Just as Trump said he wanted Hyperliquid to enter the United States legally, a 15 page opinion letter that would determine the perpetual fate of stocks was presented to the SEC and CFTC There is only one question: Should stocks with no expiration date be considered as swaps or securities futures? This classification may seem like a legal term, but in reality it may determine whether stocks like TradeXYZ are perpetual and truly accessible to ordinary investors in the United States On August 24th, the deadline for the joint consultation between the SEC and CFTC, the Hyperliquid Policy Center submitted a formal opinion letter in response to regulatory questions regarding the definition of "Swap" and "Securities Swap" The core proposition of HPC is that perpetual stock contracts with traditional futures characteristics and cash settlement can be regulated in accordance with securities and futures regulations First, explain the classification logic clearly US regulatory agencies should not only judge whether a derivative belongs to futures or swaps based on whether it has a fixed maturity date, but also on its contract structure and trading method HPC believes that typical stock perpetuity already has a lot of traditional futures features: Standardization of contract terms, where different users trade the same contract Centralize transactions in a publicly available central order book • Can close positions at any time through reverse trading Continuously calculate and manage margin Market prices are open and transparent Users gain price exposure rather than stock ownership • Continuously keeping contract prices close to spot prices through funding rates The most obvious difference between stock perpetual and traditional futures is that there is no fixed maturity date Traditional futures settle at maturity, allowing futures prices to eventually converge towards spot prices; Perpetual contracts use periodic funding rates to allow both long and short parties to continue paying fees, achieving a similar price convergence function Simply put, traditional futures reconcile at the end point, while perpetual contracts reconcile continuously during the trading process. Although the implementation methods are different, both aim to solve the same problem: avoiding derivative prices from deviating from reference assets for a long time Therefore, HPC believes that perpetual contracts should not be automatically excluded from futures without an expiration date Why do we have to strive for the identity of "securities and futures"? Because the other road has been blocked for almost 15 years If a stock is permanently recognized as a security class Swap and is aimed at ordinary investors in the United States, it usually requires registration under the Securities Act and trading on a registered stock exchange This system has been in existence for over 15 years, but a mature retail securities swap market has not yet developed. Compliance requirements exist, but a market that can truly serve ordinary investors has not emerged Securities and futures are different, as they already have a ready-made framework jointly regulated by the SEC and CFTC: Futures exchanges can register notifications with the SEC Stock exchanges can register notifications with the CFTC Two types of trading venues can launch similar products online Securities firms and futures intermediaries can also register across systems In July of this year, CME re launched 77 single stock futures contracts covering 55 US stocks, offering both standard and micro versions with nearly 23 hours of daily trading time, indicating that the long dormant securities and futures system is being restarted HPC hopes that stocks can continue to use and upgrade this existing track, rather than being stuck in a securities swap framework that has not formed a retail market for a long time But HPC also does not advocate that all stocks automatically become perpetual securities futures. It distinguishes between two product structures The first type is standardized perpetual contracts in the open market. They have unified terms, centralized trading, the ability to freely hedge and close positions, and are maintained by margin and funding rates. This type of product is closer to securities and futures The second type is a customized contract negotiated separately by both parties in the transaction. If the contract is not interchangeable, cannot be freely closed in the open market, and the trader needs to bear the credit risk of the specific counterparty, it may still belong to a Swap or securities Swap So what really determines regulatory classification is not whether there is a "Perp" in the product name, but how it is designed, traded, and how users exit positions Based on this logic, HPC has put forward several suggestions to the SEC and CFTC: • Issue clear guidelines to confirm that the definition of securities and futures can cover perpetual cash settled stocks Do not exclude the futures nature of perpetual contracts simply because they do not have a fixed expiration date • Maintain the flexibility of the trading venue in product judgment and listing Ensure that the SEC and CFTC adopt consistent classification standards for similar perpetual contracts • Evaluate the competitive value brought by securities and futures, and continue to improve the existing regulatory framework HPC also emphasizes that these issues do not necessarily have to wait for a lengthy comprehensive legislation. Regulatory agencies can provide initial certainty to the market through explanatory guidelines, policy statements, or staff opinions What does this mean for Hyperliquid? In the past few months, when we discussed the US version of Hyperliquid, we mainly focused on two issues: the licensing HIP-3 to address "who can enter the market", and the PA account control function to address "how securities firms manage customer risk" This opinion letter addresses the third question: What kind of product does stock perpetuity legally belong to? After connecting the three pieces of the puzzle, a possible path to US compliance gradually becomes complete The regulated HIP-3 deployment party is responsible for launching the market, setting parameters, and oracle; Securities firms or builders are responsible for KYC, customer entry, and risk management; HyperCore provides order book, margin, clearing, and settlement services; Perpetual stocks are subject to joint supervision by the SEC and CFTC in accordance with the securities and futures framework HIP-3 has been online for about 10 months, with a cumulative nominal trading volume exceeding $480 billion and open contracts of approximately $4 billion, covering crude oil, precious metals, foreign exchange, stock indices, ETFs, and individual stocks This market has proven with real funds that users have a demand for 24/7 global asset sustainability What is lacking now is not the product, nor the transaction volume But rather a regulatory track that allows these products to legally enter the US market Trump publicly stated that he wants Hyperliquid to enter the United States in a fully compliant and legal manner, addressing political attitudes. License market and account control tools address product structure. This 15 page opinion letter begins to address the legal definition The United States may not need to invent a regulatory system specifically for stock perpetual, it may only need to recognize that stock perpetual is a type of security futures that has no fixed maturity date and relies on funding rates to continuously achieve price convergence Welcome to Hyperliquid HYPE Hyperliquid HIP3 TradeXYZ DeFi