BlackRock has formally opposed the Office of the Comptroller of the Currency's (OCC) proposed 20% cap on tokenized reserve assets in the GENIUS Act draft rules. In a 17-page comment letter submitted on the final day of the comment period, BlackRock argued that the cap is unnecessary and does not align with the OCC's objectives. The asset manager emphasized that reserve risk is determined by credit quality, duration, and liquidity, rather than the use of distributed ledger technology. The firm highlighted that the proposed cap could limit the scalability of its BUIDL fund, which holds nearly $2.6 billion in assets and supports major stablecoins like Ethena’s USDtb and Jupiter’s JupUSD. BlackRock also requested that the OCC recognize ETFs as reserves under the law and include two-year US Treasury floating-rate notes as eligible assets. The outcome of the OCC's decision on tokenization will significantly impact the integration of BUIDL into bank-issued stablecoin reserves.