Hyperliquid Strategies has applied to establish a U.S. futures commission merchant as part of an effort to bring permissioned perpetual markets built on Hyperliquid infrastructure to American customers. According to the company’s official quarterly filing with the SEC, a subsidiary has submitted an FCM application that remains subject to regulatory approval, with no guaranteed timeline or outcome. The application was filed through the National Futures Association and remains pending.
The proposed FCM, HypeStrat Markets, would carry U.S. customer accounts for approved markets using Hyperliquid’s planned HIP-3* infrastructure. That role is narrower than operating the underlying exchange. Hyperliquid Strategies is attempting to become a regulated intermediary between U.S. customers and permissioned onchain derivatives markets rather than bringing the existing permissionless Hyperliquid venue directly onshore.
FCM Registration Is Only One Layer
Under Commodity Futures Trading Commission requirements, an FCM can accept futures or derivatives orders and hold customer funds supporting those positions. Registered FCMs must also meet capital, segregation, reporting and customer-protection requirements and become NFA members. FCM approval would give HypeStrat Markets the regulatory capacity to carry eligible customer accounts, but it would not independently authorize the contracts those customers trade.
Hyperliquid Strategies’ own regulatory diagram places a designated contract market and derivatives clearing organization above the blockchain layer. Those regulated entities would create and administer the permissioned markets and control their allowlists, while participating FCMs would handle customer accounts. The proposed model therefore places regulated financial infrastructure above Hyperliquid rather than replacing those intermediaries with the blockchain itself.
That structure fits a wider attempt to move crypto-style perpetual products into U.S. regulatory frameworks. Coinbase has separately filed registrations aimed at bringing single-stock perpetuals onshore, while offshore exchanges already offer equity and ETF perpetual contracts around the clock. The unresolved U.S. challenge is not simply technological access, but fitting perpetual market design into existing exchange, clearing and intermediary rules.
HIP-3* Remains on Testnet
Hyperliquid already operates HIP-3, which allows independent deployers to create perpetual DEXs by staking 500,000 HYPE and managing their own markets, oracles and leverage parameters. Those markets have helped turn the network into an active venue for 24/7 derivatives tied to equities, indices and commodities. HIP-3 itself remains permissionless, making it different from the regulated access model Hyperliquid Strategies is pursuing.
HIP-3* is an optional extension that adds deployer-managed onchain allowlists. Verified users could be admitted to individual permissioned markets while existing HIP-3 deployments remain unchanged. The initial implementation is currently available only on testnet, and Hyperliquid says specifications remain preliminary. No production launch date has been announced, so FCM approval would still leave a separate technical deployment milestone before the proposed structure could operate.
The economic case for moving part of that activity onshore comes from HIP-3’s existing scale. Hyperliquid Strategies reported that builder-deployed markets had generated more than $514 billion in cumulative volume by August 23, while commodity-linked contracts have previously pushed Hyperliquid into periods of billion-dollar daily oil-perpetual activity. Those historical volumes demonstrate demand for the permissionless product, not expected volume for any future regulated U.S. market.
Hyperliquid Strategies is also legally distinct from Hyperliquid Labs and the underlying protocol. Its primary business remains accumulating and staking HYPE, with 38.5 million tokens held at September 30. The FCM application would add a regulated operating role to a company currently centered on a digital-asset treasury strategy, but neither the registration nor permissioned HIP-3 markets have been approved for production use.