Hyperliquid group and trade[XYZ] ask SEC to write rules for pre-IPO perpetuals
DeFi & Yields ·
The two entities want a formal U.S. framework, including eventual retail access, for perpetual contracts tied to companies that haven't yet gone public.
Hyperliquid Policy Center and trade[XYZ], described as a deployer of perpetual markets on Hyperliquid, jointly filed a comment letter with the SEC proposing rules for what they call IPOPs, or pre-IPO perpetual contracts, according to wublockchain.xyz. The letter recommends that U.S. investors, including retail participants, eventually be permitted to trade these instruments.
Under the proposal, IPOPs would not confer shares, voting rights, or rights to an eventual IPO allocation. Instead, they would give holders exposure to price movements ahead of a public listing, serving a price-discovery function for companies that have not yet completed an offering.
Beyond the IPOP concept itself, the filing pushes regulators to resolve a broader classification question: whether equity-linked perpetual contracts should be treated as security futures or as security-based swaps. That distinction determines which agency, and which rulebook, would govern the products. The letter asks the SEC and CFTC jointly to settle the matter rather than leave it ambiguous.
The submission also calls for specific guardrails once a framework exists, including disclosure requirements, listing standards, leverage limits, position limits, and safeguards against market manipulation. These are the kinds of structural rules regulators typically require before extending access to retail traders, and their absence has been a central obstacle to bringing pre-IPO exposure products into a compliant U.S. market.
The filing sits alongside other regulatory and market developments tracked in the same period, including a proposal on U.S. stablecoin regulation and a block on Polymarket in South Korea, underscoring active scrutiny of crypto-adjacent derivatives and prediction markets across jurisdictions. What remains unresolved is whether the SEC and CFTC will act on the joint letter, how quickly any classification guidance might arrive, and whether retail access would be phased in or conditioned on the disclosure and risk-limit regime the letter proposes.