Case 1:25-cv-14723 Document 10-1 Filed 08/19/25 Page 15 of 34 PageID: 87
CFTC, 17 C.F.R. §§ 1.10(b), 1.10(d), 17.00, disclosure requirements to the public, id. § 1.55, and
minimum financial requirements, id. §§ 1.12, 1.17. FCMs must “establish, maintain, and enforce
a system of risk management policies and procedures designed to monitor and manage the risks
associated with the activities of the” FCM, id. § 1.11(c)(1), and the CFTC’s regulations set forth
elements that such a risk management program must include, id. § 1.11(e), as well as reporting
requirements related to risk management, see id. § 1.15. The CFTC requires FCMs to “establish
and enforce internal rules, procedures and controls to” ensure compliance with certain trading
standards. Id. § 155.3. FCMs must also “adopt and implement written policies and procedures”
to ensure that they and their employees comply with CFTC regulations concerning conflicts of
interest. Id. § 1.71. Finally, the CFTC imposes recordkeeping requirements on FCMs. Id.
§§ 1.14, 1.18. Failure to comply with these requirements could require the FCM to “transfer all
customer accounts and immediately cease doing business as a futures commission merchant.”
Id. § 1.17(a)(4).
C.
Robinhood, Event Contracts and Kalshi
The companies within the Robinhood organization are financial-services companies that
are democratizing finance by removing barriers to access to financial markets, including by
offering zero-commission stock trading and easy-to-use mobile and web applications.
Mackenzie Decl. ¶ 2. With their commitment to offering low fees, an intuitive mobile
experience and powerful tools, the Robinhood companies empower everyday investors to
navigate financial markets safely and efficiently. Id.
On March 17, 2025, Robinhood launched its prediction markets hub, through which its
customers can place event contract trade orders. 1 Id. ¶ 4. Robinhood intermediates its
1 Robinhood began offering some limited event contract trading starting in October 2024, prior to the launch of the prediction markets hub. Mackenzie Decl. ¶ 4. The only event contracts
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