Comment Text:
From what I can see on the CFTC website, Exchange self-certifications for the listing of new products typically include a letter from the Exchange ascertaining self-certification of compliance with CFTC core principles. The submissions include the futures contract rules and an analysis of deliverable supply of the underlying commodity/asset. What the self-certification does not include is an analysis ascertaining that the futures contract is not readily susceptible to price manipulation such as an analysis of the cash settlement index itself. How does the CFTC ensure that the contract is consistent with the guidance under appendix C of Core Principle 3 without this analysis?
