BlackRock Opposes 20% Cap on Tokenized Reserve Assets in GENIUS Act Comment Letter

BlackRock, the world's largest asset manager, submitted a comment letter to the Office of the Comptroller of the Currency opposing a potential 20% cap on tokenized reserve assets under the proposed GENIUS Act. The cap would directly limit BlackRock's BUIDL fund and similar tokenized financial products. In its letter, BlackRock urged the OCC to eliminate the proposed cap and instead expand the range of eligible assets that can be tokenized. The dispute highlights tensions between traditional financial institutions seeking to innovate with blockchain technology and regulators attempting to establish guardrails for emerging digital asset products.

BlackRock's Opposition to the 20% Tokenized Reserve Cap

• ▪BlackRock opposed a potential 20% cap on tokenized reserve assets in a comment letter to the OCC regarding the GENIUS Act.
• ▪BlackRock is the world's largest asset manager.
• ▪BlackRock urged the OCC to drop the tokenized reserve cap idea in its GENIUS Act comment letter.
• ▪BlackRock urged the OCC to expand eligible assets in its GENIUS Act comment letter.

Impact on BUIDL Fund and Tokenized Asset Products

• ▪BlackRock operates a tokenized asset product called the BUIDL fund.
• ▪The potential 20% cap on tokenized reserve assets would limit products like BlackRock's BUIDL fund.

Perspective of BlackRock

• ▪BlackRock advocates for expanding the range of eligible assets that can be tokenized under the GENIUS Act framework.
• ▪BlackRock believes the proposed 20% cap on tokenized reserve assets in the GENIUS Act would unnecessarily restrict tokenized financial products.

Perspective of Office of the Comptroller of the Currency

• ▪The Office of the Comptroller of the Currency is evaluating a 20% cap on tokenized reserve assets as part of GENIUS Act implementation.

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