Custody · Counterparty

Where Does Your Money Actually Sit?

Both venues will tell you their contracts are fully collateralised, and both are telling the truth. Neither statement is a promise that you get your money back if the venue fails. On Kalshi your money is cash in a segregated bank account governed by a CFTC rule. On polymarket.com it is a token at an address on a public blockchain, and nobody at Polymarket can move it or return it. This page is about that difference, and about three words used interchangeably when only one of them means insurance.

Fully collateralised is not the same as insured

Polymarket's help centre puts the collateral claim like this:

“every pair of event outcomes (i.e. each pair of ‘YES’ + ‘NO’ shares) is fully collateralized by $1.00 USDC” help.polymarket.com, What is Polymarket, read 11 August 2026

Kalshi's event contracts work on the same principle: every side is paid for in advance, and a resolved market pays out of collateral posted before the trade existed.

That rules out a real failure mode. Neither venue can be short of money because a position moved against somebody who could not pay. There is no leverage on an ordinary event contract, so no margin call and no forced liquidations.

What it does not rule out is everything else. Notice what the sentence is a claim about. It is a claim about the contract: the pot is full. It says nothing about who holds the pot, whether they may spend it, what happens to it in a bankruptcy, or whether anybody will make you whole if it goes missing. Three claims get compressed into the word “safe”, and only one is insurance.

The claimWhat it actually promisesWhat it does not cover
Fully collateralised Every contract is paid for in advance, so a payout is never funded by a counterparty who might default. Theft, insolvency, a lost key, a resolution you disagree with, or the platform simply being unreachable.
Segregated Customer money is accounted for separately from the company's own money and may not legally be spent on running the business. A shortfall in the segregated pool itself. Segregation is a legal and accounting boundary, not a top-up.
Insured A named third party pays you if a defined event happens. Everything outside that definition. There is no such third party for either venue's trading balance.

Why neither SIPC nor the FDIC applies

SIPC is the body that steps in when a stockbroker fails, and it is explicit about the boundary:

“SIPC does not protect commodity futures contracts (unless held in a special portfolio margining account)” sipc.org, What SIPC Protects, read 11 August 2026

The same page excludes “investment contracts… that are not registered with the U.S. Securities and Exchange Commission”. Event contracts on a CFTC-designated exchange sit on the futures side of the fence, not inside a SIPC-member brokerage. Wrong body.

The FDIC is the wrong body for a subtler reason. Its insurance covers bank deposits against the failure of the bank, and its own list of products it does not insure names “Stock Investments, Bond Investments, Mutual Funds, Crypto Assets… Annuities, Municipal Securities” among others. So when a venue says it keeps customer cash at FDIC-insured banks, note what is insured and against what: the cover protects that deposit from the bank going under. It does not protect you from the venue going under, and it does not attach to an open position at all. “Held at an FDIC-insured bank” and “your balance is insured” are different sentences, and only the first is usually the one being said.

And collateralisation is no longer universal inside one venue

Kalshi now lists margined perpetual futures alongside its event contracts, and its documentation for that product says:

“As with any margined futures, losses in black swan scenarios can exceed posted margin.” help.kalshi.com, How Margin Works, read 11 August 2026

Same platform, same login, opposite risk profile. On an event contract your maximum loss is the money you put in. On a margined perpetual it is not.

Kalshi: the CFTC segregation rules

Kalshi is two registered entities doing two different jobs, and the split is the point of the structure. KalshiEX LLC is the designated contract market, where contracts are listed and matched. Kalshi Klear LLC is the clearing house, and the CFTC issued it an Order of Registration as a derivatives clearing organisation effective 28 August 2024. Your money sits on the clearing side.

The rule that governs it is 17 CFR 1.20. It requires a futures commission merchant to

“separately account for all futures customer funds and segregate such funds as belonging to its futures customers” 17 CFR 1.20(a), read 11 August 2026

in an amount “at least sufficient in the aggregate to cover its total obligations to all futures customers”. The same regulation forbids commingling customer funds with the firm's own money, securities or property, and forbids using them to

“secure or guarantee the commodity interests, or to secure or extend the credit, of any person other than the futures customer for whom the funds are held” 17 CFR 1.20(f)(1), read 11 August 2026

As a set of prohibitions that is strong. Your balance cannot lawfully be lent to the exchange's operating company, pledged against its debts, or used to fund another customer's losing position. Kalshi describes its margin accounts in the same terms: margin “is held in a customer-segregated account, separate from Kalshi's operating funds, as required by CFTC regulations”.

Now note what segregation is, mechanically, because this is where most readers stop early. It is a legal and accounting boundary drawn around a pool of money sitting at a bank, enforced by rules, audits and the threat of enforcement. It is not a guarantee fund. It does not put money into the pool if the pool turns out to be short. A firm that breaks the rule has broken the rule, and customers still have to be paid out of whatever is actually there.

Polymarket: USDC on Polygon, and what that means

Polymarket's answer to the custody question is that there is no custody:

“Polymarket is non-custodial, so you're in control of your funds” … “we never take possession of your USDC” help.polymarket.com, Is My Money Safe?, read 11 August 2026

Mechanically: your collateral is USDC, a dollar-referenced token issued by a private company, held at an address on Polygon, a blockchain separate from Ethereum. Your positions are token balances at that address, and moving any of it needs a signature from the key that controls it. Polymarket runs the interface, the matching and the resolution. It does not hold the balance. That cuts both ways.

In your favour

There is no account to freeze

No balance exists to be suspended, seized in a corporate bankruptcy, or spent on payroll. If the servers went dark tonight, the USDC at your address would still be there in the morning.

Against you

There is also nobody to appeal to

Nobody can reverse anything: no fraud department, no chargeback, no password reset that recovers a key. The collateral is a token, not a deposit, so its value depends on the issuer honouring redemption. And your balance sits in a public ledger, visible to anybody with the address.

Self-custody versus the platform holding keys

“Non-custodial” is a property of the architecture. Whether it is a property of your account depends on how your key is stored, which is not obvious from the screen. The only test that matters: who can produce a valid signature without your involvement?

  • You hold the key. A wallet you set up, with a recovery phrase you control. Nobody can move your funds, and nobody can help you if you lose it.
  • Somebody else holds it for you. An embedded or social-login wallet, a custodial exchange account, or a bot you granted signing rights to. It reintroduces the counterparty you were told did not exist.

Polymarket states that “You can export your private key at any time, ensuring sole access to your funds”, so the test is one you can run. The same page states the cost of being your own custodian:

“Losing your private key or passwords can result in losing access to your funds.” help.polymarket.com, Is My Money Safe?, read 11 August 2026

There is no recovery process behind that sentence. Treat the recovery phrase as the asset, because here it is.

Whether your money can move at all

Polymarket publishes a geoblock endpoint. Read on 5 August 2026 and checked again on 11 August 2026, it lists the United States as close-only on both the frontend and the API: existing positions may be closed and new ones may not be opened. The same status applies to the United Kingdom, France, Germany, Italy, Poland, Belgium, Slovakia, Australia, Singapore and four Canadian provinces (British Columbia, Ontario, Alberta and Quebec), among others. If you are in one of those places, the answer to this page's title is: in a position you can exit and cannot add to.

Polymarket US is a different thing with a similar name

QCX LLC, operating under the assumed name Polymarket US, appears on the CFTC's filings register as a designated contract market, dated 9 July 2025, with the remark that “QCX LLC is now operating under the assumed name of Polymarket US”. Its clearing house, QC Clearing LLC trading as Polymarket Clearing, is a registered derivatives clearing organisation. That venue has segregated customer funds and sits structurally closer to Kalshi than to polymarket.com, so look up the entity, not the logo.

The acquisition that brought that entity under the Polymarket name is widely reported with a specific price attached. We have not found that figure in any filing, order or other primary document, so it does not appear here. The amount is not independently verified. The registrations above are.

What happens if the venue fails

Kalshi: a commodity broker bankruptcy, and the words “pro rata”

Failures on the regulated side run through 17 CFR Part 190, the CFTC's bankruptcy rules for a commodity broker, which define customer property as

“the property subject to pro rata distribution in a commodity broker bankruptcy” 17 CFR 190.01, read 11 August 2026

Pro rata is the phrase to hold on to. If the segregated pool is whole, customers are made whole. If it is short, customers share the shortfall in proportion to their claims. Nobody tops it up. The rules also keep account classes distinct, so futures, cleared swaps and delivery accounts are distributed separately rather than pooled.

Then there is time, which nobody puts in the marketing copy. Even an orderly case needs a trustee appointed and claims verified. Money that is legally yours is not money you can spend this week.

polymarket.com: nothing to seize, and nobody left to resolve

There is no bankruptcy estate holding your collateral, because no estate ever held it. Your USDC stays at your address regardless of what happens to the company. What fails instead is everything the company was providing: the order book, price discovery, the interface, and above all resolution. An unresolved market is collateral locked in a contract with nobody left to declare the outcome. You would hold the position and not the payout. The exposure is not theft, it is abandonment.

Neither venue has a compensation scheme

No SIPC equivalent, no FSCS equivalent, no deposit guarantee, no industry fund. The recovery path on one side is a bankruptcy process with pro rata arithmetic and a queue. On the other it is a smart contract and your own key.

The Panama question

Counterparty risk is not only a question about money. It is a question about who you would have to find.

Polymarket's Panamanian corporate filings give a headquarters address on the 21st floor of the Oceania Business Plaza in Panama City. NPR went to it and published what it found on 5 May 2026: a law office, a lobby opening onto a room with about a dozen unoccupied computer stations, no sign of Polymarket and no sign of Adventure One QSS Inc, the entity Polymarket does business as in Panama. A worker there had not heard of either name. NPR also reported that at least 15 other cryptocurrency companies use the same office as their registered headquarters.

Be careful about what that does and does not establish. Registering at a law firm's address is ordinary corporate practice in many jurisdictions and is not evidence of wrongdoing. What the finding establishes is narrower and still material: the address in the public record is not a place where you would find anybody responsible for your money.

That matters because an address is what a dispute needs. Segregation is enforceable because there is a named registrant, a regulator, and a court that will hear the case. When the registered address resolves to a shared law office in a jurisdiction you have no relationship with, “who do I bring a claim against, and where” has no cheap answer. That is not a claim that your funds are at risk. It is a claim that your recourse is thin, and recourse is most of what you are buying when you accept a counterparty.

Kalshi's answer is dull, and dull is the point: named US entities, a named regulator, a public filings register, and a clearing house whose order of registration is published. That is not a verdict on which venue prices better. It is a difference in where you would be standing if something went wrong.

What neither venue protects you from

Custody gets the most attention of the four ways to lose money here and causes the least damage. The other three are constant, and untouched by either venue's custody arrangement.

Resolution

Somebody has to decide what happened. A market that reads unambiguously to you can resolve against you on a technicality in its own rules text, and the rules text is the contract. No segregation rule and no smart contract protects you from an outcome you did not anticipate, and disputing one is a process rather than a right.

Cost

Fees and spread are certain. Profits are not. Both venues charge a taker fee proportional to price multiplied by one minus price, so it is not a flat percentage: per contract it is largest in the middle of the book and shrinks toward both ends. Polymarket's published formula is fee = C × rate × P × (1 - P), charged to takers only, with makers at a verified zero. Kalshi's is the same shape, rounded up to the cent. Applying a flat rate in your head underestimates the cost of exactly the coin-flip markets you are most drawn to.

Depth

A price you can see is not a price you can fill. A position you can enter and cannot leave near the screen price is a loss that has not printed yet, and thin books are the norm where mispricing lives.

And one that belongs to this page: your own operations

On the segregated side, the realistic failure modes are a compromised login and a mistaken withdrawal instruction. On the self-custody side it is the key, which has no appeal process. Neither is a platform risk. Both are yours, and between them they account for more lost money than venue insolvency ever has.

Prediction markets are not legal everywhere, and the geoblock list above is a snapshot of one endpoint on one day.

Primary sources

Every claim above, and where it came from

  • 17 CFR 1.20 Segregation of customer funds. Read 11 Aug 2026.
  • 17 CFR Part 190 Commodity broker bankruptcy. Read 11 Aug 2026.
  • SIPC, What SIPC Protects sipc.org/for-investors/what-sipc-protects. Read 11 Aug 2026.
  • FDIC, Financial Products That Are Not Insured fdic.gov/resources/deposit-insurance/financial-products-not-insured/. Read 11 Aug 2026.
  • CFTC press release 8957-24 Kalshi Klear LLC DCO registration, effective 28 August 2024. Read 11 Aug 2026.
  • CFTC industry filings registers QCX LLC d/b/a Polymarket US, Designated, 9 July 2025, and QC Clearing LLC d/b/a Polymarket Clearing. Read 11 Aug 2026.
  • Polymarket, What is Polymarket Read 11 Aug 2026.
  • Polymarket, Is My Money Safe? Read 11 Aug 2026.
  • Polymarket geoblock endpoint docs.polymarket.com/api-reference/geoblock. Read 5 Aug 2026, checked again 11 Aug 2026. Carries no date and no version number.
  • Kalshi How Margin Works, and Your Perpetuals Margin Account. Read 11 Aug 2026.
  • NPR, 5 May 2026 “NPR went looking for Polymarket's Panama headquarters. It's elusive”. Read 11 Aug 2026.
  • Fee formula shapes This site's own scanner/fees.py, where every coefficient carries its citation and verification date.

Two things deliberately not printed here. An acquisition price: a figure for the QCX LLC acquisition circulates widely and we could not trace it to a primary document, so it is absent rather than hedged. A metric of our own: no honest number from our own testing belongs on a custody page, so it ships with none. Corrections will be published here, dated, with the original wording left readable.

Disclosure

PredictionEdge is free to use. No sign-up and no paywall. The Polymarket buttons on our scanner page carry a referral code, which means Polymarket pays us if a reader opens an account through one. That changes nothing about which candidates the scanner finds or how it ranks them, and the Kalshi buttons pay us nothing at all. This page carries no referral link. Nothing here is financial advice.