CFTC Mention Markets Advisory: 886 Open on Kalshi

On September 22, 2026 the CFTC's Division of Market Oversight told the exchanges it designates that "Mention Markets" - contracts settling on whether a named person will say a word, attend an event or meet someone - may be treated as "presumptively readily susceptible to manipulation". Two days later we counted 886 of them open on Kalshi across 58 series.

The advisory is CFTC Letter No. 26-27, signed by Duncan Hennes, Acting Director of the Division of Market Oversight. It is addressed to designated contract markets, and it names a new category it calls "Mention Markets": event contracts "based on whether an individual will say or 'mention' certain words, attend or appear at an event, or otherwise interact with another person".

That category is not remote from this site. The CFTC's own registry lists Kalshi as designated since November 3, 2020 and QCX LLC d/b/a Polymarket US since July 9, 2025, and it also lists Ludlow Exchange, LLC, designated June 16, 2026. Ludlow Exchange is Novig, which ran a sweepstakes sportsbook until it retired both coin currencies in August. One operator that sold sweeps coins this summer now holds a designation from the regulator that wrote this advisory.

What did the CFTC actually say?

That this contract type is different in kind from the rest of the book. Most event contracts, the advisory says, "settle on independently generated, externally verifiable outcomes that are outside the control of any single person, such as economic data releases, election results, or the outcomes of regulated sporting events". Mention markets do not. "Their settlement turns not on an aggregate outcome but on the discrete conduct of a named person", and that conduct "may be neither independently generated nor externally verifiable".

The consequence the staff draw is conditional, and the condition is doing real work: "In certain circumstances where the costs of manipulation or the likelihood of detection is low and sufficient safeguards are absent, the person whose conduct determines settlement (or those in close proximity of such person) may readily influence the outcome of the contract, exploit advance knowledge of it, or both."

The worked example in the document is a podcast. "A contract might depend on whether the host of a live-streamed podcast utters a particular catchphrase; the host can easily fulfill this condition, and a trader may directly induce the outcome by submitting a question or purchasing an on-air acknowledgment."

There is a second example that lands closer to what is actually listed. Even in high-profile settings, the staff write, words that lack substantive meaning in the context of the event, "such as an unrelated buzzword recited during an earnings call or an incidental gesture at a public ceremony", may not attract the scrutiny that disciplines words that matter.

Two caveats matter and the document states both. The advisory "is informational and does not create new obligations", and it "represents only the views of DMO staff and does not necessarily represent the views of the Commission". It is a signal about how filings will be reviewed, not a rule.

How many mention markets does Kalshi have open?

We counted them ourselves against Kalshi's public trading API on September 24, 2026, paging all 14,133 open events on the exchange rather than guessing at series names.

The first row is not our judgment call: "Mentions" is a category label Kalshi applies in its own data, and every series carrying it asks what a named person will say. The earnings-call block inside it covers 33 companies, from Apple and Amazon to Domino's, Kroger and Carnival Cruise. Beyond those there are markets on what Fed chair Kevin Warsh says at his October 28 press conference (47 contracts), what Trump says in his evening remarks with Xi Jinping (31), what Jensen Huang says at the GTC Berlin keynote, what Robinhood's Vlad Tenev says at his own company's summit, and what reporters say on ABC World News Tonight.

The other two rows are ours, and they are narrow on purpose. The meeting markets ask whether two named people will meet in person, which is the advisory's "otherwise interact with another person" leg: Trump and Kim Jong Un, Xi and Zelenskyy, Trump and each of Sundar Pichai, Sam Altman and Mark Zuckerberg. The attendance row is two contracts on whether Donald Trump attends UFC 332 and UFC 333, plus one on whether the New York basketball team visits the White House.

We left two things out that a looser count would have swept in. Kalshi lists eight contracts on how many people will attend Broadway shows across the 2026-27 season: that is an aggregate box-office statistic, the kind of independently generated outcome the advisory contrasts with mention markets, so it is not in our total. We also excluded contracts on whether the US and Iran hold a diplomatic meeting and on whether the Fed calls an emergency meeting, because those settle on institutional acts rather than a named individual's conduct.

Who decides whether the word was said?

The exchange does, at least in the first instance. The settlement rules on a Tesla earnings-call contract read: "If Waymo is said by any Tesla representative (including the operator of the call) during the next Tesla earnings call (including the Q+A), then the market resolves to Yes." The resolution method is video of the call, and then: "If a consensus by Kalshi employees cannot be reached using video, transcripts of the Tesla earnings call will be used according to the news publications listed in the contract."

The attendance contracts go further in the direction the advisory flags. On the UFC markets, "Attendance is confirmed if the person is reported present at the event by any Source Agency, including social media posts by the person themselves." The person whose conduct settles the contract can also be the source that verifies it.

The Trump speech markets work the same way: the phrase counts if it appears in "public statements, direct quotes published by Source Agencies, or written public statements on his personal social media accounts (Twitter/Truth Social)". Eighteen settlement sources are listed for that series, and alongside Reuters, the AP and the major networks, one of them is "the President of the United States", pointing at whitehouse.gov.

None of this is hidden. Kalshi publishes all of it in the contract rules on its own API, which is how we read it. And none of it is an allegation of wrongdoing by anyone: the advisory describes a design risk, and we found no finding, order or enforcement action against any exchange over these contracts.

Why does this matter if you play sweepstakes casinos?

Because the two markets keep converging, and one of the exchanges the advisory is addressed to used to sell sweeps coins. The same week this advisory landed, New York sued Polymarket US for running an unlicensed gambling operation, and the office that filed it is the one that ended sweeps coin play in New York. The CFTC has already told prediction markets to stay away from sweepstakes-style bonus mechanics, and states from Missouri to Connecticut have issued cease-and-desist orders to the same platforms. The CFTC has also stepped in on an exchange's side before: on August 11 it ordered Kalshi to keep trading after New York sued. No equivalent federal protection exists for a sweepstakes casino.

If you hold a position in one of these contracts, there is something concrete to do with this. Open the contract's own rules before you trade it, not after, and ask the two questions the advisory asks: can the person who settles this contract simply decide the answer, and who verifies that they did? On Kalshi both answers are published in the contract text. A federal regulator has now said in writing that when the answer to the first is yes and the second is thin, the contract is presumed manipulable. Kalshi has separately been sued by traders over an account suspension and a $6,229 penalty and over a frozen withdrawal, so how an exchange resolves a disputed outcome is not a theoretical question.

Our how we verify page sets out what we do and do not test. We read Kalshi's public contract data directly; we did not run the same count against any other exchange, so the 886 figure is a Kalshi figure and nothing more.

Sources & documents

• CFTC Staff Advisory on Individual Mention, Attendance and Interaction Event Contracts - CFTC Letter No. 26-27, 6 pages, dated September 22, 2026; every quotation above is verbatim from this document
• CFTC press release 9302-26 - the announcement, September 22, 2026
• CFTC registry of designated contract markets - the designation dates for Kalshi, QCX LLC d/b/a Polymarket US and Ludlow Exchange, LLC
• Kalshi open-events feed - paged in full on September 24, 2026; 14,133 open events, from which the 58 series in the table were identified
• Kalshi contract rules, Tesla earnings-mention series, Trump UFC attendance series and Trump meeting series - the settlement language quoted above
• Kalshi series metadata for the Trump speech markets - the 18 listed settlement sources
• CFTC press release index - how the advisory was found

Counts were taken on September 24, 2026 and move as contracts open and settle. We counted contracts with an open status only. Which contracts fall inside the advisory's category is in part a judgment, so we have set out above what we included, what we excluded and why. We have no comment from Kalshi and there is no suggestion that any listed contract has been manipulated.

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