Hyperliquid Policy Center and trade[XYZ] have filed a joint comment letter with the U.S. Securities and Exchange Commission (SEC) proposing pre-IPO perpetuals (IPOPs) for U.S. investors, announced on X. The groups said these contracts could create public price signals before companies begin trading, moving price discovery earlier than in conventional IPOs, where the first broad public market signal has typically come when shares start trading on an exchange. IPOP contracts would give U.S. traders price exposure to planned listings without providing equity ownership or voting rights.

The filing follows five completed IPOP markets on Hyperliquid, a decentralized perpetual futures exchange, covering planned listings including Cerebras, an AI chipmaker; SpaceX, the space launch company; SK Hynix, a South Korean memory chipmaker; and CXMT, a Chinese memory chipmaker. Across those markets, the groups said, IPOP prices closely anticipated subsequent public-market opening prices.

Pre-IPO Perpetuals Create Early Price Signals

According to the filing, an IPOP lets traders take directional exposure to an expected listing before shares begin trading. The contracts provide price exposure only and offer no ownership, voting rights, or share allocation. Perpetual futures, a contract type that originated in cryptocurrency markets, have no expiration date and use recurring funding-rate payments to keep contract prices anchored to the underlying reference price.

The groups said IPOP prices closely anticipated opening prices across the five completed markets. In the U.S. offerings, final prices came in 10.8% to 38.4% below IPOP prices recorded the previous day.

Cerebras priced at $185 and opened at $350. SpaceX priced at $135 and opened at $150, while SK Hynix priced at $149 and opened at $170. CXMT priced its Shanghai listing at 8.66 yuan and opened at 49.50 yuan, leaving the opening price 472% above its listing price.

Filing Seeks Rules for IPOP Markets

However, the proposed contracts would require regulatory decisions before they could serve U.S. investors. The filing asks the SEC to determine whether equity perpetuals qualify as security futures or as security-based swaps. The classification is consequential: security futures are jointly overseen by the SEC and CFTC, while security-based swaps are regulated by the SEC under rules adopted after the 2008 financial crisis.

The groups also proposed disclosure rules covering funding rates, leverage, liquidation thresholds, pricing, conversion, and settlement. They urged listing eligibility rules tied to publicly announced offerings and defined listing windows.

The filing also calls for safeguards covering market manipulation, conflicts, deployer activity, and trading while holding material nonpublic information.

SEC Could Review Retail Access

The filing proposes eventually making IPOP markets available to all U.S. investors, including retail traders. It suggests phased access with leverage limits, position limits, and product-specific risk disclosures for participants.

Hyperliquid Policy Center and trade[XYZ] also proposed advance disclosure of the oracle and settlement rules governing the contracts. They said any changes to those rules should receive full disclosure.

The proposal follows an SEC request for ideas on modernizing the IPO process. It also references a May 29 CFTC policy statement supporting joint SEC-CFTC review of equity perpetuals.