BlackRock urged the OCC to remove a proposed 20% cap on tokenized reserve assets in draft rules tied to the GENIUS Act, saying reserve risk should be assessed based on credit quality, duration, and liquidity rather than whether assets are recorded on distributed ledgers. The firm also asked the regulator to clarify whether Treasury ETF reserves qualify under Section 4. The letter adds specific detail to BlackRock’s earlier push for broader reserve eligibility and more flexible treatment of tokenized assets in the developing regulatory framework.