KalshiEX LLC

KalshiEX LLC

April 26, 2023

SUBMITTED VIA CFTC PORTAL 

Secretary of the Commission 

Office of the Secretariat 

U.S. Commodity Futures Trading Commission 

Three Lafayette Center 

1155 21st Street, N.W. 

Washington, D.C. 20581 

Re: KalshiEX LLC – CFTC Regulation 40.6 Notification Regarding the Amendment of 

the “Will the settle price of WTI crude oil futures be <above/below/between> <price> 

for <date>?” Contract

Dear Sir or Madam, 

Pursuant to Section 5c(c) of the Commodity Exchange Act and Section 40.6 of the regulations of the 

Commodity Futures Trading Commission, KalshiEX LLC (Kalshi) hereby notifies the Commission that 

it is amending the “Will the settle price of WTI crude oil futures be <above/below/between> <price> for 

<date>?” contract (Contract). 

This filing is a straightforward modification of Kalshi’s previous “Will the settle price of WTI crude oil 

futures be <above/below/between> <price> for <date>?” contract. The changes are as follows:

● The Contract’s Expiration time was changed from 7:55 PM ET to be the sooner of the first 6:00 

PM, 6:30 PM, 7:00 PM, 7:30 PM, or7:55 PM ET following the data release in order to reduce 

settlement times for Members.

● The Contract’s Expiration Date was also changed to reflect this.

Along with this letter, Kalshi submits the following documents:

● A clean copy of the amended Contract; and 

● A redline showing the changes to Appendix A, the product rules and terms and conditions of the 

contract.

If you have any questions, please do not hesitate to contact me. 

Sincerely, 

Elie Mishory

Chief Regulatory Officer 

KalshiEX LLC 

emishory@kalshi.com
KalshiEX LLC

KalshiEX LLC

KalshiEX LLC

Official Product Name: Will the settle price of WTI crude oil futures be <above/below/between> <price> for 

<date>?

Rulebook: WTIOIL

Kalshi Contract Category: Commodity

WTI Oil Future price

April 26, 2023

CONCISE EXPLANATION AND ANALYSIS OF THE PRODUCT AND ITS 

COMPLIANCE WITH APPLICABLE PROVISIONS OF THE ACT, INCLUDING 

CORE PRINCIPLES AND THE COMMISSION'S REGULATIONS THEREUNDER

Pursuant to Commission Rule 40.2(a)(3)(v), the following is a concise explanation and analysis of 

the product and its compliance with the Act, including the relevant Core Principles, and the 

Commission's regulations thereunder.

I. Introduction

The “Will the settle price of WTI crude oil futures be <above/below/between><price> for 

<date>?” Contract is a contract relating to the future price of crude oil. After careful 

analysis, Kalshi (hereafter referred to as “Exchange”) has determined that the Contract 

complies with its vetting framework, which has been reviewed by the CFTC and formed 

part of the Exchange’s application for designation as a Contract Market (“DCM”) that was 

approved by the Commission. 

West Texas Intermediate, a form of sweet (or light) crude oil, is the benchmark of oil 

pricing in the United States. 

Further information about the Contract, including an analysis of its risk mitigation and 

price basing utility, as well as additional considerations related to the Contract, is included 

in Confidential Appendices B, C, and D.

Pursuant to Section 5c(c) of the Act and CFTC Regulations 40.2(a), the Exchange hereby 

certifies that the listing of the Contract complies with the Act and Commission regulations 

under the Act.

General Contract Terms and Conditions: The Contract operates similar to other event 

contracts that the Exchange lists for trading. The minimum price fluctuation is $0.01 (one 

cent). Price bands will apply so that Contracts may only be listed at values of at least $0.01 

and at most $0.99. Further, the Contract is sized with a one-dollar notional value and has a 

minimum price fluctuation of $0.01 to enable Members to match the size of the contracts 
KalshiEX LLC

KalshiEX LLC

purchased to their economic risks. The Exchange has further imposed position limits 

(defined as maximum loss exposure) of $25,000 USD on the Contract. As outlined in Rule 

5.12 of the Rulebook, trading shall be available at all times outside of any maintenance 

windows, which will be announced in advance by the Exchange. Members will be charged 

fees in accordance with Rule 3.6 of the Rulebook. Fees are charged in such amounts as 

may be revised from time to time to be reflected on the Exchange’s Website. Additionally, 

as outlined in Rule 7.2 of the Rulebook, if any event or any circumstance which may have 

a material impact on the reliability or transparency of a Contract’s Source Agency or the 

Underlying related to the Contract arises, Kalshi retains the authority to designate a new 

Source Agency and Underlying for that Contract and to change any associated Contract 

specifications after the first day of trading. That new Source Agency and Underlying would 

be objective and verifiable. Kalshi would announce any such decision on its website. All 

instructions on how to access the Underlying are non-binding and are provided for 

convenience only and are not part of the binding Terms and Conditions of the Contract. 

They may be clarified at any time. Furthermore, the Contract’s payout structure is 

characterized by the payment of an absolute amount to the holder of one side of the option 

and no payment to the counterparty. During the time that trading on the Contract is open, 

Members are able to adjust their positions and trade freely. After trading on the Contract 

has closed, the Expiration Value and Market Outcome are determined. The market is then 

settled by the Exchange, and the long position holders and short position holders are paid 

according to the Market Outcome. In this case, “long position holders” refers to Members 

who purchased the “Yes” side of the Contract and “short position holders” refers to 

Members who purchased the “No” side of the Contract. If the Market Outcome is “Yes,” 

meaning that the settle price of front-month WTI oil is <above/below/between> <price> 

for <date>, then the long position holders are paid an absolute amount proportional to the 

size of their position and the short position holders receive no payment. If the Market 

Outcome is “No,” then the short position holders are paid an absolute amount proportional 

to the size of their position and the long position holders receive no payment. Specification 

of the circumstances that would trigger a Market Outcome of “Yes” are included below in 

the section titled “Payout Criterion” in Appendix A. 
KalshiEX LLC

KalshiEX LLC

CERTIFICATIONS PURSUANT TO SECTION 5c OF THE COMMODITY 

EXCHANGE ACT, 7 U.S.C. § 7A-2 AND COMMODITY FUTURES TRADING 

COMMISSION RULE 40.2, 17 C.F.R. § 40.2

Based on the above analysis, the Exchange certifies that:

❏ The Contract complies with the Act and Commission regulations thereunder.

❏ This submission (other than those appendices for which confidential treatment has been 

requested) has been concurrently posted on the Exchange’s website at 

https://kalshi.com/regulatory/filings. 

Should you have any questions concerning the above, please contact the exchange at 

ProductFilings@kalshi.com. 

______________________

By: Eliezer Mishory

Title: Chief Regulatory Officer 

Date: April 26, 2023
KalshiEX LLC

KalshiEX LLC

Attachments:

Appendix A - Contract Terms and Conditions

Appendix B (Confidential) - Further Considerations

Appendix C (Confidential) - Source Agency

Appendix D (Confidential) - Compliance with Core Principles

Appendix E (Confidential) - Agreement with ICE Data Services
KalshiEX LLC

KalshiEX LLC

APPENDIX A – CONTRACT TERMS AND CONDITIONS

Official Product Name: Will the settle price of the front-month WTI crude oil future be 

<above/below/between><price> for <date>?

Rulebook: WTIOIL
KalshiEX LLC

KalshiEX LLC

WTIOIL

Scope: These rules shall apply to this contract.

Underlying: The Underlying for this Contract is the settle price of Intercontinental Exchange’s 

(“ICE”) front-month West Texas Intermediate (“WTI”) Light Sweet Crude Future for <date> 

Revisions to the Underlying made after Expiration will not be accounted for in determining the 

Expiration Value.

Instructions: The Underlying can be found here and selecting “T-West Texas Intermediate Light 

Sweet Crude Future”. After accessing the report file for <date>, the Underlying is the number 

under ‘SETTLE’ and ‘PRICE’ for the first month listed. The settlement price can also be accessed 

to a variety of public sources, including from the Energy Information Administration homepage 

here. These instructions on how to access the Underlying are provided for convenience only and 

are not part of the binding Terms and Conditions of the Contract. They may be clarified at any 

time. 

Source Agency: The Source Agency is ICE.

Type: The type of Contract is an Event Contract.

Issuance: The Contract is based on the outcome of a recurrent data release, which is issued on a 

daily basis. Thus, Contract iterations will be issued on a recurring basis, and future Contract 

iterations will generally correspond to the next day, month, and year. 

<price>: Kalshi may list iterations of the Contract with <price> levels that fall within an inclusive 

range between -5,000 and 5,000 at consecutive increments of 0.01. Due to the potential for 

variability in the Underlying, the Exchange may modify <price> levels in response to suggestions 

by Members.

<date>: <date> refers to a calendar date specified by Kalshi. Kalshi may list iterations of the 

Contract corresponding to different statistical periods of <date>.

Payout Criterion: The Payout Criterion for the Contract encompasses the Expiration Values that 

are <above/below/between> <price>. If the value of <above/below/between> is “between”, then 

<price> shall be a pair of values and the Payout Criterion encompasses Expiration Values that are 

greater than or equal to the lesser of the pair, and less than or equal to the greater of the pair. 

Minimum Tick: The Minimum Tick size for the referred Contract shall be $0.01.
KalshiEX LLC

KalshiEX LLC

Position Limit: The Position Limit for the $1 referred Contract shall be $25,000 per Member.

Last Trading Date: The Last Trading Date of the Contract will be <date>. The Last Trading Time 

will be 2:30 PM ET. 

Settlement Date: The Settlement Date of the Contract shall be no later than the day after the 

Expiration Date, unless the Market Outcome is under review pursuant to Rule 7.1.

Expiration Date: The Expiration Date of the Contract shall be the sooner of the date of the first 

6:00 PM, 6:30 PM, 7:00 PM, 7:30 PM, or 7:55 PM ET after the data has been released, or one 

week following <date>. 

Expiration time: The Expiration time of the Contract shall be the sooner of the first 6:00 PM, 

6:30 PM, 7:00 PM, 7:30 PM, or 7:55 PM ET following the data release.

Settlement Value: The Settlement Value for this Contract is $1.00.

Expiration Value: The Expiration Value is the value of the Underlying as documented by the 

Source Agency on the Expiration Date at the Expiration time. 

Contingencies: Before Settlement, Kalshi may, at its sole discretion, initiate the Market Outcome 

Review Process pursuant to Rule 6.3(c) of the Rulebook. Additionally, as outlined in Rule 7.2 of 

the Rulebook, if any event or any circumstance which may have a material impact on the reliability 

or transparency of a Contract’s Source Agency or the Underlying related to the Contract arises, 

Kalshi retains the authority to designate a new Source Agency and Underlying for that Contract 

and to change any associated Contract specifications after the first day of trading.
KalshiEX LLC

WTIOIL

Scope: These rules shall apply to this contract.

Underlying: The Underlying for this Contract is the settle price of Intercontinental Exchange’s

(“ICE”) front-month West Texas Intermediate (“WTI”) Light Sweet Crude Future for <date>

Revisions to the Underlying made after Expiration will not be accounted for in determining the

Expiration Value.

Instructions: The Underlying can be found here and selecting “T-West Texas Intermediate Light

Sweet Crude Future”. After accessing the report file for <date>, the Underlying is the number

under ‘SETTLE’ and ‘PRICE’ for the first month listed. The settlement price can also be

accessed to a variety of public sources, including from the Energy Information Administration

homepage here. These instructions on how to access the Underlying are provided for

convenience only and are not part of the binding Terms and Conditions of the Contract. They

may be clarified at any time.

Source Agency: The Source Agency is ICE.

Type: The type of Contract is an Event Contract.

Issuance: The Contract is based on the outcome of a recurrent data release, which is issued on a

daily basis. Thus, Contract iterations will be issued on a recurring basis, and future Contract

iterations will generally correspond to the next day, month, and year.

<price>: Kalshi may list iterations of the Contract with <price> levels that fall within an

inclusive range between -5,000 and 5,000 at consecutive increments of 0.01. Due to the potential

for variability in the Underlying, the Exchange may modify <price> levels in response to

suggestions by Members.

<date>: <date> refers to a calendar date specified by Kalshi. Kalshi may list iterations of the

Contract corresponding to different statistical periods of <date>.

Payout Criterion: The Payout Criterion for the Contract encompasses the Expiration Values that

are <above/below/between> <price>. If the value of <above/below/between> is “between”, then

<price> shall be a pair of values and the Payout Criterion encompasses Expiration Values that are

greater than or equal to the lesser of the pair, and less than or equal to the greater of the pair.

Minimum Tick: The Minimum Tick size for the referred Contract shall be $0.01.

KalshiEX LLC
KalshiEX LLC

Position Limit: The Position Limit for the $1 referred Contract shall be $25,000 per Member.

Last Trading Date: The Last Trading Date of the Contract will be <date>. The Last Trading

Time will be 2:30 PM ET.

Settlement Date: The Settlement Date of the Contract shall be no later than the day after the

Expiration Date, unless the Market Outcome is under review pursuant to Rule 7.1.

Expiration Date: The Expiration Date of the Contract shall be the sooner of the date of the first

6:00 PM, 6:30 PM, 7:00 PM, 7:30 PM, or 7:55 PM ET after the data has been released, or one

week following <date>.

Expiration time: The Expiration time of the Contract shall be the sooner of the first 6:00 PM,

6:30 PM, 7:00 PM, 7:30 PM, or 7:55 PM ET following the data release.

Settlement Value: The Settlement Value for this Contract is $1.00.

Expiration Value: The Expiration Value is the value of the Underlying as documented by the

Source Agency on the Expiration Date at the Expiration time.

Contingencies: Before Settlement, Kalshi may, at its sole discretion, initiate the Market

Outcome Review Process pursuant to Rule 6.3(c) of the Rulebook. Additionally, as outlined in

Rule 7.2 of the Rulebook, if any event or any circumstance which may have a material impact on

the reliability or transparency of a Contract’s Source Agency or the Underlying related to the

Contract arises, Kalshi retains the authority to designate a new Source Agency and Underlying

for that Contract and to change any associated Contract specifications after the first day of

trading.

KalshiEX LLC