- IPOP contracts could give U.S. traders price exposure to planned listings without providing equity ownership or voting rights.
- Five completed Hyperliquid IPOP markets showed prices that closely anticipated subsequent public-market opening prices.
- The proposal calls for leverage limits, disclosures and safeguards against manipulation, conflicts and trading on material nonpublic information.
Hyperliquid Policy Center and trade[XYZ] have filed a joint SEC comment letter proposing pre-IPO perpetuals for U.S. investors. The groups said these contracts could create public price signals before companies begin trading. Their filing follows five completed IPOP markets on Hyperliquid, covering planned listings including Cerebras, SpaceX, SK Hynix, and CXMT.
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.
The groups said IPOP prices closely anticipated opening prices across five completed markets. U.S. offerings priced 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. The opening price stood 472% above its listing price.
Filing Seeks Rules for IPOP Markets
However, the proposed contracts would require regulatory decisions before serving U.S. investors. The filing asks the SEC to determine whether equity perpetuals qualify as security futures or security-based swaps.
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.
Notably, 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.
Hyperliquid Policy Center and trade[XYZ] also proposed advance disclosure of oracle and settlement rules. They said 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.
