Asset manager Grayscale has submitted a new S-1 registration statement to the U.S. Securities and Exchange Commission for a Hyperliquid exchange-traded fund, moving another step closer to launching a product tied to the blockchain network. The filing, made public this week, comes alongside a certification letter from Nasdaq, which signed off on the application on May 27.
The S-1 filing and what it covers
The S-1 is the standard SEC form for registering a new security. Grayscale’s latest filing proposes a fund that would track the price of Hyperliquid’s native token, though the filing does not specify a ticker or a target launch date. The document outlines the fund’s structure, custody arrangements, and risk factors — the same kind of detail the SEC expects for any ETF seeking to list on a national exchange.
Grayscale has filed for several crypto ETFs before, including for bitcoin and ether, and has both won and lost SEC approvals. This Hyperliquid ETF is the firm’s first attempt at a fund tied to the Hyperliquid ecosystem, a layer-1 blockchain focused on decentralized trading.
Nasdaq’s accreditation step
Nasdaq, the exchange where Grayscale wants to list the Hyperliquid ETF, issued a certification letter on May 27 as part of the application process. The letter essentially verifies that the exchange has reviewed Grayscale’s proposal and considers it compliant with Nasdaq’s listing rules. While the certification doesn’t guarantee SEC approval, it’s a procedural requirement — the SEC typically expects an exchange to confirm a product meets its standards before regulators rule on the S-1.
The certification means Nasdaq is ready to support the fund if the SEC greenlights it. The exchange has previously listed other Grayscale crypto ETFs, including the Grayscale Bitcoin Trust after its conversion to an ETF.
What the SEC will weigh
The SEC now has a 45-day review window for the S-1, which can be extended. The agency will evaluate whether the Hyperliquid ETF meets investor-protection standards, including surveillance-sharing agreements, custody of the underlying tokens, and the potential for market manipulation. Hyperliquid’s blockchain is relatively new compared to bitcoin or ethereum, which could raise questions about liquidity and price discovery.
Grayscale’s filing acknowledges those risks. The document notes that Hyperliquid’s token market may be less regulated than major cryptocurrencies, and that the fund could face volatility. The company has also proposed using a third-party custodian for the tokens, a common feature in crypto ETFs.
The SEC has not yet signaled its stance on Hyperliquid-based products. The agency has approved ETFs tied to bitcoin and ether futures, and recently allowed spot bitcoin ETFs, but has been cautious about smaller or less-established tokens.
The next concrete milestone is the SEC’s initial comment letter on the S-1, which typically comes within weeks. If the agency asks for revisions, the clock resets. Grayscale has not said when it expects a final decision.
