KalshiEX LLC

July 31, 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 U.S. life expectancy be <above/below/between> <count> in <year>?”

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 U.S. life expectancy be <above/below/between> <count> in <year>?”

contract (Contract). The Exchange intends to list the contract on an annual basis. The Contract’s terms

and conditions (Appendix A) includes the following strike conditions:

● <year> (the target year)

● <count> (the target life expectancy)

● <above/below/between>

Along with this letter, Kalshi submits 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 U.S. life expectancy be <above/below/between> <count> in <year>?

Rulebook: LIFEEXP

Kalshi Contract Category: Health/Science

Life Expectancy

July 31, 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 U.S. life expectancy be <above/below/between> <count> in <year>?” Contract 

is a contract relating to changes in life expectancy as measured by the Centers for Disease 

Control and Prevention. After careful analysis, Kalshi (hereafter referred to as 

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

Life expectancy in the United States has fallen two years in a row, in 2020 and 2021, 

mostly due to the coronavirus pandemic. Data for 2022 is expected to be released in 

August 2023, which will provide an important update on the impact and path of life 

expectancy now that excess deaths have fallen to historic levels. Life expectancy has an 

important impact for many firms and financial assets. 

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 

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. 

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 life expectancy is <above/below/between> <count> in 

<year> according to the CDC, 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 31, 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 

KalshiEX LLC 
KalshiEX LLC

APPENDIX A – CONTRACT TERMS AND CONDITIONS 

Official Product Name: Will U.S. life expectancy be <above/below/between> <count> in 

<year>? 

Rulebook: LIFEEXP 

KalshiEX LLC 
KalshiEX LLC

LIFEEXP

Scope: These rules shall apply to this contract. 

Underlying: The Underlying for this Contract is the Centers for Disease Control and 

Prevention’s provisional life expectancy estimate for <year>. Revisions to the Underlying made 

after Expiration will not be accounted for in determining the Expiration Value. 

Instructions: The Underlying can be found here under “Special Reports”. In the provision life 

expectancy report, the relevant number is at the intersection of age zero and “total”. For 2021, 

this number was 76.1 years. 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 the Centers for Disease Control and Prevention. 

Type: The type of Contract is an Event Contract. 

Issuance: The Contract will be listed on an annual basis. 

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

inclusive range between 0 and 200 at consecutive increments of <count>. Due to the potential for 

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

suggestions by Members. 

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

Contract corresponding to variations of <year>. 

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

are <above/below/between> <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 day before the expected 

release of the data, which can be found on the website of the CDC. Here is the schedule for 2023. 

The Last Trading Time will be 11:59 PM ET. 

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 sooner of the date of the first 

10:00 AM ET following the release of data for all of <year>, or one year after <year> has ended. 

Expiration time: The Expiration time of the Contract shall be 10:00 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