CFTC Advisory Declares ‘Mentions Market’ Contracts Present Heightened Risk of Manipulation

• A CFTC advisory released today notes that mention market contracts “present a heightened risk of manipulation”
• Mentions market contracts are based on whether an individual will mention certain words, attend or appear at an event, or interact with another person
• Settlement of contracts may be controlled by a single individual or small group of individuals, which may be easily manipulated

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The Commodity Futures Trading Commission today released a staff advisory declaring mention market contracts may present a “heightened risk of manipulation,” as their outcomes can be influenced by a single person or small group of people.

The Commodity Futures Trading Commission (CFTC) advisory encouraged designated contract markets to consider what types of mention market contracts they may offer moving forward and to only list contracts moving forward that are not “readily susceptible to manipulation.”

“As the settlement of contracts in Mention Markets may be controlled by a single individual, a small group of individuals, or persons with access to or influence over the individual whose words, attendance, or interaction determines settlement, DMO staff may view Mention Markets as presumptively readily susceptible to manipulation and accordingly expect a heightened showing in support of any submission seeking to list such contracts,” the settlement reads.

Popular Form of Contracts

CFTC Chairman Mike Selig today praised the staff advisory. The head of the CFTC said he was “pleased to see staff provide guidance on the potential risks and unique considerations associated with the listing of mentions markets on CFTC regulated exchanges”.

“Regulatory clarity drives sound markets. Pleased to see staff provide guidance on the potential risks and unique considerations associated with the listing of mention markets on @CFTC
regulated exchanges and remind DCMs of their obligation to list only contracts not readily susceptible to manipulation,” Selig noted on his X account.

Regulatory clarity drives sound markets. Pleased to see staff provide guidance on the potential risks and unique considerations associated with the listing of mention markets on @CFTC regulated exchanges and remind DCMs of their obligation to list only contracts not readily… https://t.co/KwRpmLQ43Y

— Mike Selig (@ChairmanSelig) September 22, 2026

Mention market contracts have proved to be popular on prediction market operator platforms, but a DCM’s ability to list them may have just gotten much harder.

In its advisory, the CFTC notes that a mention market contract’s susceptibility to manipulation is contract-specific, but also involves consideration of its design and the effectiveness of measures implemented by a DCM to prevent manipulation and misappropriation of material non-public information.

The CFTC said DCM’s should consider the following when submitting mention market contracts:

• Independent obligations constraining the controlling individual: Is the individual whose speech or conduct controls the contract outcome subject to independent legal, professional, contractual, fiduciary, confidentiality, or organizational obligations that deter manipulation?
• Susceptibility to manipulation through external pressure directed at controlling individuals: Can a contract be manipulated not only by the individual whose conduct determines settlement, but through that individual. Meaning, can social engineering, inducement, or public pressure campaigns influence the individual in any way?
• Independent verification and substantial public scrutiny: DCMs must evaluate whether the actions or outcomes underlying the contract are subject to transparent, independent verification and contemporaneous, significant public scrutiny
• Robustness of prophylactic trading rules, surveillance, and controls: Staff expects any DCM seeking to list mention market contracts will implement prophylactic trading rules, surveillance, and controls designed to detect and deter manipulation.

Prophylactic measures, the CFTC noted in its advisory, can including maintaining a “restricted” list of market participants with contract affiliations, prohibiting public officials or those associated with the official from trading on if he or she will attend an event, and a review of their public statements.

Any filing for mention market contracts moving forward, the CFTC noted, will have to address the factor before being listed.

Mentions Markets Have Been Manipulated in the Past

Two well-publicized events have come to light within the last several months regarding market mention contracts being manipulated by public figures or those surrounding them. A longtime White House teleprompter for President Donald J. Trump (R) in July allegedly profited more than $100,000 by using insider information and placing bets on prediction market platforms on the president’s speeches, according to an ABC News report.

ABC News today reported Gabriel Perez, a technical assistant to Trump who has been operating his teleprompter since 2016, placed thousands of dollars in bets through Kalshi on what the president would say in more than a dozen speeches this year.

Kalshi allegedly alerted theCFTC of suspicious activity on its “mentions” market, which allows users to place bets on certain words or phrases public figures will use in speeches.

Earlier this month, Kalshi also announced a $71,356 fine and a lifetime ban for ex-Congressman George Santos after he allegedly profited off of manipulated mention market contracts based on his potential attendance at the 2025 State of Union address.

The Kalshi Compliance Department established reasonable cause to believe Santos engaged in trading activity in markets related to his attendance, which he manipulated with several comments on his social media channels.

“As a person capable of influencing the outcome of the underlying event, Santos was prohibited from trading in this market under Kalshi Exchange Rule 5.17(z). Despite this, between February 2 and February 25, 2026, Santos placed a series of large trades in a market where the underlying contracts depended upon his own attendance at the event. He then began making a series of public statements regarding his attendance at the event in an attempt to influence the price of Yes and No contracts, respectively. Some of these included false or misleading statements,” Kalshi noted in its announcement.