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Custody

In prediction markets, custody refers to who holds the funds backing a trader's positions and under what legal and operational protections. On CFTC-regulated exchanges, a Derivatives Clearing Organization holds customer funds in segregated accounts; on decentralized platforms, smart contracts or crypto wallets hold assets directly.

Updated June 24, 2026Regulation & Risk
TL;DR
Custody determines whether your funds are protected by federal regulation or left in your own hands. Regulated exchanges segregate funds; decentralized platforms put custody control with the trader and the smart contract.

Key Points

CFTC rules require Derivatives Clearing Organizations (DCOs) to hold customer funds in segregated accounts, separate from the exchange's own capital, reducing risk of loss in insolvency.
Kalshi's affiliated DCO holds US customer collateral in a dedicated account structure that cannot be used for operating expenses or proprietary trading.
On Polymarket and other blockchain-based platforms, custody is held by smart contracts on Polygon, with positions collateralized in USDC — giving traders self-custody but no regulatory backstop.
Custodial arrangements on regulated platforms are subject to CFTC inspection and must follow rules on permissible investments for segregated funds, limiting risk.
Crypto-wallet self-custody on decentralized markets means a lost private key or smart contract exploit can result in permanent, unrecoverable loss of funds.

Custody on CFTC-Regulated Exchanges

On a Designated Contract Market operating under CFTC oversight, customer funds deposited as collateral for Event Contract positions are subject to strict segregation requirements. The exchange's affiliated Derivatives Clearing Organization holds these funds in accounts legally separate from the platform's operating capital. CFTC rules prescribe which instruments the segregated funds may be invested in — primarily US Treasuries and money market funds — to ensure they remain liquid and low-risk. Revised DCO rules finalized in 2025 further strengthened investment restrictions and mandated additional funding mechanisms for DCO guarantee funds. In the event of platform insolvency, segregated customer funds are prioritized for return to traders before any other creditors are paid. Kalshi publicly discloses that the first layer of user protection is this segregated account structure, distinct from SIPC or FDIC coverage.

Self-Custody on Decentralized Platforms

On Decentralized Prediction Market venues like the original Polymarket (pre-US relaunch), asset custody sits with the trader and the blockchain protocol. Users connect a Crypto Wallet such as MetaMask, deposit USDC Collateral into smart contracts, and receive on-chain position tokens. The platform operator never holds funds directly, which eliminates traditional Counterparty Risk from exchange insolvency. However, this model introduces distinct hazards: smart contract bugs can drain funds irrecoverably, USDC depeg events (where the stablecoin loses its dollar peg) reduce collateral value, and lost private keys mean permanent loss with no recourse. There is no regulatory body to complaint to, no segregation audit, and no guarantee fund. Traders on decentralized platforms therefore bear full personal responsibility for custody security, including wallet hygiene, seed phrase storage, and approval management to avoid phishing exploits.

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