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 “What will the high temperature be in New York City?” 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 “What will the high temperature be in New York City?” contract (Contract). 

This filing is a straightforward modification of Kalshi’s previous “What will the high temperature be in 

New York City?” contract. The changes are as follows:

● The Contract’s Expiration time was changed from 10:00 AM ET to the first 7:00 AM ET or 8:00 

AM ET following the release of data for <date>.

● 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: What will the high temperature be in Chicago?

Ticker: CHIHIGH

Kalshi Contract Category: Weather/climate

Chicago high temperature

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 “What will the high temperature be in Chicago” Contract is a contract relating to the 

high temperature in Chicago. 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. 

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 

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 
KalshiEX LLC

KalshiEX LLC

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 high temperature for Chicago Midway is <greater than/less than/between> 

<degrees> (please see Appendix A for the legally binding terms and conditions), 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
KalshiEX LLC

KalshiEX LLC

APPENDIX A – CONTRACT TERMS AND CONDITIONS

TERMS OF CONTRACTS TRADED ON KALSHI

Official Product Name: What will the high temperature be in Chicago?

Ticker and Rulebook: CHIHIGH
KalshiEX LLC

KalshiEX LLC

CHIHIGH

Scope: These rules shall apply to the contract referred to as CHIHIGH.

Underlying: The Underlying for this Contract is the maximum temperature recorded for the 

specified <date> published in the National Weather Service’s (“NWS”) Daily Climate Report for 

Chicago Midway, Illinois. Revisions to the Underlying made after Expiration will not be taken 

into account.

Instructions: The data can be accessed here:

https://w2.weather.gov/climate/index.php?wfo=lot.Click on Observed Weather, then under 

“Choose a location”, select “Chicago Midway, IL”. Specifically, it is in the section labeled 

“Temperature” in a column titled “Observed Value” and row titled “Maximum”. Temperatures 

are reported in degrees Fahrenheit. As stated on the NWS website, “These data are preliminary” 

and “are subject to revision.” The exchange will use the most recent Daily Climate Report 

available for the location for the data from <date> Data that is revised past the Expiration Date 

and Expiration time of the contract will not be used to determine the Expiration Value of the 

Contract. Revisions made during the statistical period or the period between the Last Trading 

Date and Time and Expiration Date and Expiration time may be taken into account in settling the 

contract. These instructions are provided for convenience only and may be modified or clarified 

at any time. 

Source Agency: The Source Agency is the National Weather Service (“NWS”).

Type: The type of Contract is a Binary 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. 

Degrees: Kalshi may list CHIHIGH contracts with <degrees> levels that fall within an inclusive 

range between a maximum value of 130 degrees Fahrenheit and a minimum value of -40 degrees 

Fahrenheit at consecutive increments of 1 degree. Due to the potential for variability in the 

Underlying, the Exchange may modify <degrees> levels in response to suggestions by Members.

Date: <date> refers to a date specified by Kalshi. Kalshi may list contracts corresponding to 

different statistical periods of <date>. 

Payout Criterion: The Payout Criterion encompasses the Expiration Values that are strictly 

<greater than/less than/between> <degrees>. If the value of <greater than/less than/between> is 
KalshiEX LLC

KalshiEX LLC

“between”, then <degrees> shall be a pair of degrees, and an Expiration Value that is greater 

than or equal to the lower value of the degree pair and less than or equal to the greater value of 

the degree pair are encompassed in the Payout Criterion. If the value of <greater than/less 

than/between> is “greater than”, then the Payout Criterion only encompasses Expiration Values 

that are strictly greater than <degrees> (e.g. if the strike variable values are “greater than” and 

“56 degrees”, then an Expiration Value of 56 degrees is not encompassed in the Payout 

Criterion). If the value of <greater than/less than/between> is “less than”, then the Payout 

Criterion only encompasses Expiration Values that are strictly less than <degrees>.

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 shall be <date> and the Last Trading time will be 

11:59 PM ET.

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

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

Expiration Date: The Expiration Date of the Contract shall be the sooner of the first 7:00 or 

8:00 AM ET following the release of the data for <date>, or one week after <date>. 

Expiration time: The Expiration time of the Contract shall be the sooner of the first 7:00 or 8:00 

AM ET following the release of data for <date>.

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

CHIHIGH

Scope: These rules shall apply to the contract referred to as CHIHIGH.

Underlying: The Underlying for this Contract is the maximum temperature recorded for the

specified <date> published in the National Weather Service’s (“NWS”) Daily Climate Report for

Chicago Midway, Illinois. Revisions to the Underlying made after Expiration will not be taken

into account.

Instructions: The data can be accessed here:

https://w2.weather.gov/climate/index.php?wfo=lot.Click on Observed Weather, then under

“Choose a location”, select “Chicago Midway, IL”. Specifically, it is in the section labeled

“Temperature” in a column titled “Observed Value” and row titled “Maximum”. Temperatures

are reported in degrees Fahrenheit. As stated on the NWS website, “These data are preliminary”

and “are subject to revision.” The exchange will use the most recent Daily Climate Report

available for the location for the data from <date> Data that is revised past the Expiration Date

and Expiration time of the contract will not be used to determine the Expiration Value of the

Contract. Revisions made during the statistical period or the period between the Last Trading

Date and Time and Expiration Date and Expiration time may be taken into account in settling the

contract. These instructions are provided for convenience only and may be modified or clarified

at any time.

Source Agency: The Source Agency is the National Weather Service (“NWS”).

Type: The type of Contract is a Binary 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.

Degrees: Kalshi may list CHIHIGH contracts with <degrees> levels that fall within an inclusive

range between a maximum value of 130 degrees Fahrenheit and a minimum value of -40 degrees

Fahrenheit at consecutive increments of 1 degree. Due to the potential for variability in the

Underlying, the Exchange may modify <degrees> levels in response to suggestions by Members.

Date: <date> refers to a date specified by Kalshi. Kalshi may list contracts corresponding to

different statistical periods of <date>.

Payout Criterion: The Payout Criterion encompasses the Expiration Values that are strictly

<greater than/less than/between> <degrees>. If the value of <greater than/less than/between> is

KalshiEX LLC
KalshiEX LLC

“between”, then <degrees> shall be a pair of degrees, and an Expiration Value that is greater than

or equal to the lower value of the degree pair and less than or equal to the greater value of the

degree pair are encompassed in the Payout Criterion. If the value of <greater than/less

than/between> is “greater than”, then the Payout Criterion only encompasses Expiration Values

that are strictly greater than <degrees> (e.g. if the strike variable values are “greater than” and

“56 degrees”, then an Expiration Value of 56 degrees is not encompassed in the Payout

Criterion). If the value of <greater than/less than/between> is “less than”, then the Payout

Criterion only encompasses Expiration Values that are strictly less than <degrees>.

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 shall be <date> and the Last Trading time will be

11:59 PM ET.

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

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

Expiration Date: The Expiration Date of the Contract shall be the sooner of the first 10:00 AM

ET7:00 or 8:00 AM ET following the release of the data for <date>, or one week after <date>.

Expiration time: The Expiration time of the Contract shall be 10:00 AM ETthe sooner of the

first 7:00 or 8:00 AM ET following the release of data for <date>.

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