DICE ETF Launches on Cboe Giving Retail Investors Pre-IPO Access to Kalshi and Polymarket
Tema ETFs launched DICE (Tema Trading & Prediction Markets ETF) on Cboe on September 9 — the first ETF offering retail exposure to private companies Kalshi and Polymarket before their IPOs. Each platform is held at approximately 7.3% via an SPV. The fund also holds Robinhood and Coinbase. Expense ratio: 0.75%. Tema cites the Bernstein $1 trillion annual volume projection by 2030 as the fund thesis.
Tema ETFs launched the Tema Trading & Prediction Markets ETF (DICE) on Cboe on September 9, 2026 — the first ETF to give retail investors direct economic exposure to Kalshi and Polymarket before either company IPOs. Kalshi and Polymarket each account for approximately 7.3% of DICE's total assets (15% combined), accessed through a special purpose vehicle that holds stakes in the private companies. The remaining 85% is publicly traded companies including Robinhood Markets (HOOD) and Coinbase Global (COIN). Expense ratio: 0.75%. Tema President Steve Munroe cites Bernstein's $1 trillion annual volume projection by 2030 as the fund thesis.
For UK readers, the SPV structure is the key mechanism. An ETF normally holds publicly listed securities whose prices update continuously in a market. A special purpose vehicle allows the ETF to reference a private-company equity stake — Kalshi and Polymarket are both private — by packaging the stake in a separate legal entity that the ETF can hold as a portfolio asset. The SPV's value is typically marked to a reference price from the most recent secondary transaction or third-party valuation rather than a live market price, which means the ETF's exposure to Kalshi and Polymarket does not update in real time the way its Robinhood and Coinbase holdings do. The structure is commonly used for pre-IPO exposure ETFs in the UK alternative investment market as well. Its limitation is that private valuations can lag market sentiment materially in either direction.
The Robinhood and Coinbase holdings are the publicly traded legs of the fund's prediction market thesis. Robinhood Derivatives is one of the five largest prediction market platforms in the US; its contribution to Robinhood's total revenue and user engagement has grown substantially in 2026 as sports contract volume surged. Coinbase operates Coinbase Predictions and is named as a co-defendant in the Baltimore City lawsuit against Kalshi, reflecting its role as a distribution partner for Kalshi's sports contracts. Holding HOOD and COIN gives DICE liquid exposure to the prediction market sector's growth while the Kalshi and Polymarket SPV positions provide higher-beta private-company upside if either platform IPOs at a premium to current private valuations.
The timing of the DICE launch — September 9, 2026 — is significant. It follows the Ninth Circuit's August 28 ruling against Kalshi (adverse to the platforms), the Robinhood Michigan stipulation (signals regulatory risk), and two SCOTUS cert petitions accumulating. A fund manager that believes the legal risk is terminal would not launch a 15%-private-prediction-market ETF during this window. Tema's launch implicitly argues that the legal uncertainty is temporary, that SCOTUS will eventually resolve the circuit split in a way that preserves platforms' national operating ability, and that the $14.1 billion in weekly volume the sector was generating in NFL kickoff week is the correct baseline for projecting forward — not the disrupted scenario where state enforcement succeeds in fragmenting the market. Whether that assessment proves correct will determine DICE's performance more than any individual market movement in the fund's publicly traded holdings.
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Recent updates
Utah Files Felony Charges Against Kalshi and Its Founders — Second State to Criminally Charge a Platform
Utah filed criminal charges against Kalshi and its two co-founders, Tarek Mansour and Luana Lopes Lara, on October 28 — 13 felonies and a misdemeanour, including a second-degree 'pattern of unlawful criminal activity' count and 12 counts of online gambling promotion. The charges stem from a September sting in which an undercover agent placed 12 sports wagers verified to be in Utah. The CFTC sued Utah the day before to block state enforcement, its tenth such suit. Utah is the second state after Arizona to criminally charge Kalshi, and the first to charge the founders personally. Kalshi called it a 'crazy overreach.'
NBA Names Kalshi and Polymarket Preferred Exchanges — Leaving the NFL Alone in Opposition
The NBA announced on October 26 that it has named Kalshi and Polymarket its 'preferred prediction market exchanges,' signed a non-binding memorandum of understanding with the CFTC on basketball integrity, and expanded its DraftKings deal to include prediction markets — the first league to extend a sportsbook partnership into the category. The exchange deals bar league and team personnel from trading NBA contracts, limit permissible markets, and require sharing suspicious-trading data, in exchange for NBA intellectual property and official data. The NBA joins MLB, the NHL, and MLS as partnered leagues, leaving the NFL as the lone major holdout — and the only league fighting the platforms in court.
CFTC Chair Says Agency Is Watching Prediction Markets for Manipulation Ahead of Midterms
CFTC Chairman Michael Selig said on October 23 that the agency is closely monitoring prediction markets for manipulation ahead of the November 3 midterms, and that it is separately scrutinising oil market trading tied to President Trump's announcements about the war in Iran. Combined midterm open interest on Kalshi and Polymarket stood at $250 million as of October 18, with Kalshi holding 84%. Selig acknowledged the agency often catches political figures trading 'oftentimes after the fact.' The remarks highlight the CFTC's dual role as both the platforms' federal protector and their manipulation watchdog.