Gemini Titan, LLC Product Self-Certification under 17 C.F.R. § 40.2(a) for “Will the US CPI Index be up at 5 PM ET on November 3, 2026 compared to 5 PM ET on November 2, 2026?” Event Contract.

Gemini Titan, LLC · received by the CFTC 30 October 2026 · the filing (PDF)

Summary

Warrant Check read 6 operative provisions in this filing. Across them, 19 of 36 checks are present, 4 partial and 11 absent. 3 provisions have every check present.

19 present4 partial11 absent2 not assessed

Staff-letter lens

The payout rule here is “Payout Criterion / Up 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	2 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	2 of 5 addressed
Terms in the public filing	In the filing	2 of 5 in the filing

How the lens works and what it does not read

What the wording addresses

Payout Criterion / Up Determination — every check present.
“whether the Measurement Value is up from the Reference Value”
Unavailable Index Fallback: Comprehensive Coverage.
“the last valid value published by the Source Agency before that time shall be used”
Post-Measurement Correction — every check present.
“the Source Agency corrects the value published for the Measurement Time”
BLS Reschedule / Last Trading Date Adjustment — every check present.
“BLS schedules or reschedules an Official Release to a time after the Reference Time”

What the wording leaves open

Unavailable Index Fallback “the last valid value published by the Source Agency before that time shall be used”
- Independent Verification — Partial: still a published Mecone figure, but which figure is used depends on an unstated staleness window combined with Exchange discretion beyond one hour
- Suitable Method — Partial: a prior published value can approximate but does not establish the value at the actual required instant
- Defined Benchmark — Partial: the 'last valid value before that time' is a procedural rule, not a quality/accuracy standard
- Conclusive Link — Partial: using an earlier value entails only an approximation of the required time's value, not equivalence
- Relevant Timeline — Absent: a one-offearlier-published figure stands in for the specific Measurement/Reference instant, which can diverge from that instant's true value
- Relies on material referred to but not in the public filing.
What would close it: specify a maximum staleness tolerance and an objective criterion for when the stand-in value is treated as equivalent, rather than leaving the beyond-one-hour case to sole Exchange discretion under Rule 7.1 (not provided)
Methodology Change / Discontinuation Resolution “the Contract shall resolve to the last fair price determined in the sole discretion”
- Independent Verification — Absent: rests on the Exchange's own sole discretion, not any third-party-receivable evidence
- Suitable Method — Absent: a discretionary judgment cannot establish a precise settlement value with the certainty the Payout Criterion otherwise asserts
- Defined Benchmark — Absent: no defined 'fair price' methodology, formula, or threshold is specified
- Comprehensive Coverage — Absent: no stated procedure tying the discretionary price to the specific Measurement/Reference population
- Relevant Timeline — Absent: no defined period or cutoffgoverns how the discretionary determination is made
- Relies on material referred to but not in the public filing.
What would close it: incorporate the detailed Rule 7.2 methodology (not provided in this text) defining objective inputs, a named valuation methodology, and timing for the 'last fair price' determination
Additional Settlement Contingencies / Market Outcome Review “the Exchange has the right to determine payouts pursuant to Rule 7.1”
- Independent Verification — Absent: relies on the Exchange's own sole-discretion process, not external verifiable evidence; Rule 7.1 content is not in the supplied text
- Suitable Method — Absent: an undefined internal review process cannot be assessed as capable of establishing a precise settlement determination
- Defined Benchmark — Absent: no standard or criteria for the review process are stated in the supplied text
- Comprehensive Coverage — Absent: scope of what 'cannot be determined' triggers review is undefined in the provided text
- Relevant Timeline — Absent: no time bounds on the review process are specified here
- Relies on material referred to but not in the public filing.
What would close it: attach or reference the full content of Rulebook Rule 7.1 so the review process's criteria, evidence, and timing can be assessed

Every provision read

Payout Criterion / Up Determination

“whether the Measurement Value is up from the Reference Value”

Determination: the Index value at the Measurement Time is strictly greater than its value at the Reference Time, as reported by Mecone · Consequence: the Contract resolves to Yes (payout) or No

Present Independent Verification. evidence is the published Index value from a named third-party publisher (Mecone), obtainable and not a party's own opinion

Present Suitable Method. direct comparison of two published figures matches exactly the claim asserted (Index up/down), no inferential gap

Present Defined Benchmark. "strictly greater than" is a precise numeric threshold applied to rounded published values

Present Conclusive Link. meeting the strictly-greater-than threshold is definitionally identical to the claim of 'up'

Present Comprehensive Coverage. claim concerns exactly two defined time points and the evidence covers precisely those two points

Present Relevant Timeline. Measurement Time and Reference Time are the exact times the evidence is drawn from

Unavailable Index Fallback

“the last valid value published by the Source Agency before that time shall be used”

Determination: the last published value before the required time adequately represents the Index value at that time · Consequence: that stale value is used to determine the Measurement or Reference Value for settlement

Partial Independent Verification. still a published Mecone figure, but which figure is used depends on an unstated staleness window combined with Exchange discretion beyond one hour

Partial Suitable Method. a prior published value can approximate but does not establish the value at the actual required instant

Partial Defined Benchmark. the 'last valid value before that time' is a procedural rule, not a quality/accuracy standard

Partial Conclusive Link. using an earlier value entails only an approximation of the required time's value, not equivalence

Present Comprehensive Coverage. same single Index and same two points are referenced, no population mismatch

Absent Relevant Timeline. a one-offearlier-published figure stands in for the specific Measurement/Reference instant, which can diverge from that instant's true value

Post-Measurement Correction

“the Source Agency corrects the value published for the Measurement Time”

Determination: a correction issued by Mecone within one hour after Measurement Time is the accurate value · Consequence: the corrected value is substituted and used for settlement

Present Independent Verification. evidence is a published correction from the same named third-party source

Present Suitable Method. a direct correction to the same metric by its publisher is capable of establishing the accurate value

Present Defined Benchmark. the one-hour correction window is a defined, bright-line threshold

Present Conclusive Link. a timely correction by the publisher of record directly establishes the value to be used

Present Comprehensive Coverage. covers the same single Measurement/Reference points

Present Relevant Timeline. the correction window (one hour) is explicitly matched to the determination period

Methodology Change / Discontinuation Resolution

“the Contract shall resolve to the last fair price determined in the sole discretion”

Determination: the Exchange's sole discretion determination of 'last fair price' reflects what the Index/CPI would have shown · Consequence: the Contract settles at that discretionarily-determined price rather than an observed Index value

Absent Independent Verification. rests on the Exchange's own sole discretion, not any third-party-receivable evidence

Absent Suitable Method. a discretionary judgment cannot establish a precise settlement value with the certainty the Payout Criterion otherwise asserts

Absent Defined Benchmark. no defined 'fair price' methodology, formula, or threshold is specified

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 stated procedure tying the discretionary price to the specific Measurement/Reference population

Absent Relevant Timeline. no defined period or cutoffgoverns how the discretionary determination is made

Additional Settlement Contingencies / Market Outcome Review

“the Exchange has the right to determine payouts pursuant to Rule 7.1”

Determination: the Exchange's review process correctly determines payouts when the Expiration Value cannot otherwise be determined · Consequence: the Exchange determines and imposes payout outcomes outside the standard Payout Criterion

Absent Independent Verification. relies on the Exchange's own sole-discretion process, not external verifiable evidence; Rule 7.1 content is not in the supplied text

Absent Suitable Method. an undefined internal review process cannot be assessed as capable of establishing a precise settlement determination

Absent Defined Benchmark. no standard or criteria for the review process are stated in the supplied text

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. scope of what 'cannot be determined' triggers review is undefined in the provided text

Absent Relevant Timeline. no time bounds on the review process are specified here

BLS Reschedule / Last Trading Date Adjustment

“BLS schedules or reschedules an Official Release to a time after the Reference Time”

Determination: BLS has scheduled/rescheduled an Official Release into the window between Reference Time and Expiration Time · Consequence: the Last Trading Date/Time is moved to before that Official Release

Present Independent Verification. evidence is BLS's publicly announced release calendar, a neutral third-party source

Present Suitable Method. a published calendar date directly establishes the scheduling fact asserted

Present Defined Benchmark. the trigger is a defined comparison: scheduled publication time vs. Reference/Expiration Time window

Present Conclusive Link. if the published schedule shows a release in that window, the adjustment rule logically follows

Present Comprehensive Coverage. applies to the single identified Official Release event relevant to this Contract

Present Relevant Timeline. the window assessed (Reference Time to Expiration Time) matches the obligation's relevant period

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.

Drafting a certification?

Have the draft read through the same lens before it is filed: privately, with nothing published. You get what the wording addresses and what it leaves open, term by term, including the fallback rules for cancellation, delay, missing data and challenged results, where gaps most often sit.

Ask for a private reading or check a single clause free →

← All filings in the monitor