Representatives of the Hyperliquid Policy Center and trade XYZ have submitted a joint letter to the U.S. Securities and Exchange Commission with proposals for modernizing the initial public offering process. The key idea is to create rules for a pre-IPO perpetual instrument, which the authors call IPOP. According to the authors of the letter, this is a derivative that provides the investor with only price exposure to the issuer’s securities until the time of listing. The instrument does not involve ownership of shares, allocation, voting rights, or any requirements for the company. After the start of public trading, IPOP should cease to exist, rather than becoming a permanent synthetic market for a private company.

The authors of the letter claim that the first IPOP market for Cerebras shares lasted thirteen days. They also stated that there are now forty percent fewer companies listed on US exchanges than there were in the mid‑1990s. The letter lists five completed IPOP markets on the Hyperliquid platform as examples. Among them are Cerebras, with an IPO price of $185 and a closing price of $350; SpaceX, with a price of $135 and a closing price of $150; SK Hynix, with a price of $149 and a closing price of $170; and ChangXin Memory Technologies, with a price of 8.66 yuan and a closing price of 49.5 yuan.

The American regulator was asked to consider five sets of issues: the classification of the instrument, disclosure requirements, listing rules, measures to ensure integrity, and the phased launch of markets in the United States for different categories of investors, with limits on leverage and positions. Special attention is paid to the possible usefulness of the instrument in direct listings, where there is no public price formation mechanism in advance. It should be recalled that in June, the Commodity Futures Trading Commission and the Securities Commission sought public input on the definitions of swaps and other derivative instruments.