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The $480bn it waves at the SEC and CFTC is under a tenth of its own venue's volume, and the onshore category it wants to enter is one CME only reopened in July.
The Investor · Invest desk
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Two figures in the same filing describe two different businesses. The $480bn of cumulative notional belongs to independent operators who deployed their own perpetual markets on Hyperliquid in oil, metals, currencies, equity indices and single stocks over ten months, alongside roughly $4bn of open interest [6]. DefiLlama's count for the venue as a whole is above $5trn of cumulative perpetual volume and near $13bn of open interest [7]. The slice being presented to Washington is therefore under a tenth of the volume the exchange clears [16], while carrying close to three in every ten dollars of its open interest [17]. Set cumulative notional against current open interest and the builder markets show about 120 turns versus roughly 385 for the venue overall [18]; the measurement windows differ, so read that as a direction rather than a ratio. It says the independent books hold committed capital that trades comparatively rarely. And $480bn over ten months averages about $48bn a month of churn [19], which is not a pool of assets waiting to be moved onshore.
What HPC wants is cheap to grant. It asks the commissions to confirm that a qualifying cash-settled equity perpetual can be listed as a security future, to leave listing decisions with venues, to keep the classification identical at both agencies, and to modernise the security futures framework [4], and it says interpretive guidance, policy statements and staff action can do all four without formal rulemaking [5]. That is the fast route and also the least anchored one. The letter's own history section is the warning: novel options, index participations and volatility-index futures each hit the same inter-agency boundary over four decades, and each dispute stalled new markets for years [14]. HPC quoted a federal judge comparing the exercise to deciding whether tetrahedrons belong in square or round holes [13].
The destination matters as much as the permission. Security futures is a category where CME only revived single-stock futures on July 27, the first real activity in years [9]. Onshore equity perps would launch into that, starting from whatever liquidity US participants bring, not inheriting the offshore book. The nearest precedent stops short too: the CFTC cleared Kalshi's BTCPERP as a futures contract on May 29, and in the same policy statement flagged equity perpetuals as needing joint SEC-CFTC review [8].
The economics of the two legal buckets are identical; what differs is who may trade them and where [12], which is why the filing is aimed at the agencies' joint request for comment on defining "swap" and "security-based swap" [3] rather than at Congress. HPC's argument is that a perpetual already carries the hallmarks courts use for futures, and that the absent expiry date does not disqualify it [2], with the pitch that following its steps brings more of the offshore market home [15].
Who is paying is on the record. The Hyper Foundation launched HPC in February 2026 with 1 million HYPE tokens, worth about $30m at the time, and hired Jake Chervinsky to run it [10]. Trump's August 20 remark that CFTC chairman Michael Selig was working to bring Hyperliquid into the US legally moved HYPE more than 17% [11]. The token repriced on a political sentence before any agency wrote a word, which tells you what the market is actually tracking.
Ranked by verification strength, evidence, and original report placement.
Independent operators deploying their own perpetual markets on Hyperliquid in oil, metals, currencies, equity indices and single stocks booked more than $480 billion in cumulative notional trading over their first ten months and hold roughly $4 billion in open interest, with liquidity developed offshore.
The Hyperliquid Policy Center told the SEC and CFTC on August 24 that cash-settled equity perpetual contracts should be permitted in US markets as "security futures".
HPC's comment letter argues a perpetual contract already behaves like a futures contract, citing hallmarks courts have used such as standardized terms, fungibility, futurity and close-out through an offsetting trade, and says the missing expiry date is not disqualifying.
HPC's filing responds to a joint SEC-CFTC request for comment on how to further define "swap" and "security-based swap".
HPC asks the agencies for four steps: confirm a qualifying equity perpetual can be listed as a security future; preserve venues' current freedom to make listing calls; keep classification consistent across both agencies; and modernize the security futures framework.
HPC says the commissions can take each of the four steps without any formal rulemaking, using interpretive guidance, policy statements and staff action.
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Evidence-backed comparisons of source perspectives and observed adoption signals. Read the methodology
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Single-outlet account of an interested party's filing
Everything traces to one crypto-trade report of HPC's own comment letter and blog post. The letter itself is not linked or quoted at length, the headline volume figures are the advocacy group's self-reported numbers, and no regulator, opposing commenter or independent legal analysis appears. Checkable third-party anchors do exist — DefiLlama venue data, the CFTC's BTCPERP clearance, CME's single-stock futures relaunch — which keeps this above the floor.
Heavy offshore usage, zero onshore uptake of the ask
Perpetuals themselves have real usage: >$5trn cumulative venue volume, ~$13bn open interest, and $480bn/$4bn on independent HIP-3 markets. But the subject of the story — equity perpetuals listed onshore as security futures — has no adoption at all: no agency has acted, the only cleared US perpetual is a crypto contract (BTCPERP), and the onshore security-futures category was reopened by CME barely a month before this filing.
Leverage number oversold against a category barely reopened
The story's persuasive weight rests on $480bn of offshore notional, which is under a tenth of the venue's own cumulative volume, and on the assertion that four regulatory changes need no rulemaking — a position asserted by the petitioner and untested by any agency response. Political framing (Trump's remark, a 17% HYPE move) amplifies further. The report does supply its own counterweights, which limits the gap: DefiLlama's totals, the July 27 CME relaunch, and the four decades of SEC-CFTC boundary fights that stalled comparable products for years.
Token-funded advocacy arm petitioning on its own venue's behalf
HPC was created in February 2026 by the Hyper Foundation and endowed with 1 million HYPE worth about $30m, and is led by a crypto lawyer hired for the role; its filing would directly benefit the Hyperliquid ecosystem whose token funds it. HYPE's 17%-plus move on a favorable political remark shows the financial sensitivity to regulatory narrative. The sole publisher is a crypto trade outlet relaying the petitioner's figures, and the volume statistics come from the beneficiary itself.
Filing and milestones are solid; consequences are not
That HPC filed this letter and made these four asks is straightforwardly reported, as are the dated regulatory milestones, so the descriptive core is reasonably firm even on one source. Confidence drops on the numbers, which are unverified and mixed with a differently-scoped third-party dataset, and on the outcome, where no agency reaction exists and prior jurisdictional fights suggest years rather than staff-level fixes.
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