Two Comment Letters, One Battlefield
The U.S. Office of the Comptroller of the Currency (OCC) has received pushback from two major institutions on the GENIUS Act's stablecoin reserve framework—both pointing in the same direction.
BlackRock's letter explicitly opposes a proposed 20% cap on tokenized reserve assets, calling the restriction irrelevant to regulatory objectives. The firm argues that asset risk is determined by credit quality, duration, and liquidity—not by whether the asset is held or transferred on a distributed ledger. This directly challenges the foundational logic of the regulatory draft.
Anchorage: Principles-Based Oversight Over Mechanical Quotas
Anchorage Digital's comment letter targets several specific quantitative requirements. Its core recommendations include: recognizing South Dakota trust structures for reserve asset segregation; opposing rigid caps such as the 10% daily liquidity deposit limit, the 40% single-custodian ceiling, and the 20-day WAM requirement in favor of stress-testing-based oversight; and rejecting the blanket classification of third-party payment yields as "prohibited interest circumvention."
Anchorage also recommends removing the mechanism that triggers up to a 7-day redemption delay when single-day redemptions exceed 10%, arguing that such mechanical triggers could backfire under real stress conditions.
The Reserve Rules Debate: Who Gets to Define "Safe"?
At its core, this battle over reserve rules is a contest over who gets to define what counts as a safe asset. Traditional regulators draw risk boundaries by asset form; Wall Street institutions insist that underlying asset quality is the only meaningful benchmark.
As the stablecoin market grows, the reserve framework will directly shape institutional participation costs and competitive dynamics. In this environment, compliance monitoring capability becomes increasingly critical—Trustformer KYT offers full-chain fund flow tracking, helping institutions achieve precise compliance across shifting regulatory landscapes.