BlackRock has submitted a comment letter to the Office of the Comptroller of the Currency (OCC) opposing restrictions on reserve assets proposed in the draft rules for implementing the GENIUS Act. The OCC's comment focuses on the "Permitted Payment Stablecoin Issuers" rule, urging against setting a cap on the quantity of tokenized reserve assets. BlackRock argues that such restrictions are irrelevant to regulatory objectives, and that the risk of reserve assets should depend on their credit quality, duration, and liquidity, not on whether they are held or transferred in the form of a distributed ledger. This comment letter is a response to several rule-related questions raised by the OCC, covering aspects such as reserve composition, capital requirements, and custody. (The Block)