The Commodity Futures Trading Commission’s Division of Market Oversight issued an advisory reminding designated contract markets how to submit self-certifications for event contract series. The guidance says broad, template-style certifications that bundle multiple potential event contract variations into a single filing should not be submitted under Commission Regulation 40.2(a) because that approach can prevent staff from determining whether the market has provided the required information, analysis and compliance assessment, including for settlement methodology, data sources and core principles. For event contract series, the advisory says filings should be made under Regulation 40.2(d) or Regulation 40.3 where appropriate. A class self-certification under Regulation 40.2(d) is limited to contracts that are based on excluded commodities and share identical pricing sources, formulas, procedures and methodologies for calculating reference prices and payment obligations, match a previously certified or approved specific contract filed by the same designated contract market, and use identical currency or currencies. The advisory also says designated contract markets should specifically identify settlement sources in their filings so they can assess manipulation risk, reliability, public availability and timeliness. Where a self-certification is inadequate, the Division of Market Oversight may recommend that the Commission stay the listing or require the designated contract market to withdraw the filing and resubmit individual contracts, or certain contracts within a series, for review under Regulation 40.2 or 40.3. The guidance also clarifies that markets may still use the Commission’s consolidated submission functionality to submit shared supporting materials once, provided each contract is still certified individually under Regulation 40.2(a) or as a qualifying class under Regulation 40.2(d), and it encourages pre-filing engagement with staff where a contract series raises novel questions about the appropriate filing route.
Commodity Futures Trading Commission2026-07-24
Commodity Futures Trading Commission issues advisory on event contract series self-certification, warns against broad template filings
The Commodity Futures Trading Commission’s Division of Market Oversight told designated contract markets not to use broad template self-certifications that bundle multiple event contract permutations into one filing. Event contract series should instead be filed under Regulation 40.2(d) or 40.3 where appropriate, with class treatment limited to contracts that share identical pricing and settlement methodologies and reference a previously certified or approved specific contract. Inadequate filings may be stayed or sent back for resubmission, although shared documents may still be filed through the Commission’s consolidated submission process.