BlackRock has thrown its weight behind the U.S. Office of the Comptroller of the Currency's proposed GENIUS Act framework for payment stablecoin issuers, filing a comment letter that backs the agency's principles-based approach while pushing for several key changes. The world's largest asset manager submitted seven recommendations, including a request to treat same-day settling government money market funds as eligible reserves and an opposition to a proposed 20% cap on tokenized reserve assets.
Endorsing Option A
BlackRock explicitly endorsed the OCC's 'Option A,' a principles-based framework paired with an optional quantitative safe harbor. That safe harbor sets specific requirements: 10% daily liquidity, 30% weekly liquidity, 40% concentration limits, and a 20-day weighted average maturity cap on reserve assets. The firm said the approach provides enough flexibility while ensuring stability.
Counting government money market funds
One of BlackRock's main requests is to allow same-day settling government money market funds to count toward the weekly liquidity requirement. The firm pointed to over $6.2 trillion in such funds that could serve as reserves, arguing that excluding them would unnecessarily limit the pool of eligible assets. BlackRock also asked that qualifying ETFs receive equal treatment as reserve assets under the framework.
Rejecting the tokenization cap
BlackRock came out strongly against a proposed 20% cap on tokenized reserve assets, calling it a restriction that penalizes form over substance. The firm argued regulators should focus on actual risk rather than whether an asset is tokenized. Instead, BlackRock proposed adding U.S. Treasury Floating Rate Notes with maturities of up to two years as eligible reserve assets, a move that would broaden the types of securities stablecoin issuers can hold.
Professional reserve management
The asset manager also supported allowing separately managed accounts for professional reserve management under the framework. This would let stablecoin issuers use dedicated accounts managed by asset managers rather than relying on pooled funds, giving them more control over their reserve composition.
What this could mean for payments
In its letter, BlackRock stated that a proper regulatory framework could enable stablecoins to improve payment systems and enable real-time settlement. The firm's detailed recommendations show it sees stablecoins as a serious part of the financial infrastructure, not just a niche crypto product. The OCC is currently reviewing public comments on the GENIUS Act proposal, and BlackRock's input is likely to shape the final rule.
