Gemini Titan, LLC Product Self-Certification under 17 C.F.R. § 40.2(a) for “Will the BLS CPI-U year-over-year change for November 2026 be above 3.7%?” Event Contract.

Gemini Titan, LLC · received by the CFTC 29 October 2026 · the filing (PDF)

Summary

Warrant Check read 6 operative provisions in this filing. Across them, 23 of 36 checks are present, 1 partial and 10 absent. 3 provisions have every check present. 1 statement the exchange makes to the CFTC about the filing itself (such as that it complies with the Act) is not contract terms and is left out.

23 present1 partial10 absent2 not assessed

Staff-letter lens

The payout rule here is “Primary settlement determination”: the rule that says what makes the contract pay Yes or No. The other 5 rules are fallback rules: what happens if the event is cancelled or delayed, the data goes missing, or the result is challenged.

Topic the staff letters raise	Payout rule	Fallback rules
Settlement source identified	Addressed	3 of 5 addressed
Settlement method described	Addressed	2 of 5 addressed
Covers every case it applies to	Addressed	3 of 5 addressed
Timing set	Addressed	3 of 5 addressed
Terms in the public filing	In the filing	3 of 5 in the filing

How the lens works and what it does not read

What the wording addresses

Primary settlement determination — every check present.
“whether the Measurement Value is above the Threshold”
Fallback to BLS source: Independent Verification, Defined Benchmark, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“the Source Agency has not reported the figure”
One-hour correction window — every check present.
“corrects the Measurement Value it reported as of”
Release postponement/rescheduling — every check present.
“If BLS postpones or reschedules the Official Release”

What the wording leaves open

Fallback to BLS source “the Source Agency has not reported the figure”
- Suitable Method — Partial: Determining whether Mecone 'continues to display a value that has not been re-anchored' requires some interpretive judgment, not a purely mechanical check.
No-release / 30-day discretionary resolution “does not issue the Official Release within thirty”
- Independent Verification — Absent: Resolution rests on the Exchange's own 'sole discretion' under an unreproduced internal rule, not any named third-party evidence.
- Suitable Method — Absent: Sole discretion is not a checkable procedure and cannot establish any specific numeric claim; the trigger condition (non-publication) is checkable but the consequence itself is not evidence-based.
- Defined Benchmark — Absent: No standard for 'last fair price' is stated in the supplied text; Rule 7.2 is referenced but not provided.
- Comprehensive Coverage — Absent: No defined population or data source for determining 'last fair price'; scope of the discretionary determination is unbounded in the text.
- Relevant Timeline — Absent: No temporal scope is defined for how the 'last fair price' is derived once discretion is invoked.
- Relies on material referred to but not in the public filing.
What would close it: Incorporate the text of Rulebook Rule 7.2, including the evidentiary basis, standard, and procedure for determining 'last fair price.'
Market Outcome Review / discretionary payout “the Exchange has the right to determine payouts”
- Independent Verification — Absent: Determination rests on the Exchange's own discretionary process under an unreproduced rule, not named third-party evidence.
- Suitable Method — Absent: A discretionary 'right to determine payouts' is not a checkable procedure capable of establishing a specific Expiration Value.
- Defined Benchmark — Absent: No threshold or methodology is given for how payouts are determined; Rule 7.1 is referenced but not supplied.
- Comprehensive Coverage — Absent: No defined population or data set for the Exchange's determination is stated in the text.
- Relevant Timeline — Absent: No time window for the review/determination process is specified in the supplied text.
- Relies on material referred to but not in the public filing.
What would close it: Incorporate the text of Rulebook Rule 7.1 describing the evidentiary basis, standard, and procedure for the Market Outcome Review Process.

Every provision read

Primary settlement determination

“whether the Measurement Value is above the Threshold”

Determination: The BLS CPI-U year-over-year figure for November 2026, as reported by Mecone, is above 3.7% · Consequence: Contract's Expiration Value is set to Yes or No, determining payout

Present Independent Verification. Evidence is the BLS Official Release figure as re-anchored and published by a named third party (Mecone) on a specific webpage; a receivable published document.

Present Suitable Method. Reading a single published numeric figure to one decimal place can establish a simple above/below comparison at the precision asserted.

Present Defined Benchmark. Numerical Threshold of 3.7%, with 'above' defined as strictly greater than, is explicitly named.

Present Conclusive Link. A Measurement Value strictly greater than 3.7% directly and exclusively satisfies the 'above' claim as defined.

Present Comprehensive Coverage. Claim concerns one specific national statistic (CPI-U all items, NSA) for one Reference Month, matching exactly what BLS/Mecone publish.

Present Relevant Timeline. Measurement is taken at the defined Measurement Time on the Measurement Date, matching the single point-in-time claim.

Fallback to BLS source

“the Source Agency has not reported the figure”

Determination: Mecone has not reported the BLS figure by the Measurement Time · Consequence: Measurement Value is instead taken from the BLS Official Release (Fallback Source)

Present Independent Verification. Fallback evidence is the BLS Official Release at a named official URL, a receivable public document.

Partial Suitable Method. Determining whether Mecone 'continues to display a value that has not been re-anchored' requires some interpretive judgment, not a purely mechanical check.

Present Defined Benchmark. Trigger is explicitly defined as non-reporting by the Source Agency as of the Measurement Time, including listed failure scenarios.

Present Conclusive Link. Satisfying the non-reporting condition directly triggers use of the Fallback Source by the rule's own terms.

Present Comprehensive Coverage. Same single statistic and Reference Month as the primary claim; fallback does not broaden scope.

Present Relevant Timeline. Condition and switch are both anchored to the same Measurement Time on the Measurement Date.

One-hour correction window

“corrects the Measurement Value it reported as of”

Determination: Mecone issues a correction to its reported value within one hour after the Measurement Time · Consequence: The corrected value, rather than the original, is used for settlement

Present Independent Verification. Evidence is a further published correction by the same named third-party source, a receivable document.

Present Suitable Method. Checking for and reading a subsequent published correction is a straightforward factual procedure matching the claim's precision.

Present Defined Benchmark. Explicit one-hour window after the Measurement Time is the named threshold for a valid correction.

Present Conclusive Link. A correction published within that window directly and exclusively triggers substitution of the corrected value.

Present Comprehensive Coverage. Same single statistic/Reference Month; correction only addresses the same already-identified value.

Present Relevant Timeline. Explicit one-hour cutoffafter Measurement Time matches the obligation's defined window exactly.

No-release / 30-day discretionary resolution

“does not issue the Official Release within thirty”

Determination: BLS fails to publish the required 12-month CPI-U change within 30 days of the scheduled Measurement Date · Consequence: Contract resolves to 'the last fair price' as determined in the Exchange's sole discretion under Rule 7.2

Absent Independent Verification. Resolution rests on the Exchange's own 'sole discretion' under an unreproduced internal rule, not any named third-party evidence.

Absent Suitable Method. Sole discretion is not a checkable procedure and cannot establish any specific numeric claim; the trigger condition (non-publication) is checkable but the consequence itself is not evidence-based.

Absent Defined Benchmark. No standard for 'last fair price' is stated in the supplied text; Rule 7.2 is referenced but not provided.

Not assessed Conclusive Link. Not assessed: no Defined Benchmark is named, so whether meeting it would settle the question cannot be judged.

Absent Comprehensive Coverage. No defined population or data source for determining 'last fair price'; scope of the discretionary determination is unbounded in the text.

Absent Relevant Timeline. No temporal scope is defined for how the 'last fair price' is derived once discretion is invoked.

Release postponement/rescheduling

“If BLS postpones or reschedules the Official Release”

Determination: BLS has postponed or rescheduled the Official Release to a new date/time · Consequence: Contract remains open and key dates/times (Measurement, Expiration, Last Trading) are substituted accordingly

Present Independent Verification. Evidence is BLS's own published rescheduled release calendar/announcement, a receivable public document.

Present Suitable Method. Checking a published new release date/time is a simple factual confirmation matching the claim's precision.

Present Defined Benchmark. The condition is explicitly defined: a postponed or rescheduled Official Release date/time as published by BLS.

Present Conclusive Link. A published rescheduled date directly triggers the stated substitution mechanics with no interpretive gap.

Present Comprehensive Coverage. Applies to the same single statistic/Reference Month; no scope expansion.

Present Relevant Timeline. New times are explicitly pegged to the rescheduled release time (e.g., five minutes before/thirty minutes after).

Market Outcome Review / discretionary payout

“the Exchange has the right to determine payouts”

Determination: Neither the Source Agency nor the Fallback Source reports the Measurement Value, and an Expiration Value cannot otherwise be determined · Consequence: Exchange determines payouts under Rule 7.1 in an undefined review process

Absent Independent Verification. Determination rests on the Exchange's own discretionary process under an unreproduced rule, not named third-party evidence.

Absent Suitable Method. A discretionary 'right to determine payouts' is not a checkable procedure capable of establishing a specific Expiration Value.

Absent Defined Benchmark. No threshold or methodology is given for how payouts are determined; Rule 7.1 is referenced but not supplied.

Not assessed Conclusive Link. Not assessed: no Defined Benchmark is named, so whether meeting it would settle the question cannot be judged.

Absent Comprehensive Coverage. No defined population or data set for the Exchange's determination is stated in the text.

Absent Relevant Timeline. No time window for the review/determination process is specified in the supplied text.

Read 3 November 2026 with Warrant Check (instrument 1.0). Labels: Present, Partial, Absent describe whether each check is found in the wording as written. Not assessed: Conclusive Link cannot be judged where no Defined Benchmark is named; that follows from the missing benchmark and is not a separate gap.

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