Six of the largest U.S. asset managers — BlackRock, JPMorgan, Morgan Stanley, Fidelity, Goldman Sachs, and State Street — have filed or launched dedicated money market funds engineered to serve as eligible reserve assets for stablecoin issuers under the GENIUS Act, which was signed into law in Ju...
"Investors are increasingly looking for ways to modernize liquidity management without changing the fundamentals of what they own. Money market funds have long served as a core tool for investors seeking liquidity, stability and competitive short-term yield." — John Donohue, Head of Global Liquidity, J.P. Morgan Asset Management
Six of the largest U.S. asset managers — BlackRock, JPMorgan, Morgan Stanley, Fidelity, Goldman Sachs, and State Street — have filed or launched dedicated money market funds engineered to serve as eligible reserve assets for stablecoin issuers under the GENIUS Act, which was signed into law in July 2025. The funds collectively target a share of the $320 billion stablecoin reserve pool, with the July 18, 2026 regulatory deadline driving urgency across the industry.
The race marks a structural shift in how Wall Street views blockchain infrastructure. Rather than building competing tokens or speculative products, these institutions are packaging their most traditional product — short-duration Treasury funds — into GENIUS Act-compliant vehicles. JPMorgan committed $100 million of its own capital to its Ethereum-based JLTXX fund at launch. BlackRock, which already manages approximately $65 billion of Circle's USDC reserves, filed for the BRSRV vehicle in May. Moody's assigned its top Aaa-mf rating to both BlackRock and Fidelity tokenized money market funds on May 14, the first time the agency simultaneously rated two distinct tokenized fund products from separate managers.
The combined effect is that stablecoin reserve management — previously an opaque, bilateral arrangement between issuers and custodians — is rapidly becoming a standardized, rated, and regulated asset management product line. The total tokenized Treasury and money market fund market surpassed $15 billion in AUM as of May 2026, up from $1 billion two years prior.
The GENIUS Act, signed by President Trump in July 2025, requires payment stablecoin issuers to maintain reserves on a 1:1 basis with the outstanding issuance value of their stablecoins. The law specifies a narrow set of eligible reserve assets:
The Office of the Comptroller of the Currency (OCC) issued its implementing proposed rulemaking on February 25, 2026. The FDIC followed with its own proposed rules on April 7. Both proposals require reserves to be identifiable, segregated, and maintained at fair value at all times. Rehypothecation or pledging of reserve assets is prohibited.
Federal regulators face a statutory deadline of July 18, 2026 to issue final implementing regulations. The Act takes full effect on the earlier of January 18, 2027 or 120 days after final regulations are published.
For issuers with $25 billion or more in outstanding stablecoins — currently only Tether (USDT, ~$185 billion) and Circle (USDC, ~$78 billion) — the OCC proposal requires holding at least 0.5% of reserves as insured deposits, capped at $500 million for issuers above $100 billion in outstanding value.
JPMorgan OnChain Liquidity-Token Money Market Fund is the firm's second tokenized money market product following MONY (launched December 2025). JLTXX operates on the public Ethereum blockchain, powered by JPMorgan's Kinexys Digital Assets platform.
BlackRock Daily Reinvestment Stablecoin Reserve Vehicle, filed with the SEC alongside a second product (BSTBL), is purpose-built for GENIUS Act reserve compliance. Built in partnership with Securitize, designed to operate across multiple chains.
Morgan Stanley Institutional Liquidity Funds Stablecoin Reserves Portfolio is a government money market fund explicitly designed around GENIUS Act investment constraints.
Fidelity's entry makes it the fifth money fund manager to file a dedicated stablecoin reserves product. The fund is structured under a national trust bank charter, opting for direct OCC oversight rather than state-by-state money transmitter licensing.
Goldman Sachs filed its stablecoin reserves money market fund in October 2025. BNY Mellon (Dreyfus) filed its own product in August 2025. Both funds follow the same GENIUS Act reserve constraint template — short-duration Treasuries, cash, and overnight repos. BNY Mellon additionally announced plans to tokenize its broader money fund lineup through its LiquidityDirect portal.
State Street Investment Management became the fourth manager to launch a dedicated stablecoin reserves money market fund. The State Street Stablecoin Reserves Money Market Fund invests exclusively in assets permitted under the GENIUS Act framework.
Total stablecoin supply reached $320 billion as of April 2026, according to DeFiLlama data. The composition:
| Issuer | Supply | Market Share | |--------|--------|-------------| | Tether (USDT) | ~$185B | 57.96% | | Circle (USDC) | ~$78B | ~24.4% | | Others | ~$57B | ~17.6% |
Under the GENIUS Act, every dollar of outstanding stablecoin supply must be backed by eligible reserve assets. This means that up to $320 billion — and growing — requires compliant reserve parking. For asset managers charging 15–20 basis points in management fees, the addressable revenue pool from stablecoin reserve management alone is $480 million to $640 million annually at current supply levels.
The competitive dynamics are already visible. BlackRock holds the early lead: its management of approximately $65 billion in Circle reserves gives it roughly 20% of the total addressable market. JPMorgan's $100 million seed commitment is modest relative to the opportunity but positions the firm as an alternative reserve manager. Morgan Stanley and Fidelity are targeting both stablecoin issuers and traditional institutional investors seeking GENIUS Act-compliant yield vehicles.
The stablecoin market itself continues to expand. Supply grew from approximately $130 billion in late 2023 to $315 billion by Q1 2026, a compound annual growth rate of roughly 55%. USDC has been gaining share against USDT, driven by B2B settlement integrations with Visa and Stripe and by Circle's U.S. regulatory positioning under the GENIUS Act.
A critical milestone occurred on May 14, 2026, when Moody's assigned Aaa-mf assessments — its highest money market fund rating — to both Fidelity International's FILQ tokenized fund and BlackRock's BUIDL simultaneously. This was the first time Moody's awarded its top money market designation to two tokenized fund products from separate asset managers at the same time.
The rating action matters for two reasons. First, many institutional mandates and regulatory frameworks reference Moody's money fund ratings as eligibility criteria. An Aaa-mf designation removes a barrier for regulated entities — including potential stablecoin issuers — that might otherwise be prohibited from holding unrated or low-rated fund shares. Second, the dual rating signals that the credit agency's evaluation framework has been adapted to accommodate the operational and settlement mechanics of tokenized fund structures.
The underlying tokenization infrastructure varies by manager:
| Manager | Platform | Blockchain(s) | |---------|----------|---------------| | JPMorgan | Kinexys Digital Assets | Ethereum | | BlackRock | Securitize | Multi-chain | | Fidelity | Sygnum Desygnate + Chainlink | Multiple | | Franklin Templeton | Proprietary (BENJI) | 8 blockchains |
Franklin Templeton's BENJI, which expanded to its eighth blockchain network in May 2026, represents the broadest chain distribution. The firm modified two institutional money market funds — LUIXX and DIGXX — to meet stablecoin reserve standards, with DIGXX offering an on-chain share class for 24/7 settlement.
The total tokenized Treasury and money market fund market surpassed $15 billion in AUM as of May 2026. The broader tokenized real-world asset market (excluding stablecoins) stood at $31–$34 billion, with Treasuries representing roughly half of total tokenized RWA value.
The economics of stablecoin reserve management at scale resemble government money market fund management — thin margins, massive volumes. At a 0.15–0.20% net expense ratio (the range disclosed by Morgan Stanley and JPMorgan), the revenue per dollar managed is modest. The margin depends entirely on scale.
Current fee pool estimate:
For context, the total U.S. government money market fund industry manages approximately $4.5 trillion. A $320 billion stablecoin reserve allocation would represent roughly 7% of the total government money fund market — a non-trivial increment that explains the competitive urgency among managers.
If stablecoin supply doubles to $640 billion — a scenario consistent with Citigroup's projections of stablecoins reaching $1.6 trillion by 2030 — the annual reserve management fee pool would reach $960 million to $1.28 billion.
The value distribution analysis is notable: stablecoin reserve management fees flow to traditional asset managers, not to blockchain validators or protocol treasuries. This mirrors the broader dynamic identified in economic value distribution research — that significant portions of the economic value generated by blockchain activity accrues to off-chain intermediaries and infrastructure providers rather than to on-chain participants.
Key dates:
Outstanding regulatory questions:
Final reserve composition rules: The OCC proposed two options (principles-based vs. mandatory quantitative) for reserve diversification. The final choice will determine how much flexibility issuers have in allocating across fund managers.
Tokenized fund eligibility: While the GENIUS Act permits "tokenized versions" of eligible reserve assets, regulators have not yet issued final guidance on what qualifies as a compliant tokenized fund structure versus a standard money market fund.
Non-U.S. stablecoin issuers: Tether, which operates primarily outside U.S. jurisdiction and accounts for 58% of total stablecoin supply, has not disclosed whether it will seek GENIUS Act compliance. Tether's reserve composition currently includes commercial paper and other assets that may not meet the Act's narrow eligible asset list.
State-level regimes: The Treasury Department is separately developing principles for acceptable state stablecoin regulatory regimes, creating a parallel compliance track.
The regulatory uncertainty has not slowed product development. Asset managers appear to be positioning for a worst-case scenario in which only the most conservatively structured funds will qualify, which explains the uniform focus on ultra-short Treasuries and overnight repos across all six managers' products.
The simultaneous entry of six major asset managers into the stablecoin reserve fund market represents one of the most concentrated institutional responses to a single piece of crypto legislation. The GENIUS Act created a defined, regulated demand pool — $320 billion and growing — for a specific category of financial product that these firms already manufacture at scale.
The competition is less about blockchain technology and more about traditional money fund economics: basis-point fees, operational scale, and regulatory relationships. The tokenization layer, whether on Ethereum (JPMorgan), multi-chain (BlackRock), or eight blockchains (Franklin Templeton), serves primarily as a distribution and settlement mechanism rather than as a source of differentiation.
For the stablecoin industry, the shift toward rated, regulated, institutional-grade reserve management adds a layer of credibility that bilateral custodial arrangements lacked. For the asset management industry, stablecoin reserves represent a net-new $320 billion addressable market that did not exist in a regulated form before July 2025.
The unresolved question is how much of the $320 billion reserve pool will flow to tokenized fund structures versus traditional, off-chain money market fund subscriptions. The answer depends on regulators' final treatment of tokenized fund eligibility — a determination expected no later than July 18, 2026.