A Kalshi-funded letter asks the SEC and CFTC to write perps rules to actual risk

Start with the growth rate, because that is the number the letter is really built on. Kalshi's estimate takes offshore perpetuals volume from about $28 trillion two years ago to more than $90 trillion in 2025 ^[6], which is 3.2 times in two years ^[16], or roughly 79 percent a year compounding ^[17], and in absolute terms it is $62 trillion of annual notional added ^[18] in venues that no US examiner walks into.

Set that against the $2.5 trillion figure Decrypt attaches to the industry ^[1] and you get about 36 turns of notional per dollar of underlying ^[15], which is not a valuation ratio and should not be read as one; or rather, the more useful reading is that it measures how much levered churn a $2.5 trillion asset base can generate once leverage is available offshore and nowhere else.

A comment letter into the June request for input on swap definitions and jurisdictional lines ^[7] is the cheapest instrument in the whole lobbying kit, and what Kalshi bought when it retained Bellementis PLLC to help draft one ^[10] was not drafting hours. It was a bipartisan signature block: Giancarlo, Quintenz, Brown-Hruska, Wallman, Spatt ^[2], filed at a moment when neither commission itself has bipartisan representation ^[8]. The signatories say they were not compensated and that Kalshi had no say over the contents ^[10], which I take at face value and also consider beside the point, since the position they advance (similar risks, similar treatment, no stacked compliance cost from overlapping rules ^[3]) describes precisely the regime in which the perps product Kalshi launched earlier this year ^[5] becomes unremarkable. Kalshi, notably, is not waiting for a statute to grant that.

This is probably wrong, but the causal claim underneath deserves testing before anyone sizes the prize: that US regulation drove this market overseas ^[4]. Offshore venues also compete on leverage no registered venue will offer and on listings no registered venue will touch, so a rulebook calibrated to actual risk rather than maximum burden, in Giancarlo's phrasing ^[11], can be entirely sensible and still repatriate a single-digit share. President Trump's remark that CFTC Chairman Michael Selig is working to bring Hyperliquid into the United States ^[9] is the experiment worth watching: if it registers and its volume travels with it, the calibration thesis holds; if it registers and the volume stays on the offshore book, the binding constraint was never the rulebook.

The quieter half is custody, where the SEC sent its rewrite of adviser and investment company rules to OIRA last week ^[12], aimed at how regulated firms can hold digital assets under the qualified custodian standard ^[13]. The text is not public, so which firms qualify and on what terms is unknown ^[14]. My thesis fails if the first onshore perps venues, two years from now, are clearing low single-digit percentages of $90 trillion ^[6] while offshore volume keeps compounding near 79 percent ^[17].