HPC and trade.XYZ Bring Pre‑IPO Perpetuals to the SEC for Approval

TL;DR

• Hyperliquid Policy Center and trade[XYZ] have submitted a joint comment letter to the SEC proposing pre-IPO perpetuals, or IPOPs, as a new tool for public price discovery.
• The contracts provide synthetic exposure to expected listing prices without granting shares, voting rights, dividends, or IPO allocations.
• The proposal argues that onchain markets could improve IPO pricing by giving issuers, regulators, and investors a transparent price signal before a stock begins trading.
  

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Hyperliquid Policy Center and trade[XYZ] are asking the U.S. Securities and Exchange Commission to consider pre-IPO perpetuals as part of a broader modernization of the IPO process. The proposal comes as private companies remain private longer, limiting access to early-stage equity gains and leaving public investors with fewer opportunities to participate before valuations mature.

The groups call the product an IPOP, a perpetual derivative that tracks market expectations for a company preparing to list. Unlike a private secondary transaction, an IPOP does not transfer shares or ownership. Traders receive price exposure only, with no voting rights, dividends, allocation rights, or claim against the issuer.

The proposal points to Cerebras as an early example. Its IPOP traded on Hyperliquid before the company listed on Nasdaq, creating a continuous market around expectations for the eventual public share price. Research from Castle Labs reported that the Cerebras market generated $281 million in cumulative notional volume during its 14-day window. The stock ultimately opened at $350 after an IPO price of $185.

Onchain Price Discovery Could Reshape The IPO Process

HPC and trade[XYZ] argue that a transparent pre-listing market could give issuers and underwriters another reference point when setting an offering range. That information could be particularly useful for direct listings, where companies do not rely on the traditional IPO bookbuilding process.

The proposal also asks regulators to clarify how equity-referencing perpetuals should be classified, including whether they fall under security-futures or security-based-swap rules. Other recommendations cover disclosure, listing eligibility, oracle and settlement standards, market-integrity safeguards, and a phased framework for U.S. access.

The model builds on Hyperliquid’s HIP-3 architecture, which allows independent builders to deploy perpetual markets onchain. trade[XYZ] says its markets use Hyperliquid infrastructure for execution and settlement, while its broader platform already offers equity and commodity perpetuals. In March, S&P Dow Jones Indices licensed the S&P 500 to trade[XYZ] for an officially licensed perpetual contract, showing how traditional benchmarks can connect with blockchain-based derivatives.