US Compliance

Structure: Introducing Broker (IB)

In the United States, FaaSFi operates not as an exchange, but as an Introducing Broker (IB). We have established a partner agreement with Kalshi, which is a Commodity Futures Trading Commission (CFTC) designated contract market (DCM).

Roles and Responsibilities:

• Kalshi (The Exchange): Responsible for trade matching, clearing, and holding customer funds. They possess the DCM license.

• FaaSFi (The Broker): Responsible for the user interface, customer service, and routing orders to the exchange.

CFTC Rules & Funds Segregation

To comply with the Commodity Exchange Act (CEA) and CFTC regulations, FaaSFi strictly separates client funds from operational funds.

Omnibus Account Structure

• Definition: FaaSFi maintains an "Omnibus Account" at Kalshi's clearing house. This is a master account that holds funds for multiple clients.

• Sub-Account Ledger: Within FaaSFi's internal database, every US client is assigned a unique Sub-Account ID mandated by the FIX protocol (PartyID tag 448).

• Reconciliation: The sum of all user balances in the FaaSFi ledger must exactly match the total balance of the Omnibus Account at the clearing house. This reconciliation is performed daily.

• Protection: In the event of FaaSFi's bankruptcy, client funds in the Omnibus Account are protected and cannot be seized by FaaSFi's creditors, as they legally belong to the customers.