The Commodity Futures Trading Commission’s Division of Market Oversight and Division of Clearing and Risk issued a supplemental no-action position on swap data reporting and recordkeeping requirements for transactions executed on or subject to the rules of KalshiEX LLC and cleared through Kalshi Klear LLC. The action responds to a request to modify CFTC Letter No. 24-15 by removing a restriction on third-party clearing and extending coverage to fully collateralized variable payout contracts. Under the no-action relief, the Divisions will not recommend the Commission initiate an enforcement action against KalshiEX LLC, Kalshi Klear LLC, or their participants for failure to comply with certain swap-related recordkeeping requirements and for failure to report to swap data repositories data associated with binary option transactions and variable payout contract transactions, subject to the terms of the letter. The supplemental letter also removes the condition in CFTC Letter No. 24-15 that prohibited Kalshi participants from clearing contracts through a third-party clearing member.