Some market observers have argued that the Commodity Futures Trading Commission (CFTC) has allowed the self-certification process to run on autopilot and has allowed markets to list novel event contracts without meaningful review. Recent CFTC action should put that view to rest. In late October 2026, the CFTC issued orders against two designated contract markets (DCMs). Each order instituted a proceeding to determine whether the DCM’s self-certification was false and stayed the listing of the contracts while that proceeding continues. The orders arrive on the heels of several staff advisories that put DCMs on notice of the CFTC’s expectations.