November 29, 2023

SUBMITTED VIA CFTC PORTAL

Secretary of the Commission

Office of the Secretariat

U.S. Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: KalshiEX LLC – Petition for Modification of Order of Designation

Dear Sir or Madam,

KalshiEX LLC (“Kalshi” and “Exchange”) hereby submits the attached documents in support of

its petition for modification of its Order of Designation to permit intermediated futures trading.

Included in this submission in addition to this transmittal letter is the Petition and selected

Exhibits to Form DCM (certain of which are confidential) in support of the Petition. A request

for confidential treatment is being submitted under separate cover to the Assistant Secretary for

the Freedom of Information Act. The attached documents are as follows:

Petition for Modification of Kalshi’s Order of Designation

Confidential Exhibit F

Exhibit L

Exhibit M

Exhibit N

Confidential Exhibit O

Confidential Exhibit P

Confidential Exhibit Q

Confidential Exhibit R

Confidential Exhibit S

Exhibit U

Confidential Exhibit V
If you have any questions or comments or require further information, please do not hesitate to

contact me.

Sincerely,

Elie Mishory

Chief Regulatory Officer

KalshiEX LLC

emishory@kalshi.com
COMMODITY FUTURES TRADING COMMISSION

Petition for Modification of Order of Designation

On November 3, 2020, the Commodity Futures Trading Commission issued an

Order of Designation (“Designation Order”) to KalshiEx LLC (the “Exchange”) as a

Designated Contract Market (“DCM”).

The Requested Modification

The Designation Order limited the Exchange to operating solely using a

non-intermediated trading model (“direct trading model”). The Exchange now requests

that the Designation Order be amended to permit futures commission merchants to carry

customer accounts.

The Exchange’s business plan following designation as a contract market was to

concentrate on offering Event Contracts that it would offer directly to Exchange

Members utilizing a direct membership model. As the market in general and the

Exchange have evolved, the Exchange’s business plan is now to increase access to these

products in a manner that will result in a more liquid market that will benefit all market

participants.

Accordingly, the Exchange is petitioning the Commission to modify its Designation

Order to remove the clause prohibiting Kalshi from permitting intermediation so that the

Designation Order will read as follows (underscored text indicates additions, and

overstruck text indicates deletions):

IT IS HEREBY ORDERED, pursuant to Sections 5 and 6(a) of the Act, that the

application of Kalshi for designation as a contract market is approved, subject to the

terms and conditions specified herein:

(1) Kalshi shall comply with all representations and submissions made by Kalshi

in support of its application for designation as a contract market, as shown in the

application record; and

(2) Kalshi shall comply with all provisions of the Act and all requirements set

forth in the Commission's regulations, as may be amended or adopted from time to

time, that are applicable to designated contract markets.; and

(3) Kalshi may not permit any futures commission merchant to intermediate any

transactions or carry accounts for customers executing trades on, or pursuant to the

rules of, the contract market unless the Kalshi Order of Designation has been

amended to permit futures commission merchants to carry customer accounts.

The Requested Modification is Appropriate and in the Public Interest

The modification of the Designation Order being requested will permit Kalshi to allow

futures commission merchants (“FCMs”) to carry customer accounts. This will provide a

significant convenience to potential members who are familiar with a particular interface,
or have established relationships with an FCM.

Further, removing the prohibition on FCMs will allow the Exchange to compete with

other exchanges who allow FCMs, further enhancing the competitive nature of trading

which will both benefit market participants and also advance the CEA’s goal of

promoting fair competition.

Conclusion

Based upon above facts and analysis and the supporting documents incorporated herein,

KalshiEx LLC Petitions the Commodity Futures Trading Commission to modify the

Order of Designation of KalshiEx LLC, issued November 3, 2020, by amending the

language as discussed above.

Respectfully submitted,

Elie Mishory

Chief Regulatory Officer

KalshiEX LLC

emishory@kalshi.com
COMMODITY FUTURES TRADING COMMISSION

FORM DCM

CONTRACT MARKET

APPLICATION OR AMENDMENT TO APPLICATION FOR DESIGNATION

COVER SHEET

KalshiEX LLC

Exact name of Applicant as specified in charter

594 Broadway, Suite 407, New York, New York 10012

Address of principal executive offices

[ ] If this is an APPLICATION for designation, complete in full and check here.

[x ] If this is an AMENDMENT to an application, or to an existing designation, list all

items that are amended and check here.

The following exhibits are amended:

1. F

2. L

3. M

4. N

5. O

6. P

7. Q

8. R

9. S

10.U

11. V

GENERAL INFORMATION

1. Name under which the business of the designated contract market is or will be

conducted, if different than name specified above (include acronyms, if any):

Kalshi

2. If name of designated contract market is being amended, state previous designated

contract market name:

N/A
3. Contact information, including mailing address if different than address specified

above:

N/A

Number and Street

City State Country Zip Code

Main Phone number

N/A

Fax

N/A

Website URL

Kalshi.com

E-mail Address

tarek@kalshi.com

4. List of principal office(s) and address(es) where designated contract market activities

are/will be conducted:

Office Address

Remote

Office 594 Broadway, Suite 407, New York, New York 10012

5. If Applicant is a successor to a previously designated contract market, please

complete the following: N/A

a. Date of succession:

b. Full name and address of predecessor designee

Name

City State Country Zip Code

Main Phone Number Website URL

BUSINESS ORGANIZATION

6. Applicant

is a: [ ]

Corporation
[ ] Partnership

x Limited Liability Company

[ ] Other form of organization (specify)

7. Date of incorporation or formation: December 10, 2019

8. State of incorporation or jurisdiction of organization: Delaware

9. Applicant agrees and consents that the notice of any proceeding before the

Commission in connection with this application may be given by sending such notice

by certified mail to the person named below at the address given.

Tarek Mansour, Chief Executive Officer

Print Name and Title

KalshiEX LLC

Name of Applicant

594 Broadway, Suite 407

Number and Street

New York New York 10012

City State Zip Code

SIGNATURES

10. The Applicant has duly caused this application or amendment to be signed on

its behalf by the undersigned, hereunto duly authorized, this 17th day of, 2023. The

Applicant and the undersigned represent hereby that all information contained herein

is true, current, and complete. It is understood that all required items and Exhibits are

considered integral parts of this Form DCM and that the submission of any

amendment represents that all un-amended items and Exhibits remain true, current,

and complete as previously filed.

KalshiEX LLC

Name of Applicant

/s/ Tarek Mansour

Signature of Duly Authorized Person

Tarek Mansour, Chief Executive Officer

Print Name and Title of Signatory