KalshiEX LLC

July 20, 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 – CFTC Regulation 40.2(a) Notification Regarding the Initial Listing

of the “Will USD/RUB be <above/below> <count> by <date>?” Contract

Dear Sir or Madam,

Pursuant to Section 5c(c) of the Commodity Exchange Act and Section 40.2(a) of the regulations of the

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

it is self-certifying the “Will USD/RUB be <above/below> <count> by <date>?” contract (Contract). The

Contract’s terms and conditions (Appendix A) includes the following strike conditions:

● <above/below>

● <count> (the currency ratio)

● <date> (the target date)

Along with this letter, Kalshi submitted the following documents:

● A concise explanation and analysis of the Contract;

● Certification;

● Appendix A with the Contract’s Terms and Conditions;

● Confidential Appendices with further information; and

● A request for FOIA confidential treatment.

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

Sincerely,

Xavier Sottile

Head of Markets

KalshiEX LLC

xsottile@kalshi.com

KalshiEX LLC 
KalshiEX LLC

KalshiEX LLC

Official Product Name: Will USD/RUB be <above/below> <count> by <date>?

Ticker: USDRUBMINMAX

Kalshi Contract Category: Commodity

USD/RUB long-term

July 20, 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 USD/RUB be <above/below> <count> by <date>?” Contract is a contract 

relating to the reported value of the U.S. dollar’s exchange rate with the Russian ruble by 

Intercontinental Exchange (“ICE”). After careful analysis, Kalshi (hereafter referred to as 

“Exchange”) has determined that the Contract complies with its vetting framework. 

The foreign exchange rate of the U.S. dollar to the Russian ruble is a highly salient issue 

to contemporary businesses. ICE is one of the pre-eminent suppliers of public data on the 

over-the-counter spot exchange rate, critical to making business, investment, and hedging 

decisions by firms and especially by retail. Modern firms produce goods and services 

with incredibly complex supply chains, often across dozens of different countries. 

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 binary 

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 

KalshiEX LLC 
KalshiEX LLC

contracts 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. Changes to the Source Agency can be made via a Part 40 contract amendment. 

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 USD/RUB is <above/below> <count> between Issuance and <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: Xavier Sottile 

Title: Head of Markets 

Date: July 20, 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 

TERMS OF CONTRACTS TRADED ON KALSHI 

Official Product Name: Will USD/RUB be <above/below> <count> by <date>? 

Rulebook: USDRUBMINMAX 

KalshiEX LLC 
KalshiEX LLC

USDRUBMINMAX 

Scope: These rules shall apply to this contract. 

Underlying: The Underlying for this Contract is the set of daily open prices at 10:00 AM ET for 

USD/RUB price for each market day between Issuance and <date> according to Intercontinental 

Exchange (“ICE”). Revisions to the Underlying made after Expiration will not be accounted for 

in determining the Expiration Value. 

Instructions: ICE’s real-time data on currency ratios can be accessed at a variety of public 

sources, including here . 

1 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 

real-time basis. The Contract will be issued on an annual basis. 

<count>: Kalshi may list iterations of the Contract with <count> at consecutive increments of 

0.00001. Due to the potential for variability in the Underlying, the Exchange may modify 

<count> 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 variations of <date>. 

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

contain a value that is <above/below> <count>. 

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

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 the sooner of the first 10:00 

AM ET following the occurrence of an event encompassed by the Payout Criterion or <date>. 

The Last Trading Time will be 10:00 AM ET. 

1 https://www.tradingview.com/symbols/USDRUB/?exchange=FX_IDC

KalshiEX LLC 
KalshiEX LLC

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 first 11:00 AM ET following 

the occurrence of an event encompassed by the Payout Criterion, the first 11:00 AM ET after the 

release of data for <date>, or one week after <date>. 

Expiration time: The Expiration time of the Contract shall be 11:00 AM ET. 

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. 

KalshiEX LLC