Hyperliquid Policy Center asks SEC to consider pre IPO perpetual markets

Hyperliquid Policy Center and trade[XYZ] have filed a joint comment letter with the US Securities and Exchange Commission proposing pre IPO perpetual markets as a tool to improve price discovery before public listings.

The letter responds to the SEC’s request for ideas to modernize the IPO process and argues that pre IPO perpetuals, or IPOPs, could give investors and issuers a continuous public market signal before shares begin trading.

Unlike private secondary markets, IPOPs do not provide ownership, voting rights, allocations, or claims against the underlying company. Instead, they give traders price exposure to an anticipated listing before the stock enters public markets.

The groups pointed to five completed trade[XYZ] IPOP markets on Hyperliquid, including Cerebras, SpaceX, SK Hynix and ChangXin Memory Technologies. According to the filing, US offerings were priced between 10.8% and 38.4% below where their respective IPOP markets traded the previous day.

The groups argue that these markets could help issuers and underwriters assess investor demand before setting an offering price, potentially reducing large gaps between IPO pricing and opening trades.

The letter asks the SEC and Commodity Futures Trading Commission to clarify how equity linked perpetuals should be classified and regulated. It also recommends disclosure requirements focused on contract mechanics, leverage, liquidation thresholds and settlement rules.

Additional proposals include eligibility rules limiting when IPOPs can launch, market integrity requirements and a phased framework that could eventually allow US retail investors to access the products.