Hyperliquid Strategies, the Nasdaq-listed company trading under the ticker PURR, has applied to register a subsidiary as a futures commission merchant (FCM) that would carry U.S. customer accounts for perpetual-futures markets built under Hyperliquid’s permissioned HIP-3* framework.

The company disclosed the application in its November 5 results release: Hyperliquid Strategies reports financial results for the quarter ended September 30, 2026. CEO David Schamis described the application and the company’s token purchases during the quarter as “the same bet.”

No launch date, initial contracts, customer eligibility requirements or fees have been disclosed.

What a U.S. Account Would Mean

An FCM is a firm that accepts customer orders and holds the money backing those orders, as described by the National Futures Association. It stands between traders and the market but does not operate the market itself.

That is the role Hyperliquid Strategies is seeking. Its subsidiary would carry U.S. client accounts for markets created under HIP-3*, a permissioned version of the HIP-3 framework that allows outside deployers to launch perpetual futures on Hyperliquid.

Perpetual futures — the instrument these HIP-3* markets would host — are derivative contracts with no fixed expiry that let traders hold leveraged long or short positions on an asset’s price.

The company’s release does not mention access to Hyperliquid’s existing open markets. As described, the proposal would therefore give U.S. traders access through a narrower group of permissioned markets.

The disclosed details are:

• Status: An FCM application filed by a subsidiary
• Scope: U.S. client accounts on permissioned HIP-3* markets
• Stated aim: Perpetual futures for U.S. customers within a regulated framework

The company has not disclosed the subsidiary’s name, the contracts that would be listed first, who could open an account, the cost of doing so or a start date.

The Broker Is Only Half of the Approval Process

The release links the plan to two separate decisions. It provides no assurance about the timing or outcome of the FCM application, and it also provides no assurance that the permissioned HIP-3* markets themselves will receive the approvals needed to serve U.S. customers.

The second issue is distinct from the first. Under U.S. rules, a market offering futures to retail traders generally must be designated as a contract market by the Commodity Futures Trading Commission, unless an exemption or exclusion applies. An FCM can carry customer accounts, but it cannot give a market that regulatory status.

Hyperliquid’s documentation assigns contract specifications, price inputs and daily operations to each market’s deployer. The company’s release says independent operators would run their own markets in compliance with applicable requirements, while the underlying blockchain would remain neutral infrastructure.

Neither the documentation nor the release names the operator that would seek U.S. standing for these markets or the clearinghouse that would stand behind the trades. Until those parties are identified, the application covers the account layer of a structure whose market layer has not been disclosed.

Wallet restrictions do not resolve that issue. As Coindoo previously reported in its article on Hyperliquid’s permissioned-market plans, HIP-3* limits trading to approved addresses. Determining which U.S. customers may legally control those addresses is a separate legal question.

Capital Is the Smaller Hurdle

An FCM is primarily a compliance operation rather than a trading operation. The NFA’s FCM application requirements call for financial reporting, a chief compliance officer and written procedures covering cybersecurity, risk management and customer complaints. Those requirements remain in place after approval.

The capital requirement is more limited by comparison. The CFTC sets minimum adjusted net capital for an FCM at $1,000,000, or a higher amount tied to the margin on positions it carries, according to the agency’s minimum net capital requirements.

Hyperliquid Strategies ended September with $254.6 million in cash and cash-like instruments and no debt. Meeting the opening capital requirement therefore appears manageable, provided the capital is placed in the registered subsidiary. The obligation increases with the size of the business: an FCM must hold more capital as it carries more customer margin.

What Drove the $620.6 Million in Net Income

The company’s September-quarter results were influenced more by the price of HYPE than by its operating business. The gain on tokens that the company still holds exceeded its net income, while the largest deduction was a tax provision recorded during the quarter.

Excluding those items, staking, validator commissions and interest generated approximately $13.3 million, or about 1.7 times the amount spent on selling, general and administrative expenses and research and development.

Most of that revenue came from the validator the company operates with Unit. Validators are the operators that help run the network: token holders delegate HYPE to them for staking, and validators keep a commission on the rewards produced. The release describes that validator as the largest on the network outside the Hyperliquid Foundation. Annualized, the quarter’s staking and commission revenue would equal approximately $49 million, or about 1.4% of the company’s $3,505.3 million HYPE holdings at September 30.

The company’s exposure to HYPE’s price is substantially larger. With approximately 38.5 million HYPE on its balance sheet at quarter-end, every $1 move in the token changes the value of the treasury by roughly $38.5 million. That amount is equivalent to about 6% of the quarter’s total net income.

Newer Tokens Provide a Smaller Cushion

Hyperliquid Strategies bought 9.1 million HYPE during the quarter for $785 million, an average of approximately $86 per token. HYPE closed September at $90.99, about 5% above that average. The purchases therefore increased the size of the treasury but provided only a limited margin at quarter-end.

The larger cushion comes from older holdings. Based on the cumulative figures in the company’s release, Hyperliquid Strategies has purchased approximately 25.9 million HYPE at an average price of $61.13 since launch. Its latest reported count of 38.9 million tokens, including staking and validator rewards, has a blended cost of $56.35.

HYPE would have to decline by about 38% from its September 30 price before the company’s overall position fell below its aggregate purchase cost.

Share Sales Fund the Purchases

The treasury strategy is funded through share sales. Hyperliquid Strategies raised $911 million during the quarter through its committed equity facility. A committed equity facility is a pre-arranged agreement in which an investor buys newly issued shares from a company as needed, giving it an on-demand funding channel. Under the facility, described in the company’s SEC prospectus, the company sells newly issued shares to Chardan. Coindoo previously reported on the facility’s expanded capacity in its article on Hyperliquid Strategies’ $2.5 billion funding facility.

The September quarter showed heavy use of the facility, and the income statement now includes a related charge.

During the same quarter, the company spent $17 million repurchasing 2.7 million PURR shares, or approximately $6.30 per share. Selling shares and retiring shares at the same time can benefit remaining holders when new shares are sold at higher prices than the prices paid for repurchases. The cumulative figures show that pattern: approximately $1,578.4 million raised at an average of $10.36 per share, compared with $27.9 million spent on roughly 5.8 million shares at an average of $4.81.

The company has since increased its stock-repurchase authorization to $100 million, according to its repurchase-program announcement.

The release does not provide a share count and therefore does not show HYPE per share, a measure that indicates whether share issuance has increased or diluted each holder’s portion of the treasury. The company directs investors to the Adjusted Net Asset Value section of its website for that information.

“The Same Bet” in Both Directions

Schamis’s position is that the brokerage and the treasury would reinforce one another. The company’s release says fees generated by Hyperliquid flow back to HYPE through programmatic buybacks and estimates that approximately $834 million in value accrued to the ecosystem during the 12 months ended September 30. The company says it has not independently verified that figure.

Under that view, U.S. accounts trading HIP-3* markets would contribute fees to the system supporting the token, while the FCM would generate its own account-related revenue.

The same structure also creates a shared exposure. If the brokerage and treasury represent one bet, the FCM would not hedge the treasury. A decline in HYPE would reduce the value of the asset base and could occur alongside weaker activity on the markets the brokerage is intended to serve. Investors seeking exposure to PURR beyond the token would not find that diversification in the proposal as currently described.

Three disclosures would provide important tests of the plan: an approved FCM registration visible in the NFA’s public BASIC database; the identities of the operator and clearinghouse behind U.S.-facing HIP-3* markets; and separate reporting of FCM costs and customer revenue, beginning with results for the quarter ending December 31, 2026.

Until those disclosures are made, the quarter’s figures describe a HYPE treasury, while the brokerage remains an application.