BlackRock submitted a comment letter to the OCC opposing a proposed 20% cap on tokenized assets as qualifying stablecoin reserves under the GENIUS Act framework. The firm argued the cap is arbitrary, would disadvantage products like its BUIDL tokenized Treasury fund, and urged regulators to expand the list of eligible reserve assets to include a broader range of high-quality instruments. As the world's largest asset manager, BlackRock's position carries significant lobbying weight in the rulemaking process.
Armada's crypto desk holds tokenized T-Bills as a core collateral category, and regulatory limits on their use as reserve assets would reduce their liquidity and counterparty acceptance in the broader market. If the 20% cap survives final rulemaking, it could compress demand for tokenized T-Bills and affect how hedge fund and family office clients value them as repo collateral. Armada should model a stressed collateral scenario assuming the cap is enacted and identify alternative high-quality assets.