KalshiEX LLC

August 1, 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 rent in New York City be <above/below/between> <percent> according to

StreetEasy?” 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 rent in New York City be <above/below/between> <percent> according to

StreetEasy?” contract (Contract). The Exchange intends to list the contract on a monthly and annual

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

● <period> (target period)

● <expo_date> (last possible expiration date)

● <percent> (percent increase in rent)

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 rent in New York City be <above/below/between> <percent> according to

StreetEasy?

Rulebook: NYCRENTS

Kalshi Contract Category: Economic/Demographic Measure – Non U.S. Government

Rent in New York City

August 1, 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 rent in New York City be <above/below/between> <percent> according to 

StreetEasy?” Contract is a contract relating to the average rent price in New York City. 

After careful analysis, Kalshi (hereafter referred to as “Exchange”) has determined that 

the Contract complies with its vetting framework. 

Rent prices have skyrocketed in recent months in New York City, as the effects of the 

pandemic have waned. This market is designed to allow people in New York City to 

hedge against increases in their rent. 

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. 

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 signed percent change in rent in New York City in 

<period> according to StreetEasy’s rental index is <above/below/between> <percent>, 

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: Date of Submission 

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: Will rent in New York City be <above/below/between> <percent> 

according to StreetEasy? 

Rulebook: NYCRENTS 

KalshiEX LLC 
KalshiEX LLC

NYCRENTS

Scope: These rules shall apply to this contract. 

Underlying: The Underlying for this Contract is the signed percent change in the StreetEasy 

Rental Index (all bedrooms) in New York City in <period>. The Underlying will be rounded to 

one-hundredth of a percentage point. The Underlying will be rounded to one-hundredth of a 

percentage point. Revisions to the Underlying made after Expiration will not be accounted for in 

determining the Expiration Value. 

Instructions: The data can be accessed 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 StreetEasy. 

Type: The type of Contract is a Binary Contract. 

Issuance : The Contract will be issued both monthly and also per calendar year. 

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

inclusive range between -100 and 500 at consecutive increments of 0.01. Due to the potential for 

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

suggestions by Members. 

<period> : <period> refers to a set of calendar dates specified by Kalshi. These will correspond 

to calendar months and calendar years. 

<expo_date> : <expo_date> refers to a calendar date specified by Kalshi. Kalshi may list 

iterations of the Contract corresponding to different statistical periods of <expo_date>. 

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

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

then <percent> 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. 

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

KalshiEX LLC 
KalshiEX LLC

Last Trading Date: The Last Trading Date of the Contract will be the same as the Expiration 

Date. The Last Trading Time will be the same as the Expiration Time. 

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 first 10:00 AM 

ET following the release of the data for all of <period>, or <expo_date>. 

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