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On 27 October 2026, the Capital Markets Board of Türkiye (Sermaye Piyasası Kurulu) adopted the procedures for liquidating and paying out certain investment funds under Law No. 7596. These procedures determine which holders of fund units receive interim payments, in what order and up to what amount. Individual investors who hold units in the affected funds are directly exposed to these rules, which govern how much they can recover, in what order and on what conditions.
What changed
Law No. 7596 on Certain Investment Funds Ordered into Liquidation is dated 22 October 2026. It was published in the Official Gazette (Resmî Gazete) No. 33413 on 27 October 2026. The Law leaves certain matters to the Capital Markets Board of Türkiye (the "Board"), which is the capital markets regulator.
The Board set out the procedures in its decision dated 27 October 2026, which is meeting no. 76, decision no. 1903. The decision appears in Bulletin No. 2026/76, the Board's weekly bulletin through which it publishes its decisions and announcements. The decision is listed among the Board's principle decisions, which are general rulings binding on market participants.
The decision provides for the following points:
- The liquidation begins for the funds founded by Tera Portföy Yönetimi AŞ, Pusula Portföy Yönetimi AŞ and Atlas Portföy Yönetimi AŞ that the Board placed into liquidation by its decisions of 17 September 2026.
- T.C. Ziraat Bankası AŞ liquidates the funds founded by Pusula and Atlas, and Türkiye İş Bankası AŞ liquidates the funds founded by Tera.
- The Board coordinates the process together with the Savings Deposit Insurance Fund (Tasarruf Mevduatı Sigorta Fonu), Borsa İstanbul, the Central Registry Agency (Merkezi Kayıt Kuruluşu), Takasbank and the Banking Regulation and Supervision Agency (Bankacılık Düzenleme ve Denetleme Kurumu).
- Interim payments are made under Article 4(2) or 4(3) of the Law and the Board's decisions of 30 September and 15 October 2026.
- Interim payments start with funds whose names contain the words "money market" (para piyasası).
Under Article 4(2), the interim payment per fund must not exceed the net investment amount, calculated by the Central Registry Agency without indexation, and must not exceed TRY 1 million. Where distributable cash cannot cover all such amounts, Article 4(3) applies. The interim payment is then capped at the lowest of the following amounts:
- the net investment amount;
- the amount calculated as of the end of the day before 17 September 2026 for money market funds, or as of the end of the day before the calculation date for other funds;
- the TRY 1 million cap.
Where a fund's distributable cash covers the full value of the units at the unit price applicable at the end of the day before the liquidation decision, a final payment is made instead of an interim payment.
For funds other than money market funds, payments begin with the fund that has the highest ratio of distributable cash to total interim payment obligations. Between funds with equal or similar ratios, the liquidating bank gives priority to the fund whose cash covers the largest number of investors.
No payment is made from the liquidation and recovery account to persons and entities that the Board determines to have committed, or acted together in, acts under Articles 104, 106 or 107 of Capital Markets Law No. 6362. This exclusion applies under Article 3(6) of the Law once the Central Registry Agency notifies the liquidating banks.
Amounts transferred to the general share return account (genel hisse iade hesabı) are allocated first to money market funds. Priority goes to those with the lowest interim payment coverage and the most investors whose net investment amount is below TRY 1 million. Any remainder is allocated to other funds on the same principles.
Who is affected
The rules apply to every individual investor who holds units in the funds founded by the three portfolio management companies. For these natural persons, the type of fund determines when an interim payment is likely to be made, because money market funds are paid first. The amount of the interim payment is limited by the net investment amount and by the TRY 1 million cap. Individual investors whose net investment amount is below TRY 1 million are the group to which the decision gives priority when funds from the general share return account are allocated. Individual investors with larger holdings retain an outstanding claim above the cap until the final liquidation payment. Individual investors whom the Board identifies under Article 3(6) of the Law are excluded from payment.
What this means in practice
In practice, the first point being reviewed by individual investors is which of the three portfolio management companies founded the fund in which they hold units, because this determines whether Ziraat Bankası or İş Bankası handles the payment. Whether the fund's name contains the words "money market" is also being checked, because the order of payment differs by fund type. Individual investors are comparing the net investment amount recorded by the Central Registry Agency with their own purchase and redemption records. Because that amount is calculated without indexation, the difference between the amount originally invested and the current unit value is being quantified. Individual investors whose net investment amount exceeds TRY 1 million are calculating the portion of their holding that remains unpaid after the cap applies. The balance that remains after each interim payment is being tracked until the final liquidation payment is made.
Source: Capital Markets Board Bulletin No. 2026/76 — https://spk.gov.tr/data/6ae049c98f95db0c143f6579/2026-76.pdf (27 October 2026)
This article is for general information purposes only and does not constitute legal advice.