime built around high-quality liquidity and user protection, but wants the OCC to avoid rules that are too rigid for evolving reserve markets.
The submission matters because BlackRock is trying to shape how reserve composition, custody requirements and operational obligations will work for permitted payment stablecoin issuers. Its recommendations focus on expanding eligible reserve assets, preserving legal clarity and avoiding discrimination against tokenized instruments that carry the same underlying risk as traditional assets.
BlackRock Pushes for Broader Stablecoin Reserve Assets
BlackRock urged the OCC to allow exchange-traded funds and government money market funds as permissible reserve assets. The firm highlighted government money market funds as same-day settlement liquidity providers, noting that the category currently holds more than $6.2 trillion in assets.
The asset manager also recommended that issuers be allowed to hold U.S. Treasury floating-rate notes with maturities of up to two years. In BlackRock’s view, two-year Treasury FRNs can qualify as high-quality reserves because of their limited price volatility and robust secondary-market liquidity.
A central part of the letter is BlackRock’s opposition to the proposed 20% cap on tokenized reserve assets. The firm argues that a tokenized instrument should not be penalized because of its form if the underlying asset meets liquidity, credit and risk standards.
That position has direct implications for tokenized Treasury markets and products such as BlackRock’s BUIDL fund. Removing the cap, the firm argues, would support larger institutional participation in tokenized collateral markets and avoid constraining reserve structures that use blockchain-based representations of traditional assets.
Principles-Based Rules Take Priority
BlackRock also pressed the OCC to adopt a flexible, principles-based framework instead of overly prescriptive requirements. The firm said it supports a principles-based approach with a quantitative safe harbor, allowing issuers to adapt reserve management as market and technology conditions change.
Specifically, BlackRock endorsed the OCC’s “Option A,” which combines qualitative standards with an optional quantitative safe harbor. That approach would give payment stablecoin issuers a balanced route between regulatory flexibility and measurable prudence, rather than locking all firms into one fixed reserve formula.
The firm also urged regulators to preserve separately managed accounts as an option for reserve management. SMAs, in BlackRock’s framing, can provide clear legal ownership, transparency and reduced commingling risk, which are central concerns for issuers, custodians and auditors.
Operationally, the recommendations would expand the work required from custodians and asset managers. Broader reserve eligibility means firms would need stronger documentation around segregation, liquidity testing, reporting and solvency controls to demonstrate compliance under the GENIUS Act framework.
For stablecoin issuers, removing the tokenized reserve cap and widening permissible assets could materially change reserve design. The practical effect would be a larger collateral toolkit for payment stablecoins, but also more scrutiny around custody architecture, audit trails and redemption liquidity.
As implementation moves forward, BlackRock’s letter positions major asset managers to influence how the OCC translates the GENIUS Act into workable rules. The final outcome will determine how reserve eligibility, tokenization limits and segregation standards shape the next phase of regulated stablecoin issuance.