Hyperliquid Policy Center (HPC) and trade.xyz have submitted a joint comment letter to the U.S. Commodity Futures Trading Commission (CFTC), urging the agency to establish a clear path for energy perpetual contracts to enter regulated U.S. markets, according to BlockBeats on Aug. 26.
The letter says trade.xyz is the largest third-party perpetuals market deployer on Hyperliquid. Its WTI crude oil, Brent crude oil, and Henry Hub natural gas markets have generated more than $500 billion in cumulative trading volume since launching in October 2025.
Letter cites weekend market closures during an energy supply disruption
As an example, the filing points to an interruption in energy exports caused by a Middle East conflict in late February this year. During the weekend closure of the U.S. crude futures market, non-U.S. participants were still able to manage risk through oil perpetuals on Hyperliquid, the letter says.
Before traditional benchmark markets reopened, the relevant onchain contracts had already completed roughly two-thirds of the total price discovery between Friday’s close and Sunday’s open, according to the submission.
Perpetuals framed as an alternative to expiring futures
HPC and trade.xyz argue that perpetual contracts have no expiry date, which means businesses do not need to roll positions repeatedly. They also say trading interest can be concentrated in a single order book.
The letter compares contract size in traditional WTI futures with the onchain crude market. A standard WTI futures contract represents 1,000 barrels of oil and, at recent prices cited in the letter, carries a notional value of about $70,000. By contrast, the median trade size in trade.xyz’s oil market during non-traditional trading hours was only about $1,300, which the filing says can better match smaller real-world risk exposures.
Research in the filing focuses on weekend pricing and liquidation handling
According to the research cited in the letter, in nearly 75% of sampled weekend closures, the weekend price of crude oil perpetuals was closer to the Sunday reopening price than the traditional benchmark’s Friday closing price.
The filing also says the quality of CME WTI prices at reopening did not deteriorate materially after the launch of the related contracts.
On liquidations, trade.xyz says 97.9% of notional liquidation value on its market to date has been handled through a standard order-book liquidation mechanism.
Recommendation centers on a technology-neutral regulatory approach
The letter argues that opening the U.S. market to energy perpetuals would not require new legislation. It recommends that the CFTC adopt a technology-neutral, principles-based regulatory framework.
HPC and trade.xyz propose that the regulator confirm exchanges and clearinghouses can operate around the clock as long as they satisfy core principles, clarify timing requirements such as the meaning of a "business day," allow stablecoins and tokenized traditional assets to be used as collateral, and recognize onchain infrastructure for trading, margin management, clearing, settlement, and recordkeeping.