BlackRock is pushing back against the Office of the Comptroller of the Currency’s proposed rules that would limit how much of a stablecoin issuer’s reserves can be kept in tokenized assets. The OCC’s draft framework would set a hard cap—20%—on tokenized reserve instruments, even if those assets are just tokenized versions of U.S. Treasuries or other eligible holdings.
BlackRock argues that reserve risk should be measured based on the underlying asset, not whether it’s held conventionally or in tokenized form on-chain. They made the case directly to the OCC in a 17-page comment letter, highlighting that tokenized U.S. Treasury funds like their own BUIDL product could be artificially limited under the rule.
This is a market-structure fight, not just a policy note. For tokenized Treasuries or other on-chain wrappers to scale as core reserve assets, regulators would need to treat tokenization as neutral from a prudential perspective. Beyond the tokenized asset cap, the proposal also contemplates diversification rules and a 20-day weighted average maturity cap for reserve portfolios. So even if the tokenized asset limit were dropped, issuers would still be working within a conservative framework meant to keep redemption assets safe and liquid.