Why It Matters
Kalshi Inc. is lobbying on a Commodity Futures Trading Commission (CFTC) proposed rule on public-interest determinations for event contracts as the agency considers whether to finalize it.
The CFTC issued a proposed rule on public-interest determinations for event contracts, which remained a proposal rather than a final rule as of June. Days before the lobbying filing deadline, a federal appeals court ruled against Kalshi in a dispute over state authority to regulate sports-related prediction contracts, finding that Kalshi had not shown its contracts were swaps subject to CFTC oversight.
By the Numbers
Kalshi's combined lobbying spending across all registrants rose from $915,000 in the second quarter to $1,285,000 in the third quarter, an increase of $370,000, or 40.4%. Seven registrants filed third-quarter reports:
- Kalshi Inc. (in-house): $800,000
- Squire Patton Boggs: $180,000
- Miller Strategies LLC: $120,000
- Lincoln Policy Group: $60,000
- Forbes Tate Partners LLC: $60,000
- Intersection Government Relations LLC: $45,000
- Dow Solutions Inc.: $20,000
PhronesisDC LLC filed a new client registration during the quarter but has no quarterly report in the supplied records.
The Miller Strategies LLC filing lists five lobbyists: Tyler Grimm, a former House Judiciary and House Oversight staffer; Natalie McIntyre, a former legislative director for Sen. Bill Hagerty (R-TN); Luke Wallwork, a former House Small Business and House Energy and Commerce staffer; Jeff Miller; and Jessica Mandel. Grimm, McIntyre, and Wallwork were added compared with the third quarter of 2025.
Broader Context
The CFTC's June 10 proposed rule addresses public-interest determinations for event contracts, including those involving activities such as gaming. It remains a proposal, not a final rule.
A Congressional Research Service overview of the CFTC's proposed prediction-market rule describes the framework for reviewing event contracts involving activities such as gaming and outlines the statutory and regulatory questions it raises. The proposal drew opposition from several quarters: The American Gaming Association's chief executive urged the CFTC to withdraw the proposed revisions, arguing that the definition of gaming would allow virtually any sports event contract; a joint comment from 44 state attorneys general, led by Ohio Attorney General Andy Wilson, argued that the CFTC lacked statutory authority and that the proposal conflicted with federalism principles and the major-questions doctrine; and former Sen. Chris Dodd argued that the proposal contradicted the law he wrote, while former CFTC Chairman Timothy Massad also opposed it in his personal capacity.
Sens. Mark Warner (D-VA) and Alex Padilla (D-CA) wrote to Kalshi and Polymarket on Aug. 26 demanding answers about paid influencers spreading election misinformation. Rep. Steven Horsford (D-NV) called the Ninth Circuit ruling a victory for states and backed his Prediction Markets Are Gambling Act. Sen. Jeff Merkley (D-OR), joined by Sens. Richard Blumenthal (D-CT), Chris Van Hollen (D-MD) and others, along with Rep. Jamie Raskin (D-MD), wrote to the CFTC urging it to bar event contracts involving elections, war, sports and government actions. Rep. Blake Moore (R-UT) proposed the Event Contract Enforcement Act, which would prohibit event contracts involving terrorism, war and elections.
The Bottom Line
The CFTC's proposed rule on event-contract public-interest determinations remained a proposal, not a final rule, as of the filing date. The House's next meeting is scheduled for Oct. 26. Across complete quarters, Kalshi's outside lobbying roster expanded with Forbes Tate Partners, while PhronesisDC registered as a client representative without a quarterly report in the supplied records. The Miller Strategies team grew by three lobbyists compared with a year earlier.
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