CFTC Issues Advisory on Manipulation Risks in ‘Mention Market’ Event Contracts

The Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight issued an advisory on September 22, 2026, addressing event contracts based on whether an individual says or “mentions” specified words, attends or appears at an event, or otherwise interacts with another person. These products are commonly referred to as “mention market” contracts. The advisory said these contract types present a heightened risk of manipulation because their settlement depends on discrete conduct by a person that may not be independently generated or externally verifiable. The CFTC’s guidance therefore focuses on the circumstances in which such contracts may be listed consistently with the Commodity Exchange Act and Commission regulations. The advisory provides non-exhaustive examples of factors designated contract markets (DCMs) should consider when designing and submitting mention market contracts under Commission Regulations Sections 40.2 or 40.3. The guidance applies to the contract-specific analysis DCMs provide as part of those submissions. The CFTC also reminded DCMs of their obligation under Core Principle 3 to list only contracts that are not readily susceptible to manipulation. It emphasized that submissions for mention market products should include complete, contract-specific analysis addressing the relevant manipulation risks and the design of the proposed contract.