HPC and trade[XYZ] Introduce Pre-IPO Perpetuals to the SEC

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Aug 18, 2026 Read time: 1 min HPC and trade[XYZ] Introduce Pre-IPO Perpetuals to the SEC HPC and trade[XYZ] Introduce Pre-IPO Perpetuals to the SEC American investors are missing the best opportunities that equity markets produce. These days, companies wait years longer to go public than ever before, if they go public at all, and roughly 40 percent fewer companies trade on U.S. exchanges than in the mid-1990s. While companies grow in private, only venture capital funds, accredited investors, and large institutions can own a piece. Everyone else gets to invest only after the growth is over, and even then, IPO allocations often go elsewhere. Issuers aren’t well served by this market structure either. An IPO is priced without the public: the banks running the deal gather orders privately, and everyone else, including at times the company itself, learns how the market values the company only once the stock starts trading. The company is making the most important sale in its history, but pricing it blind. This year's listings show the cost of pricing an offering without a public market. Cerebras priced its IPO at $185 and opened at $350. SpaceX priced at $135 and opened at $150. SK Hynix priced at $149 and opened at $170. Each of these offerings first traded 11 to 89 percent above its offering price, and the money in that gap went to allocation recipients rather than to the companies themselves. That problem extends beyond U.S. markets: ChangXin Memory Technologies ("CXMT") priced its Shanghai listing at 8.66 yuan (about $1.30) and opened at 49.50 yuan (about $7.30), 472 percent above the listing price. Issuers may desire some underpricing by design, since a first-day pop helps sustain demand after the offering, but misses of this magnitude are bad for business. Today, Hyperliquid Policy Center and trade[XYZ], the largest deployer of perpetual markets built on the Hyperliquid blockchain, filed a joint comment letter responding to the SEC’s call for ideas to modernize the IPO process . We share Chairman Atkins’ view that the process requires modernization, and our letter brings a new instrument to that effort, the pre-IPO perpetual ("IPOP"). Our letter presents the pricing record of the five trade[xyz] IPOP markets that have run their full course on Hyperliquid and identifies the questions that the Commission would need to resolve before these markets could serve Americans. An IPOP is a simple instrument. In the weeks before an anticipated listing, it gives traders a way to express a directional view on the referenced issuer’s equity, and it publishes a continuous public price as they do. Just like index futures tell traders where the S&P 500 stands before the opening bell, an IPOP tells them the same for a stock that has never traded publicly. Holding an IPOP conveys no shares, no allocation, no voting rights, and no claim of any kind against the referenced issuer. It provides price exposure and nothing else. That separates an IPOP from existing private secondary market structures, which deliver ownership stakes through transfers of restricted shares and carry the fees and complexity that follow from that design. IPOPs involve no transfer of shares, and the settlement architecture keeps the market from running indefinitely when a listing is repeatedly or significantly delayed. The instrument’s pre-IPO function ends when the company lists, so an IPOP cannot persist as a standing synthetic market in private-company shares. The first IPOP market, on Cerebras, existed for just 13 days . The letter walks through each completed trade[XYZ] IPOP to date. U.S. offerings priced 10.8 to 38.4 percent below where the IPOP was trading the day before, and CXMT priced its Shanghai offering at less than one-fifth of what the IPOP market indicated. In each market, the IPOP was the primary continuously traded public price signal, and it reflected demand from both longs and shorts. The IPOP’s price just before the offering closely anticipated where the stock would begin trading, in some cases more accurately than pre-open indications reported by traditional outlets . When the IPOP market’s expectations ran too high, the price corrected as the listing approached. All of the underlying data is recorded onchain, available to any issuer, regulator, or researcher who wants to check the record. Price discovery produced that way is a public good, amplified on Hyperliquid by fully onchain order books that leave the entire record in open view. IPOP markets surface pricing information that benefits the IPO process itself. Issuers and underwriters gain an independent, public read on demand against which to evaluate a proposed range. IPOPs are particularly useful for direct listings, which have long been held back by the lack of a pre-listing price formation mechanism. Liquid IPOP markets provide exactly that input at no cost to the issuer. The SEC invited bold ideas to modernize the IPO process. We support the Commission’s modernization effort, and submit this letter in that spirit to show how IPOPs can serve the Commission’s objective. Further, the CFTC's May 29 policy statement accompanying the first U.S.-listed perpetual contract noted that perpetuals referencing equity securities would benefit from joint CFTC and SEC review. Equity perpetuals are squarely before the Commission, and IPO modernization is a natural forum for an instrument built to inform the IPO itself. Our letter identifies five items for the Commission to consider, each bearing on how these markets could serve U.S. persons: Classify the instrument. Whether equity-referencing perpetuals are treated as security futures or security-based swaps drives the applicable registration, venue, clearing, and margin requirements, among others. A coordinated SEC-CFTC position would keep the taxonomy consistent with the CFTC's treatment of commodity perpetuals. Match disclosure to the instrument. Issuer-style disclosure describes ownership stakes, which an IPOP holder never acquires. Disclosure should instead cover what the holder actually faces: contract mechanics, funding rates, leverage and liquidation thresholds, pricing methodology, conversion mechanics, and alternative settlement, consistent with disclosure for other listed derivatives. Set listing eligibility guardrails. Permitting deployment only after key information about the offering is made public, and within a defined window of a publicly announced offering, would keep the instrument tied to its price discovery function. trade[XYZ]'s existing practice offers a working template. Promote market integrity. Oracle and settlement rules should be announced in advance, and changes to those rules should be fully disclosed. A framework should also cover deployer discretion, audit trails, and safeguards against manipulation, conflicts, and trading by deployers or affiliates while aware of material nonpublic information. Onshore IPOP markets for all investors. IPOPs can give all investors, including retail investors, a differentiated way to gain exposure to private companies approaching a listing. A phased introduction incorporating leverage limits, position limits, and instrument-specific risk disclosure could build the Commission's supervisory experience with the product. The ultimate objective should be making these markets available to all U.S. investors. This year, Americans watched a public price form ahead of five IPOs on markets they couldn't access. They had the signal in plain view and no way to trade it. Under a new framework that the Commission has the authority to write, American investors and issuers could join others around the world in benefitting from the innovation that pre-IPO markets afford. Our full comment letter is available here .

AI 시장 분석

HPC and trade[XYZ] have jointly submitted a pre-IPO perpetual contract product to the SEC, pushing for institutional integration. This move marks a major turning point that could significantly expand investment access to unlisted company shares. Investors should closely monitor future regulatory approval and market reactions following the introduction of the new derivatives.

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DYAX 전담 분석

With the submission of the pre-IPO perpetual contract product to the SEC, liquidity supply and trading activity in the unlisted stock derivatives market are expected to increase. Regulatory approval will be the key indicator determining short-term price volatility.

If approved, it will act as a bullish factor for the fintech and derivatives trading sectors, but if regulatory risks materialize, investor sentiment toward related assets could deteriorate sharply. The SEC review progress and major exchange reactions must be monitored.

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