KalshiEX LLC

September 25, 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 40.6 Amendment Regarding Contracts whose 

Source Agencies may be affected by a lapse in federal government appropriations 

Dear Sir or Madam, 

KalshiEX LLC (Kalshi) is filing a product rule regarding contracts whose Source Agencies may 

be affected by a lapse in federal government appropriations. An extended period of government 

shutdown could delay release of major scheduled economic and other data by federal 

government agencies, such as the inflation rate as published by the Bureau of Labor Statistics. 

Kalshi offers event contracts on a number of these data releases (e.g. what the inflation rate will 

be in September 2023). These contracts cease trading prior to the expected release of the data, 

and provide a backstop of, at minimum, one week for issues that could delay the underlying data. 

Agencies have discussed this issue and it has been reported in the major business press. Without 

a change, all contracts will settle to “No” if no data is released by the latest Expiration Date. 

However, Kalshi has in place Rule 7.2 in its Rulebook which permits it to change contract 

specifications in the case of an event that affects the reliability of the Source Agency. 

To that end, Kalshi is adopting a rule that provides for all contracts that: “In the case of a delay in 

data caused by a federal government shutdown impacting the reliability of the Source Agency, 

the market’s latest Expiration Date will be extended to the sooner of the release of the 

Underlying or six months after the end of the government shutdown.” The six months following 

the end of the shutdown which delayed data originally is to provide more than enough time for 

agencies to release data for the relevant period, and to ensure that the contract does not extend 

beyond a reasonable time. Notice of this change will be prominently posted on the Kalshi 

website. 

Compliance with Core Principles 

KalshiEX LLC 
KalshiEX LLC

This change complies with the Core Principles. The contingency will not increase the Contracts’ 

susceptibility to manipulation, per Core Principle 3; if anything, this will reduce the Contracts’ 

susceptibility to manipulation by reducing the ability of a separate action (a government 

shutdown) to affect the value of the Contracts. It also complies with Core Principle 4. This rule 

will reduce disruption by reducing uncertainty regarding Contract outcome due to an event 

unrelated to the core of the Underlying (e.g. the inflation rate). 

The changes in this filing similarly comply with the remaining Core Principles, the Commodity 

Exchange Act and Regulations thereunder. 

Accordingly, Kalshi certifies that this rule complies with the Commodity Exchange Act and 

Regulations thereunder, and a notice of pending certification with the Commission and a copy of 

the submission, concurrent with the filing of a submission with the Commission, was posted on 

the Kalshi’s website. No opposing views were expressed to Kalshi by its governing board or 

committee members, members of the entity or market participants. 

Kalshi intends to implement the changes described in this filing ten business days following the 

filing, as noted on the attached filing cover page. 

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

contact me. 

Sincerely, 

Xavier Sottile 

Head of Markets 

KalshiEX LLC 

xsottile@kalshi.com 

Enclosures: 

Appendix A - Contracts that may be affected by a lapse in federal government appropriations 

KalshiEX LLC 
KalshiEX LLC

APPENDIX A

Contracts that may be affected by a lapse in federal government

appropriations

The following Contracts use the Bureau of Labor Statistics, Bureau of Economic Analysis, or 

U.S. Census Bureau as Source Agencies, and thus their data releases may be affected by an 

extended lapse in federal government appropriations: 

- Will the Consumer Price Index (CPI) increase more than <percent>? (“CPI”) 

- Will real GDP <increase/decrease> by more than <percent>? (“GDP”) 

- Will the price of apparel change by <above/below/between> <percent> in 

- <period>? (“CPIAPPAREL”) 

- Will the price of used cars and trucks change by <above/below/between> 

- <percent> in <period>? (“USEDCAR”) 

- Will the price of food change by <above/below/between> <percent> in 

- <period>? (“CPIFOOD”) 

- Will core CPI growth be <above/below/between> <percent> in <month>? (“CORECPI”) 

- Will core inflation be <above/below/between> <percent> for the 12 months 

- ending <month>? (“YOYCPICORE”) 

- Will year-over-year inflation for the year ending <month> be 

- <above/below/between> <percent>? (“YOYCPI”) 

- Will PPI growth be <above/below/between> <percent> in <period>? (“PPI”) 

- Will core Personal Consumption Expenditures price index inflation be 

<above/below/between> <percent> in <month>? (“COREPCE”) 

- Will nonfarm payroll change be <above/below/between> <count>? (“PAYROLLS”) 

- Will the unemployment rate (U-3) be above <percent>? (“U3”) 

- Will retail sales be <above/below/between> <percent> in <month>? (“RETAIL”) 

- Will any quarterly U.S. GDP growth be <above/below> <percent> this year? (“LGDP”) 

- Will any monthly U.S. unemployment rate be <above/below> <percent> this year? 

(“LU3”) 

- Will any monthly U.S. inflation be <above/below> <percent> this year? (“LCPI”) 

- Will there be an official recession in <period>? (“NBERRECSS”) 

- Will the PPI value for semiconductors be <above/below> <value> in <month>? 

(“SEMIPPI”) 

KalshiEX LLC