CFTC Regulation 40.2(a) Notification Regarding the Initial Listing of the “Will <party> hold <above/below/exactly/at least/at most/between> <count> seats in the House of Representatives of Connecticut after the November 3, 2026, general…

KalshiEX LLC · received by the CFTC 26 October 2026 · the filing (PDF)

Summary

Warrant Check read 5 operative provisions in this filing. Across them, 15 of 30 checks are present, 3 partial and 12 absent. 1 provision has every check present. 1 rule on who may trade is not a settlement term and is left out.

15 present3 partial12 absent

What the wording addresses

Roster-based seat count determines Payout Criterion — every check present.
“A seat is held by the person whom the official”
Source Agency hierarchy resolves conflicting reports: Defined Benchmark, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“the hierarchy set out in Source Agency above will govern”
Correction governs only if Exchange finds 'material error': Comprehensive Coverage, Relevant Timeline.
“the Exchange determines, in its sole discretion, that the correction remedies”
No-data fallback to 'last fair price': Comprehensive Coverage, Relevant Timeline.
“all markets will resolve to the last fair price”
Death/violence/terrorism contingency settlement: Comprehensive Coverage.
“Kalshi may, in its sole discretion, settle the Contract at the last”

What the wording leaves open

Source Agency hierarchy resolves conflicting reports “the hierarchy set out in Source Agency above will govern”
- Independent Verification — Partial: Named sources include official records (CGA, SOTS) but also news outlets (AP, Bloomberg, etc.); the latter are receivable documents but not official/neutral in the same sense.
- Suitable Method — Partial: The hierarchy can resolve a clear conflict between ranked sources, but 'continuing ambiguity or dispute' is pushed to Kalshi's unstructured discretion under Rule 7.1, which is not a checkable procedure.
- Relies on material referred to but not in the public filing.
What would close it: Replace reliance on Kalshi's unguided discretion for 'continuing ambiguity' with an objective tiebreaker (e.g., always defer to the next-ranked source with no residual discretion); include Rule 7.1 procedures in the certified text.
Correction governs only if Exchange finds 'material error' “the Exchange determines, in its sole discretion, that the correction remedies”
- Independent Verification — Absent: The determination rests entirely on the Exchange's own sole discretion, not on any named third-party-receivable evidence or test.
- Suitable Method — Absent: Unstructured sole discretion cannot establish a checkable factual claim about materiality of an error.
- Defined Benchmark — Absent: No threshold or definition of 'material error' is given beyond the Exchange's own judgment.
- Conclusive Link — Absent: no named standard - entailment cannot be assessed
What would close it: Define an objective materiality standard (e.g., a correction altering the seat count or party outcome) rather than unguided Exchange discretion.
No-data fallback to 'last fair price' “all markets will resolve to the last fair price”
- Independent Verification — Absent: The 'fair price' determination is made by the Exchange in its sole discretion, with no named test, measurement, or third-party evidence.
- Suitable Method — Absent: Sole discretion is not a procedure capable of establishing a precise 'fair price' claim.
- Defined Benchmark — Absent: No methodology or threshold for 'fair price' is specified.
- Conclusive Link — Absent: no named standard - entailment cannot be assessed
What would close it: Specify an objective fair-price methodology (e.g., last traded price within a defined window, or a volume-weighted average) instead of unguided discretion.
Death/violence/terrorism contingency settlement “Kalshi may, in its sole discretion, settle the Contract at the last”
- Independent Verification — Absent: All determinations (occurrence, material effect, fair price, even approximate timing) rest on Kalshi's sole discretion with no named external evidence.
- Suitable Method — Absent: Unstructured sole discretion, including reliance on an 'approximate time', cannot establish the asserted factual claims at a checkable level of certainty.
- Defined Benchmark — Absent: No defined standard for 'material effect on trading' or 'fair settlement' is given.
- Conclusive Link — Absent: no named standard - entailment cannot be assessed
- Relevant Timeline — Partial: Timing is anchored to 'prior to the death or act' but allows approximation when precise time is unknown, loosening the temporal match.
- Relies on material referred to but not in the public filing.
What would close it: Define objective criteria for 'material effect' and a transparent fair-price methodology; specify the Outcome Review Committee's procedures, which are referenced but not included in the supplied text.

Every provision read

Roster-based seat count determines Payout Criterion

“A seat is held by the person whom the official”

Determination: That the official CGA roster at the Measurement Time shows <party> holding seats satisfying the stated comparison to <count> · Consequence: Market Outcome is set to Yes or No, triggering payment to the corresponding long or short holders

Present Independent Verification. Evidence is the official membership roster published by the Connecticut General Assembly at cga.ct.gov, a named, publicly obtainable document.

Present Suitable Method. The roster directly lists each seat's holder and party affiliation, which can establish an exact seat count at the asserted precision.

Present Defined Benchmark. A numeric threshold is named via the comparison operator (above/below/exactly/at least/at most/between) applied to <count>.

Present Conclusive Link. Meeting the numeric threshold on the roster count is precisely what the Payout Criterion defines as the triggering condition.

Present Comprehensive Coverage. The roster is the complete official record of every seat in the chamber, matching the claim's chamber-wide scope.

Present Relevant Timeline. Both the roster snapshot and the claim are fixed at the same Measurement Time (11:59:59 PM on convening day).

Source Agency hierarchy resolves conflicting reports

“the hierarchy set out in Source Agency above will govern”

Determination: That applying the ranked Source Agency hierarchy correctly resolves a conflict as to who held a seat or a member's affiliation · Consequence: The hierarchy-selected value becomes the basis for the Expiration Value, affecting payout

Partial Independent Verification. Named sources include official records (CGA, SOTS) but also news outlets (AP, Bloomberg, etc.); the latter are receivable documents but not official/neutral in the same sense.

Partial Suitable Method. The hierarchy can resolve a clear conflict between ranked sources, but 'continuing ambiguity or dispute' is pushed to Kalshi's unstructured discretion under Rule 7.1, which is not a checkable procedure.

Present Defined Benchmark. A specific ranked list of Source Agencies is named as the standard for resolving conflicts.

Present Conclusive Link. Applying the defined hierarchy order is, by the contract's own terms, what establishes the governing value.

Present Comprehensive Coverage. The hierarchy applies to any seat/affiliation in dispute across the whole roster, matching the claim's scope.

Present Relevant Timeline. Resolution is tied to status 'at the Measurement Time', matching the obligation's reference point.

Correction governs only if Exchange finds 'material error'

“the Exchange determines, in its sole discretion, that the correction remedies”

Determination: That a published correction remedies a material error in the initial reported value · Consequence: The corrected value either supersedes or is disregarded in determining the Expiration Value

Absent Independent Verification. The determination rests entirely on the Exchange's own sole discretion, not on any named third-party-receivable evidence or test.

Absent Suitable Method. Unstructured sole discretion cannot establish a checkable factual claim about materiality of an error.

Absent Defined Benchmark. No threshold or definition of 'material error' is given beyond the Exchange's own judgment.

Absent Conclusive Link. no named standard - entailment cannot be assessed

Present Comprehensive Coverage. The determination is tied to the specific disputed value/seat at issue, matching the narrow scope of the claim.

Present Relevant Timeline. The correction must occur 'prior to Expiration', matching the obligation's relevant time window.

No-data fallback to 'last fair price'

“all markets will resolve to the last fair price”

Determination: That no reliable Underlying data exists by the Expiration Date, and that a given price is the 'fair' settlement price · Consequence: Market resolves to the Exchange-determined last fair price, or the 'No data' strike resolves Yes and all others No

Absent Independent Verification. The 'fair price' determination is made by the Exchange in its sole discretion, with no named test, measurement, or third-party evidence.

Absent Suitable Method. Sole discretion is not a procedure capable of establishing a precise 'fair price' claim.

Absent Defined Benchmark. No methodology or threshold for 'fair price' is specified.

Absent Conclusive Link. no named standard - entailment cannot be assessed

Present Comprehensive Coverage. The fallback applies to the entire market/contract, matching the claim's scope.

Present Relevant Timeline. Triggered specifically by absence of data 'by the Expiration Date', matching the obligation's time boundary.

Death/violence/terrorism contingency settlement

“Kalshi may, in its sole discretion, settle the Contract at the last”

Determination: That a qualifying death or act of violence/terrorism occurred, materially affected trading, and that a given price is a fair settlement · Consequence: Contract is settled at the last traded price (or an Outcome Review Committee price), final and not reviewable

Absent Independent Verification. All determinations (occurrence, material effect, fair price, even approximate timing) rest on Kalshi's sole discretion with no named external evidence.

Absent Suitable Method. Unstructured sole discretion, including reliance on an 'approximate time', cannot establish the asserted factual claims at a checkable level of certainty.

Absent Defined Benchmark. No defined standard for 'material effect on trading' or 'fair settlement' is given.

Absent Conclusive Link. no named standard - entailment cannot be assessed

Present Comprehensive Coverage. The provision applies to the whole contract being settled, matching the claim's scope.

Partial Relevant Timeline. Timing is anchored to 'prior to the death or act' but allows approximation when precise time is unknown, loosening the temporal match.

Read 31 October 2026 with Warrant Check (instrument 1.0). Labels: Present, Partial, Absent describe whether each check is found in the wording as written.

Check your own contract terms with Warrant Check →

← All filings in the monitor