92%—that’s how much the spot-trading volume at Bullish has dropped since its August 2022 peak, according to CoinGecko. So why on earth is the exchange sprinting toward a U.S. IPO now, of all times?
Here's What Actually Happened
I’ve been poking around SEC filings and late-night message boards ever since Tom Farley—yes, the same Tom who once rang the NYSE opening bell—quietly sent in a confidential S-1 for Bullish just before Christmas. The Financial Times broke the surface story: Peter Thiel-backed crypto exchange Bullish has filed for a U.S. IPO. But the FT piece was thin on numbers, and everyone on Crypto Twitter seemed too busy celebrating the ETF approvals to care.
In my experience, when the street ignores a filing this size, something interesting is hiding in the footnotes. So I pulled the breadcrumbs together:
- Entity: Bullish Global, registered in the Cayman Islands, wholly owned by Block.one.
- Backers: Peter Thiel, Alan Howard, Louis Bacon, Mike Novogratz (via Galaxy), and a smattering of sovereign wealth funds out of Abu Dhabi.
- Products: A hybrid order book/AMM exchange running on its custom EOSIO fork, targeting institutions.
- Attempted SPAC: A $9B deal with Far Peak Acquisition fell apart December 2022 after the SEC dragged its feet.
That last bullet is where my eyebrows shot up. Farley ran the shell that tried to take Bullish public the first time. The SEC never signed off, so they killed the deal. Now he’s trying again—same asset, same regulators—only months after Chair Gensler sued Coinbase and Binance. Either Farley knows something we don’t, or he’s betting on a political sea change. Cue the Trump comeback chatter.
January Was Weird—And Then It Got Weirder
Right after New Year’s, Bitcoin ripped past $45k on ETF enthusiasm. The next day, Bullish’s IPO chatter leaks. Two days later, Trump tells a New Hampshire crowd he’s “very pro-crypto, unlike Biden.” Is that correlation or causation? I won’t claim a smoking gun, but timing matters in markets—and in politics.
Digging deeper, I found Bullish’s internal financial slide deck that made the rounds in Telegram VC channels last quarter. If the numbers are legit (grain of salt), the firm booked $262M in net income the first half of 2023, mostly from market-making on its own venue. Compare that to Coinbase, which bled nearly $357M in the same window. On paper, Bullish looks like a cash machine. But here’s the kicker—daily active users rarely crack 5,000. That’s smaller than most Solana meme-coin swaps.
The Liquidity Mirage
I couldn’t wrap my head around those profit margins until I spoke with a former Bullish quant who left last fall. Over Signal he told me,
“The book is 80% internal flow. We quote both sides, collect maker rebates, and recycle the EOS-based BLP token incentives. Retail isn’t the clientele.”
Translation: Bullish may be trading mostly with itself—think Binance’s internalized market-making desks circa 2020. That can goose volume numbers and P&Ls but isn’t exactly the organic demand Wall Street analysts like to model.
Connecting Dots the Press Release Ignored
Two names keep resurfacing: Peter Thiel and Palantir. Thiel’s data-mining behemoth already sells AML dashboards to federal agencies. Palantir happens to be ramping up its finance vertical, pitching “anti-dark-pool surveillance tools” to exchanges. If Bullish lands a U.S. listing, it’ll have to appease FINRA, the CFTC, and maybe the Fed if it touches stablecoins. Who better than Palantir to lubricate that process? I can’t prove a formal agreement, but insiders at Palantir’s NYC office told me last week they’re “staffing up for a big crypto KYC engagement.”
Is this why Thiel’s pushing the IPO now—lock in a dual revenue play (exchange + compliance SaaS) before a potential Republican administration eases the regulatory chokehold? It smells like classic Thiel: get a head start, then lobby for friendlier rules once you’re embedded.
Why This Matters for Your Portfolio
Most retail traders care about tickers, not cap tables. But IPO filings can reveal sector sentiment long before charts do. Bullish’s move signals three things to me:
- VC Exit Liquidity Is Back: Thiel’s Founders Fund wants a liquid path out. If underwriters bite, watch for a queue: Kraken, Galaxy (again), maybe even ConsenSys.
- Regulatory Temperature Check: A successful Bullish listing would imply the SEC’s ice is thawing—or that the political winds make enforcement risk tolerable.
- Retail Narratives Lag: CT influencers pump ETFs, but the real whales eye IPO pipelines. Follow the suits, not the memes.
Quick Tangent: Remember EOS?
I can’t mention Bullish without recalling EOS’s $4B ICO back in 2018—still the largest token raise ever. Block.one paid a $24M SEC fine (basically tip money) and walked away. Five years later, that war chest still bankrolls ventures like Bullish. Whenever someone says ICOs were a bubble, I point to Thiel and laugh—bubbles are only fatal if you’re late.
Back to the Present—The Underwriters’ Dilemma
Rumor mill says Goldman Sachs and Citigroup are in early talks to co-lead. Makes sense: both banks refused to touch Binance’s ill-fated $1B rescue fund, yet they’re hungry for fee income after a brutal 2023 IPO drought. But underwriting a Cayman-registered crypto exchange with limited U.S. users? That’s a reputational roll of the dice.
One ECM banker (who’d only talk after I promised anonymity) framed it this way:
“We’ll price anything if the comps exist. Coinbase is up 380% YoY; that’s the only comp we need.”
He’s not wrong—COIN closed above $180 last week, its highest since April 2022. Bankers smell underwriting fees like sharks smell blood.
So, What’s the Valuation?
During the SPAC era, Bullish pitched $9B. No shot it gets that today. My back-of-the-napkin DCF (yes, I still run Excel models at 2 a.m.) suggests $2.5-3B if we slap a 6x multiple on projected 2024 EBITDA—optimistic given the user metrics, but plausible if Bitcoin stays north of $40k and option greeks keep juicing volumes.
For context, Coinbase trades at ~7.2x forward EBITDA, while smaller Asian exchanges like Upbit hover around 4x (private market whispers). Bullish’s lack of retail stickiness and venue risk probably nets a discount.
What Could Go Wrong?
- Regulatory Ambush: Gensler could wake up cranky, re-file the same questions that killed the SPAC.
- Liquidity Drain: If internal market-making dries up, net income nosedives and the IPO narrative collapses.
- Trump Fades: A Biden re-election or a strong anti-crypto VP pick (think Liz Warren) could spook Wall Street compliance desks.
The Part No One’s Talking About
I keep circling back to custody. Bullish self-custodies on its EOS fork—fine offshore, but the SEC prefers SOC-2 audited third-party custodians like Coinbase Custody or BitGo. If Bullish fumbles that migration, even mid-roadshow, institutional buy-side PMs will balk. And retail? They’re already scarred post-FTX; good luck convincing them to wire fresh USD to a name they’ve barely heard.
Final Thought Before I Close My Tabs
I’m not rooting against Bullish; I’m just allergic to half-told stories. When a low-volume exchange floats a mega-valuation IPO months after regulators kneecapped its competitors, I can’t help but sniff around. Maybe Farley orchestrates a masterclass in regulatory wrangling and the stock doubles out the gate—stranger things have happened (see: Trump SPAC DWAC). Or maybe we’re watching the last gasp of 2017 ICO money trying to find a new home before the next cycle resets.
Either way, I’ll be the nerd refreshing EDGAR the second that confidential filing flips public. And yes, I already set my TweetDeck column for $BULL just in case the ticker sticks.
Until then, keep your hot wallets close and your S-1s closer.
