The advisory does not name specific firms. But the CFTC’s language makes clear it has observed a pattern: registrants submitting self-certified event contracts that rely on generic rationale rather than a genuine, contract-by-contract analysis. Self-certification was designed to let exchanges launch products faster, provided they certified that the contract complied with the Commodity Exchange Act and CFTC rules. In theory, that meant a thorough internal review. In practice, the regulator now suggests some firms are treating it as a rubber-stamp exercise.