GENIUS Act: BlackRock challenges 20% tokenized reserve cap, ENA impact
BlackRock has submitted a comment letter to the U.S. Office of the Comptroller of the Currency (OCC) criticizing draft rules under the GENIUS Act. The firm urged the OCC to remove a proposed 20% maximum cap on tokenized assets held in reserves by PPSIs (stablecoin issuers authorized under federal rules).
BlackRock argued that a hard quantitative limit conflicts with the OCC’s goals. It said reserve risk should depend on credit quality, maturity, and liquidity—not on whether assets are recorded on a distributed ledger. The letter came on the last day of the OCC’s 60-day comment window and addressed 200+ questions.
This regulatory stance matters for ENA-linked stablecoin reserves. BlackRock’s BUIDL fund reportedly manages about $2.6B in tokenized Treasury exposure (per RWA.xyz data) and is described as supplying more than 90% of reserves for Ethena’s USDtb (ENA-linked), while also backing Solana-based Jupiter’s JupUSD. BlackRock also sought confirmation that ETFs holding only eligible reserve assets would count toward reserves under Section 4 of the GENIUS Act.
From a market-trading angle, ENA is around $0.103 and is flagged as sideways (RSI ~48). Key levels cited include support near $0.099 and resistance near $0.1058. Traders may watch ENA for follow-through if regulation increases confidence in tokenized reserve utility under the GENIUS Act.
Bullish
The headline risk is regulatory design: BlackRock is pushing the OCC to remove a strict 20% cap on tokenized reserve assets under the GENIUS Act. If the final rules allow greater flexibility, it typically supports the business case for tokenized Treasuries as stablecoin reserves. That can indirectly lift demand for assets routed through ENA-linked mechanisms (the article points to Ethena’s USDtb reserve composition).
Historically, when large asset managers influence tokenized-reserve regulations toward “principles-based” limits rather than rigid quantitative caps, markets often react positively to the perceived expansion of eligible reserve capacity. That said, the article also cites ENA technicals as sideways and flags a bearish Supertrend signal, which can mute immediate price follow-through.
So the likely setup is: short-term volatility around OCC/GENIUS updates and technical resistance levels (e.g., near $0.1058). Long-term, broader acceptance of tokenized reserves can be structurally supportive for ENA-related reserve demand, but traders should still monitor rule finalization timelines and any constraints introduced in the final OCC framework.