Adriano Azzaretti The issue is technical but has concrete implications for international trade.
Blackrock's request is due to the direct consequences this rule would have on its BUIDL fund — BlackRock USD Institutional Digital Liquidity Fund — which currently has approximately $2,6 billion in assets under management invested in short-term US Treasuries entirely registered on-chain.
It covers over 90% of the reserves of two institutional stablecoins, Ethena USDtb and Jupiter JupUSD. A 20% cap on tokenized assets in reserves would make this model operationally incompatible with the federal framework, forcing issuers to dismantle a functioning reserve structure.
BlackRock's argument is one of principle, not just commercial interest.
The letter argues that the risk of a reserve depends on the credit quality of the underlying asset, its duration, and its liquidity—not on whether it is recorded on a distributed ledger rather than in a traditional custody system. A tokenized U.S. Treasury bond has the same risk profile as a U.S. Treasury bond held through a primary dealer.
Tokenization is the format of record, not a standalone risk category.
Because this is relevant to international trade.
Tokenized assets solve a structural problem in cross-border B2B payments: the time mismatch between goods delivery and payment settlement. With traditional structures, an exporter receiving a letter of credit waits for bank settlement in T+2 or T+3. If the reserve backing the stablecoin used to pay is itself a tokenized asset that can be liquidated in real time, the entire chain—collateral, stablecoin, payment—can be completed in seconds, 24 hours a day. Collateralization with tokenized Treasuries also allows payments to be automatically scheduled via smart contracts upon document verification, eliminating part of the counterparty risk currently managed by correspondent banks.
How the traditional banking system reacts
It's hard to believe that the limit on tokenized assets, contained in the draft legislation, wasn't suggested by US banks. The most likely aspect is that TradFi, traditional finance, is moving on several fronts. In the Clarity Act, whose debate in Congress has been postponed to May 2026, the American Banking Association successfully inserted a ban on stablecoins paying interest. Not everyone agrees; innovation and competition from foreign currencies could benefit from this restriction, and a compromise will likely be sought regarding the interest earned on the "active" or "passive" use of stablecoins.
Other banks, however, have adopted a "defensive integration" policy. In December 2025, JPMorgan launched the first tokenized money market fund of a GSIB on a public blockchain, through its Kinexys unit. HSBC operates the Orion platform for issuing digital bonds: in November 2025, it facilitated the world's largest digital bond issuance, HK$10 billion in multi-currency tranches for the Hong Kong government. Goldman Sachs and BNY Mellon have launched similar initiatives in collateral management and tokenized custody. In his annual letter to shareholders in April 2026, Jamie Dimon, not without difficulty considering his past outbursts on crypto assets, explicitly acknowledged that tokenization, stablecoins, and smart contracts pose a direct competitive threat to the core functions of traditional banking—payments, trading, and asset management—and that JPMorgan must accelerate this.
Transition, not obstructionism
The dynamic is typical of an industry where established players build proprietary infrastructure to control a segment that risks slipping out of their control. The goal is not to eliminate banking intermediation, but to shift it to an on-chain environment where banks retain their roles as custodians, issuers, and liquidity managers. The 20% limit proposed by the OCC, if confirmed, would encourage this defensive repositioning by slowing the scalability of non-bank products like BUIDL.
The OCC's decision is expected before the GENIUS Act's compliance deadline of January 2027. How tokenization in stablecoin reserves is handled will define who controls the international payments infrastructure for the next decade.