Tera Portföy Fund Liquidation: Law No. 7596 and the Payment Process

01 · At a glance

At a glance

Key figures and where the process stands today. Details are in the sections below; each tile shows its source.

131funds whose liquidation has been ordered · full listSPK Bulletin 2026/61
455,758unique investors (according to MKK records)SPK, 23.09.2026
38fundsstill in liquidation (from 131; latest official count); payments totalling TRY 117.6 billion made to 446,040 investors8th Fund Coordination Board, 28.10.2026 · Anadolu Agency and DHA reports, 04.11.2026 · press report
TRY 1millioninterim payment cap — per investor, separately for each fund; not a ceiling on total payments; Law No. 7596 in force since 27 October 202664/1775 · SPK, 01.10.2026 · Law 7596 art. 4(2)
16.11.2026last day to bring an action for annulment against 57/1708 (preclusive)İYUK art. 7 · calendar calculation
≈ 17.03.2027end of the maximum liquidation period (the SPK may extend it)59/1710

Calculation toolFund value calculatorFor each of the 131 funds on the liquidation list: purchase cost by purchase date and number of units, the value on 17 September 2026, and the current value at the latest price published on TEFAS (Turkey Electronic Fund Trading Platform).

Where things stand · 05.11.2026

Done: 17.09.2026SPK decisions57/1706–57/1708: the funds were closed to trading on TEFAS and the liquidation of 131 funds was ordered. Liquidation rules
Done: 28.09.2026SPK announcementInstructions of 17 September paid pro rata; instructions transmitted on or before 16 September and not executed fall under A/6. A/6
Done: 08.10.2026Payments in 17 fundsA1 Capital, Bulls and Pardus funds: proceeds transferred to banks and brokerage firms. List
Done: 14.10.2026Bill adopted in committeeBill 2/3939, Planning and Budget Committee. Law 7596
Done: 15.10.2026Hedef funds in ordinary liquidationSPK 70/1821: removed from the interim payment scheme. Payments
Done: 18.10.2026Liquidation completed in 66 fundsA1 Capital, Bulls, Pardus (Government statement, press report). List
Done: 20.10.2026First payments at HedefHYV, HDK, HAT and HGH (company statement, press report; TEFAS 21 Oct). Payments
Done: 21.10.2026General Assembly adopts Articles 1–5PBLK sentence added to Article 3. Law 7596
Done: 22.10.2026Hedef: liquidation completed in 18 of 31 funds7th Fund Coordination Board (press report); 47 funds in liquidation. The list shows 19 Hedef funds as “Paid” on the TEFAS record of 05.11.2026; not confirmed to be the same funds. Payments
Done: 22.10.2026General Assembly adopts the bill: Law No. 7596Articles 6–9 unchanged, the bill as a whole by electronic vote; sent to the Presidency the same day. Law 7596
Done: 26.10.2026Activities of Tera Portföy and Pusula Portföy suspendedSPK Bulletin 2026/75: liquidators appointed for their funds outside the 17 September decisions (İş Bankası, Ziraat Bankası); these funds are outside Law 7596. Details
Done: 27.10.2026Publication in the Official Gazette and entry into forceLaw No. 7596, Official Gazette of 27 October 2026, No. 33413 (resmigazete.gov.tr); with effect from 17 September 2026 (art. 8). Law 7596
Completed: 27.10.2026SPK 76/1903: procedures for the interim paymentInterim payment in the Tera, Pusula and Atlas funds; funds named “para piyasası” (money market) first; paid by İş Bankası (Tera) and Ziraat Bankası (Pusula, Atlas). The decision gives no date (Bulletin 2026/76). How will it work?
Completed: 28.10.20268th Fund Coordination Board: 38 funds in liquidationTRY 68 billion to 71,899 accounts; in Hedef, the liquidation work in 27 of 31 funds “largely” completed as at 23 October 2026 (as reported in the press). Payments
Completed: 30.10.2026First interim payments beganTRY 29.3 billion to 235,705 investors in 7 money market funds (Anadolu Agency, as reported in the press). The split by fund has not been disclosed; up to TRY 1 million, separately for each fund. How does it work?
Completed: 03.11.20269th Fund Coordination BoardAs at 30 October 2026, TRY 97.3 billion to 247,839 investors in 100 funds; interim payments to continue “this week” (as reported in the press). Developments
Completed: 04.11.2026Payments continued: TRY 117.6 billion in totalTRY 62.2 billion to 390,219 investors in the extraordinary liquidation; TRY 55.4 billion to 55,821 investors in the ordinary liquidation (Anadolu Agency and DHA reports). No fund list has been published. How does it work?
Pending: Mid-November (target)Remaining interim payments (Tera, Pusula, Atlas)target · no date in the SPK decisionVice President (27 October 2026): the process is expected to be completed “by mid-November” (as reported in the press). No fund-by-fund timetable or list has been published. Payments
Pending: ≤ ≈17.03.2027Final distributionWithin the maximum liquidation period; the SPK may extend it. Calendar

Important information

At this stage no lawyer can guarantee that unitholders will recover all, or any particular part, of their savings in the funds. Payments will be made under the liquidation rules set by the SPK, after the custodian banks have converted the fund assets into cash, and pro rata to unitholdings. This note outlines the avenues of application that the legislation provides for protecting rights in this process.

This note has been prepared for the information of the public. It is not intended to solicit business, does not create a lawyer–client relationship and is not legal advice on any specific matter. Data cut-off: 5 November 2026.

02 · Payments

When will the funds in liquidation be paid?

As at 5 November 2026: The 34 funds of Tera, Pusula and Atlas Portföy: by decision 76/1903 of 27 October 2026 the SPK set the procedures and principles for the interim payment under Law No. 7596. Interim payments began with funds whose names include the words “para piyasası” (money market); payment is made by T.C. Ziraat Bankası in the Pusula and Atlas funds and by Türkiye İş Bankası in the Tera funds; the amount is capped fund by fund at TRY 1 million and at the net investment amount (details). The first interim payments began on 30 October 2026 in 7 money market funds (TRY 29.3 billion; the codes given in the press are TP2, TLV, PRY, PNU, PKM, PPT and PSE). According to press reports of 4 November 2026 (Anadolu Agency and DHA), the extraordinary liquidation total has reached TRY 62.2 billion paid to 390,219 investors; the principal of 133,839 investors has been covered in full. No fund list or split by fund has been published. The Vice President had said that the process is expected to be completed by mid-November; this is a target, not a fixed date. Other funds: according to the 8th Fund Coordination Board, the number of funds in liquidation has fallen from 131 to 38, and since the start of the process liquidation payments in kind and in cash totalling TRY 68 billion have been made to 71,899 accounts; according to the 9th Fund Coordination Board, TRY 97.3 billion had been paid to 247,839 investors in 100 funds as at 30 October 2026. The total reported in the press on 4 November 2026 is TRY 117.6 billion to 446,040 investors (TRY 55.4 billion to 55,821 investors in the ordinary liquidation). No reason has been given for the ordinary liquidation amount appearing lower than the earlier TRY 68 billion. The liquidation of the 66 funds of A1 Capital, Bulls and Pardus Portföy has been completed. The 31 funds of Hedef Portföy have been in ordinary liquidation since 15 October 2026; according to the 8th Fund Coordination Board, the liquidation work in 27 of them had been “largely” completed as at 23 October 2026, and work on the remaining 4 continues. Which funds are meant has not been disclosed; according to the TEFAS record of 05.11.2026, the portfolios of 19 funds have fallen to residual amounts. The two counts rest on different bases; it has not been confirmed that the funds are the same (explanation). In KSA, HPH and HKJ part of the portfolio appears to have been distributed in the record of 26 October 2026; no payment has been announced.

How will the interim payment be made? SPK decision 76/1903

27 October 2026 · SPK Bulletin 2026/76. Primary source By decision 76/1903 of 27 October 2026 the SPK set the procedures and principles for the liquidation and payments under Law No. 7596 (PDF). Under Article 3 of the decision, “interim payments are made to the unitholders” (pay sahiplerine ara ödeme yapılır) of the investment funds under liquidation founded by Tera Portföy Yönetimi AŞ, Pusula Portföy Yönetimi AŞ and Atlas Portföy Yönetimi AŞ. Payments begin with funds whose names include the words “para piyasası” (money market) (art. 4). The liquidation is carried out by T.C. Ziraat Bankası AŞ for the Pusula and Atlas funds and by Türkiye İş Bankası AŞ for the Tera funds (art. 2); the interim payment is also made by “the banks charged with the liquidation” (art. 6).

Amount (art. 6)

The interim payment is made fund by fund and “may not exceed the net investment amount calculated by MKK without indexation, or TRY 1 million”. If the fund’s distributable cash is insufficient for all interim payments, the payment may not exceed the lowest of the following amounts, calculated by MKK and sent to the banks: (i) the net investment amount; (ii) for funds whose names include “para piyasası”, “the amount calculated as at the end of the day before 17.09.2026, the date of the liquidation decision” and, for other funds, “the amount calculated as at the end of the day before the date on which the interim payment amount is calculated”; (iii) “the TRY 1 million interim payment cap”.

Order (art. 4, 7, 8)

Funds named “para piyasası” first. In the other funds, payment begins with the fund with the highest ratio of distributable cash to total interim payment obligations; where ratios are equal or close, the fund in which the most investors can be paid with the available cash comes first; the banks set the order. If cash is insufficient, an order from the unitholder with the smallest interim payment amount to the largest may be set, and/or the Board may approve payment up to a minimum interim payment amount applied to all.

Units and final payment (art. 5, 10)

“Interim payments are made without the participation units being redeemed.” Units are redeemed on the final payment; the interim payment is set off against the amount due on the final payment. If a fund’s distributable cash covers the total amount calculated at the unit price at the end of the day before the liquidation decision, a final payment is made instead of an interim payment.

Payment ban and share return account (art. 9, 11)

No payment is made from these funds’ liquidation and recovery account to persons and entities that committed the acts under SPKn art. 104, 106 or 107 and that are “determined by the Board and notified by MKK to the institutions charged with the liquidation”; the list has not been made public. Amounts transferred to the general share return account go first to the money market funds with the lowest coverage of interim payments and the largest number of investors whose net investment amount is below TRY 1 million.

What the decision does not say. The start date of payments; whether unitholders need to apply and into which account the payment will be made; the names or codes of the funds in which the interim payment is made (the funds are identified by founder); the calculation period, method and “accounts announced by the Board” for voluntary returns (Law art. 4(4)). The SPK’s press release of 27 October 2026 and its “10 Questions” text contain no information on these points either (spk.gov.tr, PDF). As at 5 November 2026 no announcement by the SPK, MKK, Ziraat Bankası or İş Bankası on the payment procedure had been found.

When? Press report The first interim payments began on 30 October 2026. According to the Directorate of Communications’ statement on the 9th Fund Coordination Board (3 November 2026, as reported in the press), TRY 29.3 billion had been paid in the extraordinary liquidation as at 30 October 2026, and interim payments will continue “this week”. According to press reports of 4 November 2026 (Anadolu Agency and DHA), TRY 62.2 billion in total has been paid to 390,219 investors in the extraordinary liquidation, and the principal of 133,839 of them has been covered in full. No official text of these figures was found; neither fund names nor a cut-off date were given. The SPK decision gives no date. Vice President Cevdet Yılmaz told the TBMM Planning and Budget Committee on 27 October 2026 that they expect the process to be completed “by mid-November” (as reported in the press); this is a target, not a fixed date. There is no official statement that all unitholders were paid on the same day or up to the cap. (Anadolu Agency report, Memurlar.net · Sabah · ANKA report, Karar)

Which funds? Press report The official texts give no fund codes. A report in Takvim lists TP2, TLV, PRY, PNU, PKM, PPT and PSE; these seven codes match the listed funds of the three founders whose names include “para piyasası”. No list of the funds paid as at 4 November 2026 has been published. YatırımX, relying on receipts shared by investors, wrote that interim payments dated 4 November 2026 were seen in DFI; the receipts have not been independently verified, and no fund-level confirmation was found for other funds.

How much was paid? Press report TRY 1 million is a cap; it does not mean every investor is paid that amount. According to the 9th Fund Coordination Board statement, about TRY 76 billion in cash and in kind was paid to 178,537 unique investors, whose principal was covered; according to reports of 4 November 2026, 133,839 investors in the extraordinary liquidation have had their principal covered in full. The two counts have different scopes. BirGün (31 October 2026), relying on individual account movements, wrote that many investors received payments of “at most TRY 250,000”. This is a press observation; no text was found in which the SPK, the MKK or the appointed banks announce a limit or minimum of TRY 250,000. Art. 8 of decision 76/1903 allows, if cash is insufficient, ordering from smallest to largest and/or, with Board approval, a minimum amount applied to everyone; whether it has been applied has not been disclosed, and SPK Bulletin 2026/78 (30 October 2026) contains no decision on this. According to Anadolu Agency, investors found to have made unfair and excessive gains were left outside the interim payment (76/1903 art. 9); no list has been published.

In the Law, funds of a money market nature are exempt from the cap based on the current value of the units (art. 4(2)); the decision, however, provides that where cash is insufficient the amount calculated as at the end of the day before 17.09.2026 is a cap for funds named “para piyasası”. Estimate: Tool 1 · the rule in the Law: payment rule diagram.

Completed66 funds · Ziraat Bankası

A1 Capital, Bulls and Pardus

08.10.2026 The liquidation proceeds of 17 funds were transferred to banks and brokerage firms; TRY 6.4 billion to 43,643 investors (Directorate of Communications, 13 October). Primary source
16.10.2026 On TEFAS, the portfolios of 20 more funds fell to residual amounts. Calculation
18.10.2026 Government statement: liquidation transactions in kind and in cash of about TRY 40.8 billion were completed for more than 45,000 people in 66 funds; the number of funds in liquidation fell from 131 to 65. Press report
19.10.2026 On TEFAS, the portfolios of 8 Bulls funds and 16 Pardus funds fell to residual amounts; of these three founders’ 66 funds on TEFAS, 65 now have residual or zero portfolios. Primary source

For a unitholder who believes no payment has arrived, the first point of contact is the bank or brokerage firm where the units are held.

Ordinary liquidation · payments under way31 funds · 27 “largely” completed (8th FCB, as at 23 Oct) · distribution in 19 (TEFAS) · Ziraat Bankası

Hedef Portföy

15.10.2026 SPK 70/1821: the Hedef funds were removed from the scope of the interim payment decision (64/1775); the liquidation follows the rules set for A1 Capital, Bulls and Pardus (64/1770). Primary source
Funds with “para piyasası” (money market) in their names come first, then from the most investors to the fewest; the cash is distributed pro rata. The TRY 1 million interim payment and the net investment construct do not apply to these funds.
20.10.2026 Company statement: HYV (Hedef Portföy Para Piyasası (TL) Fonu) had been 97.04% liquidated, HDK 97.95%, HAT 90.80% and HGH 85.98%; about TRY 6.03 billion was paid in cash in total. Payments are made on the basis of the current portfolio values arising in the liquidation, not at the prices of 16 September 2026; the remaining funds will be paid in stages. Press report
21.10.2026 TEFAS: HYV’s portfolio fell from TRY 6.20 billion to TRY 0.18 billion; the portfolios of HDK, HAT and HGH are also at residual levels. No distribution is visible in HKJ, HPH or KSA; no date has been announced for the other funds. Primary source
22.10.2026 TEFAS: in the HBV, HDA, HPI, HFI, HKP, HPF, FNT, HVC, DUH and HPZ funds the unit price fell sharply while the number of investors did not change; the portfolios fell to residual amounts. In HMV and HVB the portfolio fell significantly. No company statement on these funds has been found. No distribution is visible in HKJ, HPH or KSA; in HEH all values are 0 in the complete record of 22 October. Primary source
22.10.2026 7th Fund Coordination Board: the liquidation of 18 of the 31 funds had been completed as at 21 October 2026; TRY 8.9 billion was paid to 10,008 accounts; work on the remaining 13 funds is to be completed “swiftly” (a target, not a date). The funds have not been named. Press report
23.10.2026 TEFAS (complete record): in HKM and HMK the unit price fell sharply while the number of investors did not change; HEH reappears at a residual price (TRY 0.000149). In HIM and NFK the price also fell sharply, but their portfolios (≈ TRY 28.6 million and 46.2 million) remain above a residual amount, having fallen substantially; in HMV and HPF all values are 0 (a price of 0 has not been treated as a payment). The list showed 18 Hedef funds as “Paid”. No distribution was visible in HKJ, HPH and KSA; no company statement was found. Primary source
26.10.2026 TEFAS (complete record): HPL’s portfolio fell to a residual amount (≈ −95.7%); the list shows 19 Hedef funds as “Paid”. In KSA (≈ −73.0%), HPH (≈ −72.7%) and HKJ (≈ −55.2%) the unit price fell sharply while the numbers of investors and units in circulation did not change: part of the portfolio appears to have been distributed; no payment has been announced. The cause of the ≈ −18.9% fall in HDH is unclear; HIM, NFK and HVB show no movement. No statement by the company, Ziraat Bankası or the SPK has been found. Primary source To be confirmed
27–28.10.2026 TEFAS: HPH’s unit price fell by a further ≈ 8.5% in the record of 27 October (number of investors unchanged); in HDH the fall continued on 27 and 28 October (≈ −17.7% since 26 October). No significant movement in KSA or HKJ. No new fund is marked “Paid” in the list. No reasons have been given. Primary source
28.10.2026 8th Fund Coordination Board: the liquidation work in 27 of the 31 funds had been “largely” completed as at 23 October 2026; TRY 27.2 billion has been paid to 26,152 accounts in total; work on the remaining 4 funds continues. The list of funds has not been disclosed. Press report

Funds: HKJ, KSA and the other Hedef funds on the list. In a fund that has been paid out, the low unit price shown on TEFAS does not show the amount paid to investors.

Interim payment · began 30 Oct6 funds · İş Bankası

Tera Portföy (THF, TP2, TLY, DOH and others)

30.09.2026 SPK 64/1775: an interim payment to reconciled unitholders, to be set off against the final payment; money market funds first. Primary source
13.10.2026 Government statement: the aim is to complete the interim payments “without delay” once “the bill is enacted”. Primary source
19.10.2026 Economic Coordination Board: the interim payments are expected to begin “as soon as possible” after enactment. This is a target, not a date. Press report
20.10.2026 Bill No. 2/3939 (adopted in committee on 14 October 2026) began its debate in the General Assembly. Primary source
21.10.2026 The General Assembly adopted Articles 1–5; Article 4, which governs the interim payment, was adopted as in Report No. 294. Primary source
22.10.2026 The General Assembly adopted the bill as a whole (Law No. 7596). Primary source
22.10.2026 7th Fund Coordination Board: once the bill is adopted, the interim payment processes for the remaining funds will be taken forward “swiftly”. This is a target, not a date. Press report
26.10.2026 SPK Bulletin 2026/75: the activities of Tera Portföy Yönetimi AŞ were temporarily suspended; Türkiye İş Bankası AŞ was appointed to liquidate the company’s funds outside the decisions of 17 September 2026 (the bulletin names no funds; these funds are outside Law 7596). The bulletin makes no change concerning the 6 Tera funds on the list. Primary source
27.10.2026 Law No. 7596 was published in the Official Gazette (No. 33413) and entered into force. The interim payment may be made in the funds the SPK determines, up to TRY 1,000,000 per investor for each fund (art. 4(2)). Primary source
27.10.2026 SPK 76/1903: interim payments are made to the unitholders of the Tera funds; the liquidation and payment are carried out by Türkiye İş Bankası AŞ; funds named “para piyasası” first (among Tera’s listed funds, those whose names include these words are TP2 and TLV). The decision gives no date and no fund codes (details). Primary source
27.10.2026 SPK Bulletin 2026/77: the activity permits of Tera Yatırım Menkul Değerler AŞ (a brokerage firm) were cancelled and compensation of its investors by the YTM was ordered. The decision does not concern the fund founder Tera Portföy (YTM row). Primary source
27–28.10.2026 Vice President (27 Oct, TBMM): payments will begin “as of Friday through İş Bankası and Ziraat Bankası”. Directorate of Communications (8th Fund Coordination Board, 28 Oct): the first interim payments “are expected to begin” on Friday 30 October 2026. An expectation, not a fixed date. Press report
30.10.2026 The first interim payments began; two of the seven funds reported are Tera’s (TP2, TLV). No amount by fund has been disclosed. Press report
03–04.11.2026 9th Fund Coordination Board: interim payments will continue “this week”. Total reported in the press on 4 November 2026: TRY 62.2 billion in the extraordinary liquidation. The share of the Tera funds, and whether payments have been made in TLY, THF, DOH and T3B, have not been disclosed. Press report

A price of 0 shown on TEFAS for THF, TP2, TLY and DOH does not show the amount that will be paid; see the FAQ.

Interim payment · began 30 Oct28 funds · Ziraat Bankası

Pusula and Atlas Portföy

27.10.2026 SPK 76/1903: interim payments are made to the unitholders of the funds under liquidation founded by Pusula and Atlas Portföy; the liquidation and payment are carried out by T.C. Ziraat Bankası AŞ; funds named “para piyasası” first (on the list, those whose names include these words: PRY, PNU and PKM at Pusula; PPT and PSE at Atlas). The decision gives no date and no fund codes (details). Primary source
27–28.10.2026 Vice President (27 Oct, TBMM) and Directorate of Communications (8th Fund Coordination Board, 28 Oct): the first interim payments are expected to begin on Friday 30 October 2026; an expectation, not a fixed date. Press report
30.10.2026 The first interim payments began; five of the seven funds reported are those of Pusula (PRY, PNU, PKM) and Atlas (PPT, PSE). No amount by fund has been disclosed; no date has been announced for funds other than the money market funds. Press report
04.11.2026 YatırımX, relying on receipts shared by investors, wrote that interim payments were seen in DFI; there is no official statement and the receipts have not been independently verified. Press report
05.11.2026 TEFAS: DFI portfolio ≈ TRY 985 million (≈ TRY 1.31 billion on 30 October 2026); investor and unit counts unchanged. BSH portfolio ≈ −70% and KLH ≈ −12% against 4 November. No reason has been given. Primary source
02.11.2026 TEFAS: unit price of DFI TRY 0.243686, portfolio ≈ TRY 1.21 billion (≈ −13.2% against 28 October 2026). No reason has been given. Primary source
28.10.2026 TEFAS: a unit price was published for Atlas Portföy Serbest Fon (DFI; 47,645 investors) for the first time after 24 September 2026 (TRY 0.280642; portfolio ≈ TRY 1.40 billion). No reason has been given. Primary source
26.10.2026 SPK Bulletin 2026/75: the activities of Pusula Portföy Yönetimi AŞ were temporarily suspended; T.C. Ziraat Bankası AŞ was appointed to liquidate the company’s funds outside the decisions of 17 September 2026 (the bulletin names no funds; these funds are outside Law 7596). The bulletin contains no decision on Atlas. Primary source
Atlas: on 7 October 2026 the Government said that, if the necessary collateral is obtained, payments in its 16 funds would be made under the ordinary liquidation rules; SPK decision 76/1903 lists the Atlas funds among the funds whose liquidation begins under Law No. 7596 and in which the interim payment is made (art. 1, art. 3). Primary source
21.10.2026 The activities of Pusula Yatırım Menkul Değerler AŞ were temporarily suspended (SPK Bulletin 2026/72). It is a brokerage firm, not Pusula Portföy Yönetimi A.Ş., the founder of the funds. Primary source

Pusula’s 12 and Atlas’s 16 funds: in the full list.

Where is the money paid?: The liquidator bank sends the amount to the account at the bank or brokerage firm where the units are held; that institution credits it to the investor’s account (Directorate of Communications, 8 October 2026; the practice in the ordinary liquidations). In the Tera, Pusula and Atlas funds the interim payment is made by “the banks charged with the liquidation” under 76/1903; the account into which it will be paid has not been announced.
Is an application needed?: There is no official statement that a separate application is needed to receive the payment; SPK decision 76/1903 and the press release of 27 October 2026 contain no application procedure. Payments are made to accounts reconciled with the MKK records.
How much is paid?: In an ordinary liquidation, the cash realised from the sale of the assets is distributed pro rata to unitholdings; in the Hedef funds, according to the company, payments are made on the basis of the current portfolio values arising in the liquidation, not at the prices of 16 September 2026. The interim payment is made fund by fund and may not exceed the unindexed net investment amount or TRY 1,000,000; if cash is insufficient, the lowest of the three amounts in 76/1903 applies (details). According to the committee report, TRY 1 million is a ceiling only on the interim payment, not on total payments.
What if the brokerage firm has been suspended?: The SPK temporarily suspended the activities of Alnus, Bulls and Pusula Yatırım Menkul Değerler AŞ from 21 October 2026 (Bulletin 2026/72). The activity permits of Tera Yatırım Menkul Değerler AŞ were cancelled on 27 October 2026 and compensation of its investors by the YTM was ordered (Bulletin 2026/77; YTM row). These are brokerage firms, not the portfolio management companies that founded the funds. As at 5 November 2026 it has not been announced how liquidation payments will reach those who hold accounts with them; information can be requested in writing from the firm itself and from the SPK.
Will a fee be charged?: The claim that investors would be charged a fee for payments was officially denied on 29 September 2026. Messages asking for a fee, a password or card details should be disregarded.

03 · Tools

Calculators: interim payment, pro rata distribution and time limits

Three tools for trying different scenarios with your own figures. The information entered is processed only in this browser; it is not sent anywhere and is not stored. The initial values in the fields are examples. Figures may be typed as 1,234.56 or in the Turkish format 1.234,56. For value by number of units and purchase date, see also the fund value calculator.

Disclaimer. The results of these tools are estimates and hypothetical calculations based on the assumptions entered; they are not an official calculation. The interim payment and the net investment amount are calculated by MKK and the liquidator bank. Tool 1 follows the limits in Article 4 of Law No. 7596 (Official Gazette 27.10.2026, No. 33413; in force) and in Article 6 of SPK decision 76/1903 of 27 October 2026; the order of payment and the sufficiency of cash under the decision are not calculated by the tool. The tools are not legal advice and are not an opinion on any specific case. No responsibility is accepted for any consequences of using the results or of any action taken in reliance on them.

Tool 1 · Tera, Pusula and Atlas funds

Interim payment estimate (Law No. 7596 art. 4(2); SPK 76/1903 art. 6)

Fund

Total amount you invested in the fund (TRY)

Total amount you withdrew from the fund (TRY)

Number of units

Assumed unit value (TRY)

Assumed inflation update of the net investment (%)Under the Law, MKK updates each inflow and outflow from its date by the average of TÜFE and Yİ-ÜFE. A single rate is assumed here; it affects only the final payment scenarios.

Estimated interim payment—

(i) Unindexed net investment: —
(ii) Value of the units (previous day end): —
(iii) Cap: TRY 1,000,000.00

Final payment scenarios: if the fund’s cash covers net investments at this rate
Coverage	Total claim	Remaining after the interim payment

The rule is based on Article 4 of Law No. 7596 (Official Gazette 27.10.2026, No. 33413; in force) and on SPK decision 76/1903; the limits are shown as (i)–(iii) in the order of Article 6 of the decision, and the result is the lowest of the three. Under the decision the interim payment is made in the Tera, Pusula and Atlas funds, fund by fund; in funds whose names include “para piyasası”, limit (ii) is not in the Law and, under the decision, applies only where cash is insufficient, as the amount calculated as at the end of the day before 17.09.2026; the tool does not calculate limit (ii) for those funds. The interim payment is set off against the final payment; no units are redeemed in return for it (art. 10). Since 15 October 2026 the Hedef funds are outside the interim payment scheme. The coverage rate is an unknown assumption.

Tool 2 · Ordinary liquidation (64/1770): Hedef and other funds

Pro rata distribution scenario

Fund

Number of units

Unit value (TRY)

Assumed rate at which the assets are converted into cash: 90%Sales may be made at prices different from the last price; 100% assumes the assets are sold exactly at their last price.

Estimated distribution on this assumption—

Scenarios
Conversion into cash	Estimated amount

In an ordinary liquidation, the cash realised from the sale of the assets is transferred to reconciled accounts pro rata to unitholdings (57/1708 A/5). The fund’s expenses and debts reduce the distributable amount.

Tool 3 · Time limits for administrative applications and actions

Deadline calculator

Start date (publication, notification or application)

Period

Last day of the period—

The period starts on the day after the start date; if the last day falls on an official holiday or a weekend, the next working day counts. Periods that fall within the judicial recess are extended by seven days from the end of the recess. Religious holidays should be checked separately against the official calendar. Which date counts as the start (publication, notification, knowledge) depends on the specific case; details: calendar, administrative route.

05 · Update

Latest position: developments in the liquidation and payments

Decisions and statements published since the first version of 24 September 2026, newest first. The full text and sources of each card are under “Details”. This note has been updated as at 5 November 2026.

05NovPaymentPrimary source

TEFAS 5 November: sharp portfolio falls in BSH and HIM; all values 0 in HPH and HDH

Between the records of 4 and 5 November 2026 the portfolio moved by ≈ −70% in BSH, ≈ −54% in HIM, ≈ −19% in BTJ and ≈ −12% in KLH; investor and unit counts stayed the same. In HPH and HDH the record of 5 November shows price, units and portfolio at 0; this has not been treated as payment. No reasons have been given.

≈ −70%BSH portfolio (4 Nov → 5 Nov)
0HPH and HDH in the 5 Nov record

TEFAS Fund list

Details

Reading note. Because units are not redeemed in interim payments, investor and unit counts do not change, and the TEFAS record does not show a payment. In PRY, PNU, PSE and PPT, for example, the portfolio stayed almost unchanged between 2 and 5 November. A fall in a portfolio cannot be read from the record as either a payment or a price change.

HPH and HDH. In the record of 4 November the HPH portfolio was ≈ TRY 1.00 billion (6,593 investors) and HDH ≈ TRY 2.60 billion. All values showing 0 with the investor count unchanged has been seen before in other Hedef funds; they are not marked “paid” in the list, and later records will be followed.

DFI. Portfolio ≈ TRY 1.31 billion on 30 October, ≈ TRY 985 million on 5 November; unit price TRY 0.197665. Other. KSA ≈ −0.4% and HKJ ≈ +0.1% (against 2 November). TP2, TLV, THF, TLY and DOH continue to show a price of 0.

04NovPaymentPress report

Payments continued: TRY 117.6 billion in total to 446,040 investors

According to Anadolu Agency and DHA on the evening of 4 November 2026, TRY 62.2 billion was paid to 390,219 investors in the extraordinary liquidation and TRY 55.4 billion to 55,821 investors in the ordinary liquidation. In the extraordinary liquidation the principal of 133,839 investors has been covered in full. The reports give no fund names or cut-off date; no official text of the figures was found.

TRY 117.6 bntotal paid (Anadolu Agency and DHA reports)
TRY 62.2 bnextraordinary liquidation; TRY 29.3 bn on 30 Oct

Anadolu Agency report DHA report YatırımX (DFI)

Details

Reading the figures. The extraordinary liquidation amount rose from TRY 29.3 billion on 30 October 2026 to TRY 62.2 billion. The ordinary liquidation amount, however, is lower than the TRY 68 billion given by the 9th Fund Coordination Board (TRY 55.4 billion); no reason has been given. The difference between the two totals should therefore not be read as the amount paid on 4 November 2026.

Which funds? No list has been published. YatırımX, relying on receipts shared by investors, wrote that interim payments dated 4 November 2026 were seen in DFI. The receipts have not been independently verified; amounts in individual accounts cannot be generalised.

Not found (5 November 2026). An SPK bulletin after 2026/78 or a new press release on the liquidation; a fund-by-fund payment list; a notice by the MKK, İş Bankası or Ziraat Bankası.

03NovPaymentPress report

9th Fund Coordination Board: TRY 97.3 billion as at 30 October; interim payments to continue this week

According to the Directorate of Communications, as at 30 October 2026 TRY 97.3 billion had been paid to 247,839 investors in 100 funds: TRY 29.3 billion in the extraordinary liquidation and TRY 68 billion in 93 funds in the ordinary liquidation. About TRY 76 billion in cash and in kind was paid to 178,537 unique investors, whose principal was covered. Interim payments will continue “this week”.

247,839investors (100 funds; as at 30 October 2026)
178,537unique investors with principal covered

Anadolu Agency (Directorate of Communications)Cumhuriyet

Details

Correction. On 2 November 2026 this note, relying on first reports, gave the total investor count as 299,464. The figure in the official statement is 247,839.

Excluded. According to the statement, investors found in the audits of the competent authorities to have made unfair and excessive gains were left outside the interim payment. Payments start with money market funds and move from the lowest unitholder to the highest.

No new figure for the number of funds in liquidation was seen in the statement; this note uses the 8th Board’s figure of 38 funds as the latest official count.

02NovPaymentPrimary source

TEFAS 2 November: investor and unit counts unchanged in the money market funds; PPT portfolio ≈ −38%

Because units are not redeemed in interim payments (76/1903 art. 5), investor and outstanding unit counts do not change. Between the records of 28 October and 2 November 2026 the portfolio moved by ≈ −38.1% in PPT, ≈ −3.4% in PKM, ≈ −1.4% in PSE, ≈ −1.2% in PNU and ≈ −1.0% in PRY; any link with the payments has not been disclosed. TP2 and TLV continue to show a price of 0. No new fund is marked “paid” in the list.

≈ −38.1%PPT portfolio (28 Oct → 2 Nov)
0published price in TP2 and TLV

TEFAS Fund list

Details

Money market funds. PPT: portfolio from ≈ TRY 1.76 billion to ≈ TRY 1.09 billion. PSE: from ≈ TRY 15.97 billion to ≈ TRY 15.75 billion. PNU: from ≈ TRY 17.09 billion to ≈ TRY 16.88 billion. PRY: from ≈ TRY 40.88 billion to ≈ TRY 40.46 billion. PKM: from ≈ TRY 355 million to ≈ TRY 343 million. These falls together are far below the TRY 29.3 billion announced; the TEFAS record does not show how much of the payments left the fund portfolios. Investor and outstanding unit counts are unchanged.

Hedef. In HDH the unit price is ≈ −17.0% against 28 October 2026; the portfolio fell from ≈ TRY 3.74 billion to ≈ TRY 3.10 billion. No significant movement in KSA, HPH and HKJ (≈ +0.1–0.2%). No reasons have been given; no statement by the company or Ziraat Bankası was found.

Atlas Portföy Serbest Fon (DFI). Unit price from TRY 0.280642 to TRY 0.243686; portfolio from ≈ TRY 1.40 billion to ≈ TRY 1.21 billion. The investor count is unchanged (47,645).

30OctPaymentPress report

First interim payments began: TRY 29.3 billion to 235,705 investors in 7 funds

According to Anadolu Agency, interim payments totalling TRY 29.3 billion began to be made to 235,705 investors in 7 funds in the extraordinary liquidation. Together with the 93 funds in ordinary liquidation, TRY 97.3 billion had been paid in 100 funds; the 9th Fund Coordination Board gave the investor count as 247,839 (first reports said 299,464). The split by fund and the timetable for the other funds have not been disclosed. The press reported that at most TRY 250,000 reached individual accounts; no official text explaining this was found.

TRY 29.3 bnfirst interim payment (Anadolu Agency report)
7money market funds; 235,705 investors

Anadolu Agency report BirGün How does it work?

Details

Payment. According to the Anadolu Agency report, payments began in 7 funds of Atlas, Pusula and Tera Portföy, starting with money market funds and moving from the investor with the lowest unitholding to the highest. Sabah (31 October 2026) wrote that the amount was deposited in accounts. Takvim gives the fund codes as TP2, TLV, PRY, PNU, PKM, PPT and PSE; the official text gives none.

Reading the figures. Anadolu Agency’s 63,759 investors (93 funds) differ from the Fund Coordination Board’s 71,899 accounts; one counts investors, the other accounts. The count of 38 funds dates from 28 October 2026; an interim payment does not end a liquidation, so the 7 funds remain in liquidation.

Amounts. BirGün, relying on individual account movements, wrote that payments of “at most TRY 250,000” were seen. No text by the SPK, the MKK or the appointed banks explaining this amount was found. Whether art. 8 of 76/1903 has been applied has not been disclosed.

Not found (2 November 2026). A statement on a 9th Fund Coordination Board meeting; a date for a second interim payment or for funds other than the money market funds; a notice by the MKK, İş Bankası or Ziraat Bankası. No new statement by the Minister of Justice on voluntary returns after 25 October 2026 was found.

30OctSPKPrimary source

SPK Bulletin 2026/78: no decision on the liquidation; equity ratio relaxation extended to 13 November 2026

The bulletin contains no decision on the liquidation of the funds, the interim payment or voluntary returns. By decision 76/1918 the relaxation of the equity ratio for margin transactions was extended to the end of the session on 13 November 2026; this is not a time limit for applications by fund investors.

13.11.2026new end of the relaxation; not an investor time limit

SPK Bulletin 2026/78

Details

As at 2 November 2026 the latest item on the SPK press page is dated 28 October 2026; it concerns allegations about foreign financial institutions, not the fund liquidation.

Earlier developments28.09–26.10 · 35 cards · TEFAS 26.10 (Hedef), Minister of Justice (voluntary refunds), TEFAS 23.10, adoption of the Law, 7th Fund Coordination Board, SPK’s PBLK press release, distribution visible in 10 Hedef funds, General Assembly vote on Articles 1–5, suspension of three brokerage firms, first Hedef payments, General Assembly debate, committee report, liquidation completed in 66 funds, adoption in committee, SPK statements, interim payment decision, return accounts, measures concerning institutions, corrections

28OctPaymentPress report

8th Fund Coordination Board: first interim payments expected to begin on 30 October 2026

According to the Directorate of Communications, in the funds in the extraordinary liquidation “the first interim payments are expected to begin on Friday 30 October 2026”. On 27 October 2026 the Vice President told the TBMM that payments would begin on Friday through İş Bankası and Ziraat Bankası and that the process is expected to be completed by mid-November. These are expectations and targets; the SPK decision gives no date. The number of funds in liquidation has fallen from 131 to 38.

38funds in liquidation (from 131; 8th FCB, 28 Oct 2026)
TRY 68 bnpaid in kind and in cash to 71,899 accounts (since the start)

CNN Türk (@iletisim)Karar (ANKA)How will the interim payment work?

Details

8th Fund Coordination Board (28 October 2026). According to the Directorate of Communications’ written statement (@iletisim post; text taken from the post embedded on CNN Türk and from the AA report; it does not appear in the iletisim.gov.tr news list): “For the funds in the extraordinary liquidation, whose processes have been clarified by Law No. 7596 adopted by the TBMM and the related SPK decision on procedures and principles, the first interim payments are expected to begin on Friday 30 October 2026.” The liquidation work in 27 of Hedef Portföy’s 31 funds “has been largely completed” as at 23 October 2026; TRY 27.2 billion has been paid to 26,152 accounts in total; work on the remaining 4 funds continues. Since the start the number of funds in liquidation has fallen from 131 to 38, and liquidation payments in kind and in cash totalling TRY 68 billion have been made to 71,899 accounts. According to the statement, “returns to the accounts opened with the TMSF are continuing”; technical preparations for a draft bill with structural measures will be accelerated, and the draft will be submitted to the TBMM after consultation with the sector (no date).

Vice President (27 October 2026, TBMM Planning and Budget Committee). According to the ANKA report (Karar; see also Diken), Cevdet Yılmaz said: “Payments of up to TRY 1 million in the extraordinary liquidation will begin as of Friday through İş Bankası and Ziraat Bankası. We will go from the lowest to the highest.” Referring to the funds’ cash and assets that can quickly be turned into cash, he said “we expect them to complete this process by mid-November”. He also said TRY 68 billion had been paid to 71,899 accounts in 93 funds as at 23 October 2026.

Reading note. 30 October 2026 is an official expectation; SPK decision 76/1903 gives no date, and no dated announcement by the SPK, Ziraat Bankası, İş Bankası or MKK has been found. There is no official statement that all unitholders will be paid on the same day; under the decision the order of payment depends on the type of fund and on the funds’ cash position (details). “Mid-November” is a target. The count “18 of 31 in Hedef” given as at 21 October 2026 has been superseded by this statement.

28OctSPKPrimary source

Tera Yatırım Menkul Değerler AŞ: activity permits cancelled; the YTM runs the compensation process

By SPK Bulletin 2026/77 (27 October 2026) all activity permits and the authorisation certificate of the brokerage firm were cancelled, and compensation of its investors and its gradual liquidation were ordered. On 28 October 2026 the YTM announced that the application form and rules will be published separately on ytm.gov.tr. The decision concerns a brokerage firm, not the fund founder Tera Portföy.

2026/77SPK Bulletin, 27 Oct 2026
3 monthspayment period from the announcement of the schedule (+3 with Board approval)

SPK Bulletin 2026/77 ytm.gov.tr YTM row

Details

By SPK Bulletin 2026/77 (27 October 2026) it was decided “to cancel all activity permits and the authorisation certificate” of Tera Yatırım Menkul Değerler AŞ (a brokerage firm), “to compensate its investors and to liquidate the Brokerage Firm gradually” (PDF). According to the YTM’s notice of 28 October 2026, from 27 October 2026 the duties and powers of the firm’s statutory bodies are performed by the YTM until the liquidation is concluded; the application form and the rules for compensation claims will be published separately on ytm.gov.tr; objections to the schedule of creditors prepared by the YTM may be made within thirty days of its announcement; compensation payments will be made within three months of the announcement of the schedule, a period that may be extended by up to three months with the Board’s approval in compelling cases (ytm.gov.tr). The YTM’s compensation covers claims arising from the failure to meet obligations to pay cash or deliver capital market instruments held or managed by the investment firm on the investor’s behalf. The decision concerns a brokerage firm; it does not concern the fund founder Tera Portföy Yönetimi AŞ. No statement has been made on fund units held at this firm or on liquidation payments to be made to such accounts.

Bulletin 2026/77 also lists Tera Portföy Yönetimi AŞ and Tera Yatırım Menkul Değerler AŞ among the entities subject to trading bans in two shares, limited to transactions in their own name and for their own account; that part does not concern the liquidation of the funds. No compensation decision has been published for Alnus, Bulls and Pusula Yatırım Menkul Değerler AŞ (brokerage firms whose activities have been temporarily suspended since 21 October 2026).

28OctPaymentPrimary source

TEFAS 27–28 Oct: falls in HPH and HDH; a price published again for DFI

In the TEFAS record of 27 October 2026 HPH’s unit price fell by a further ≈ 8.5%; in HDH the fall continued on 27 and 28 October. No significant movement in KSA or HKJ since 26 October. In the record of 28 October 2026 a unit price was published for Atlas Portföy Serbest Fon (DFI) for the first time after 24 September 2026. No new fund is marked “Paid” in the list.

≈ −8.5%HPH unit price, record of 27 Oct 2026
0.280642DFI unit price, record of 28 Oct 2026

Payments HKJ KSA Fund list

Details

Hedef Portföy. In HPH (a participation money market fund) the unit price fell from 0.675299 to 0.617690 (≈ −8.5%) in the TEFAS record of 27 October 2026; 0.617898 in the record of 28 October 2026; the number of investors (6,593) did not change. HDH’s unit price fell by ≈ 9.4% in the record of 27 October 2026 and by ≈ 9.1% in the record of 28 October 2026 (≈ −17.7% since 26 October 2026). KSA (28.10.2026: 1.166245) and HKJ (0.658439) show no significant movement after 26 October 2026. No statement on these movements by the company, the liquidator bank or the SPK has been found; the causes are unclear. These funds are not marked “Paid” in the list.

Atlas Portföy Serbest Fon (DFI). In this fund with 47,645 investors the price had been shown as 0 on TEFAS after 24 September 2026 (TRY 0.405808). In the record of 28 October 2026 a unit price was published again: TRY 0.280642; portfolio ≈ TRY 1.40 billion. No reason has been given. The TEFAS price does not show the amount to be paid to investors.

Data note. The calculation data (fund list and fund value calculator) have been updated to the TEFAS record of 28 October 2026. 28 October 2026 was a half working day; 29 October 2026 is the Republic Day holiday.

27OctSPKPrimary source

SPK 76/1903: procedures for the interim payment set (Tera, Pusula, Atlas)

The SPK set the procedures and principles for the liquidation and payments under Law No. 7596 (Bulletin 2026/76). Interim payments will be made to the unitholders of the funds under liquidation founded by Tera, Pusula and Atlas Portföy; funds whose names include “para piyasası” (money market) come first. Payment is made by Ziraat Bankası (Pusula, Atlas) and İş Bankası (Tera). The decision gives no date, no application procedure and no fund codes.

76/1903SPK decision, 27 Oct 2026 · 11 articles
TRY 1 mninterim payment cap, fund by fund (art. 6)

SPK Bulletin 2026/76 SPK press release How will the interim payment work?

Details

SPK Bulletin 2026/76 (27 October 2026). Under Board decision 76/1903 of 27 October 2026 the SPK published the “Procedures and Principles for the Liquidation and Payments to be Made under Law No. 7596 on Certain Investment Funds Whose Liquidation Has Been Ordered” (PDF). A summary of its 11 articles, and of what it does not cover: How will the interim payment work?

SPK press release. On the same day the SPK announced the decision with a question-and-answer text, “10 Questions on the Procedures and Principles for Liquidation and Payments” (spk.gov.tr, PDF). The text repeats the decision; it contains no payment date, application procedure or information on the account into which payment will be made. Answer 4 uses “and/or” where the decision says “and”; this note follows the wording of the decision.

Voluntary returns. The decision does not set the calculation period, the method or the “accounts announced by the Board” under Article 4(4) of Law No. 7596; it only regulates the order in which “amounts transferred to the general share return account” are distributed to the funds (art. 11). Details: Voluntary refunds.

27OctLawPrimary source

Law No. 7596 published in the Official Gazette and in force

Law No. 7596 on Certain Investment Funds Whose Liquidation Has Been Ordered was published in Official Gazette No. 33413 of 27 October 2026 and entered into force the same day, with effect from 17 September 2026 (art. 8). The text is identical to the text adopted by the TBMM. The SPK set the implementing procedures and principles the same day by decision 76/1903.

33413Official Gazette, 27 Oct 2026
17 Sepeffective from (art. 8)

resmigazete.gov.tr Law 7596 Payment rule

Details

Publication. Law No. 7596 on Certain Investment Funds Whose Liquidation Has Been Ordered (Tasfiyesine Karar Verilen Bazı Yatırım Fonları Hakkında Kanun) was published in the legislation section of Official Gazette No. 33413 of 27 October 2026 (resmigazete.gov.tr). The date of adoption is 22 October 2026; the date beneath the text is 26 October 2026. The Law did not appear in Official Gazette No. 33412 of 26 October 2026 (26 Oct).

Entry into force and scope. Art. 8: “This Law shall enter into force on the date of its publication, with effect from 17/9/2026.” The Law entered into force on 27 October 2026. Under art. 1 it covers those funds whose liquidation was ordered by the SPK’s decisions of 17 September 2026 and whose liquidation had not been completed on the date of publication; for other funds it “does not create a general or permanent liquidation and liability regime” (art. 1(2)).

Text. The Official Gazette text is identical to the text published by the TBMM as adopted by the General Assembly (tbmm.gov.tr); there is no difference, including in the PBLK sentence added to paragraph 5 of Article 3 in the General Assembly and in the net investment amount, the TRY 1,000,000 interim payment cap and the voluntary return provisions of Article 4.

What is left to the SPK. The interim payment may be made “in the funds determined by the Board” and is capped at TRY 1,000,000 per investor for each fund (art. 4(2)). For voluntary returns, the Board sets the calculation period, the method and the other procedures and principles (art. 4(4)). The procedures and principles for implementing the Law are set by the Board, after obtaining the TMSF’s opinion on matters within the TMSF’s remit (art. 7(2)). On the morning of 27 October 2026 the SPK’s bulletins and announcements contained no decision on these matters; the same day the SPK set the procedures and principles for the liquidation and payments by decision 76/1903 (details). The Law sets no date or time limit for payment.

26OctSPKPrimary source

SPK temporarily suspends the activities of Tera Portföy and Pusula Portföy

SPK Bulletin 2026/75: the capital market activities of the two portfolio management companies were temporarily suspended under SPKn art. 97(1). İş Bankası (Tera) and Ziraat Bankası (Pusula) were appointed to liquidate the companies’ investment funds, real estate investment funds and venture capital investment funds other than those covered by the decisions of 17 September 2026. The bulletin names no funds; these funds are outside the scope of Law No. 7596.

Art. 97(1)SPKn · temporary suspension of activities
2026/75SPK Bulletin, 26 Oct 2026

SPK Bulletin 2026/75 Off-list fund (Scenario 8)TMV

Details

SPK Bulletin 2026/75 (26 October 2026). Under the heading “Temporary suspension of activities” (Faaliyetleri Geçici Durdurma), the SPK decided to suspend temporarily the capital market activities of Tera Portföy Yönetimi AŞ and Pusula Portföy Yönetimi AŞ under art. 97(1) of Capital Markets Law No. 6362 (PDF). According to the bulletin, Türkiye İş Bankası AŞ was appointed to liquidate the investment funds, real estate investment funds and venture capital investment funds founded by Tera Portföy “other than those whose liquidation was ordered by the decisions of the Board’s Decision-Making Body of 17/09/2026” (unofficial translation). T.C. Ziraat Bankası AŞ was appointed for the funds of the same kind founded by Pusula Portföy.

Scope. The bulletin does not list the funds covered by the decision and gives no fund names or codes. The decision concerns not the 131 funds whose liquidation was ordered on 17 September 2026 but the two companies’ other funds. Law No. 7596 applies only to the funds whose liquidation was ordered by the decisions of 17 September 2026 (art. 1(1)) and, for other funds, “does not create a general or permanent liquidation and liability regime” (art. 1(2)). The liquidation procedure and payment timetable for these funds have not been announced. For the Tera funds on the 131-fund list the liquidator remains Türkiye İş Bankası AŞ, and for the Pusula funds T.C. Ziraat Bankası AŞ.

Bulletin 2026/74. Bulletin 2026/74, published the same day, concerns an amendment to the Fund Guidelines and the professional client and qualified investor thresholds; it contains no decision on the funds in liquidation (PDF).

26OctPaymentPrimary source

Hedef Portföy: HPL falls to a residual in the TEFAS record of 26 October; partial falls in KSA, HPH and HKJ

In the complete TEFAS record of 26 October 2026 HPL’s portfolio fell to a residual amount; the list now shows 19 Hedef funds as “Paid”. The Government’s last count, as at 21 October 2026, was 18 of 31. In KSA, HPH and HKJ the unit price fell by 55–73% while the number of investors did not change: part of the portfolio appears to have been distributed; no payment has been announced.

19 / 31Hedef funds shown as “Paid” (TEFAS, record of 26 Oct)
3KSA, HPH, HKJ: part of the portfolio appears to have been distributed

When paid?HKJ KSA Fund list

Details

Hedef Portföy, TEFAS 26 October 2026. The TEFAS record of 26 October 2026 is complete (34 of 2,017 funds at a price of 0, the same number as on 23 October 2026). In that record the unit price of HPL fell from 0.216490 to 0.009398 (≈ −95.7%) and its portfolio from about TRY 63.2 million to TRY 2.74 million; the numbers of investors and units in circulation did not change. HPL is marked “Paid” in the list with that record date, so the list now shows 19 of Hedef’s 31 funds as “Paid”. No statement by the company or the SPK on this fund has been found.

Partial falls. In KSA the unit price fell from 4.315480 to 1.165359 (≈ −73.0%; portfolio from about TRY 12.76 billion to TRY 3.45 billion), in the money market participation fund HPH from 2.474911 to 0.675299 (≈ −72.7%; from about TRY 4.09 billion to TRY 1.11 billion) and in the money market hedge fund HKJ from 1.467764 to 0.658279 (≈ −55.2%; from about TRY 7.29 billion to TRY 3.27 billion); in all three the numbers of investors and units in circulation did not change. Part of the portfolio appears to have been distributed; but no payment statement by the company, the liquidator bank or the SPK has been found. As assets above a residual amount remain, these three funds are not marked “Paid” in the list. The fall in the portfolio does not show the amount paid.

Other funds. In HDH the unit price fell by ≈ 18.9%; whether this is a valuation movement or a distribution is not clear. HIM, NFK and HVB show no movement. In HMV all values are 0; a price of 0 has not been treated as a payment (HPF is marked “Paid” because of its fall in the record of 22 October 2026). No distribution is visible in the liquidation funds of Tera, Pusula and Atlas. The TEFAS record of 27 October 2026 was incomplete in the morning (630 funds at a price of 0) and was not used.

Reading the figures. According to the 7th Fund Coordination Board, the liquidation of 18 of Hedef’s 31 funds had been completed as at 21 October 2026; the Government did not name those funds and has not given a new count since. The 19 in the list rests only on what TEFAS shows and relates to the record of 26 October 2026; the two counts relate to different dates and different bases. A TEFAS price does not show the amount paid to investors, and the record date is not the payment date.

25OctVoluntary refundPress report

Minister of Justice: a voluntary refund does not on its own remove legal liability

In a statement on his social media account, the Minister of Justice, Akın Gürlek, said that “making a voluntary refund does not, on its own, remove the legal liability of any natural or legal person”, and that the source, timing and amount of refunds and the way they reach the true rightholders will be examined. Law No. 7596 had not been published in the Official Gazette at that date; it was published on 27 October 2026.

Art. 4(4)Law 7596: voluntary return · in force since 27 Oct 2026
1 OctSPK announcement of the voluntary return accounts

hurriyet.com.tr (DHA)ankahaber.net Voluntary refunds

Details

Minister of Justice, 25 October 2026. In a statement on his social media account concerning the fund investigations, the Minister of Justice, Akın Gürlek, said: “Making a voluntary refund [gönüllü iade] does not, on its own, remove the legal liability [hukuki sorumluluk] of any natural or legal person. These refunds, which contribute to redressing the losses suffered, do not stand in the way of the conduct of the investigations or the assessment of the evidence. Our priority is that the refunded amounts reach the true rightholders [gerçek hak sahipleri]. In this context, the source, timing and amount of the refunds and the way in which they are passed on to the true rightholders will be examined meticulously; the allegations concerning the persons and transactions involved will also be assessed separately in law in the light of the evidence obtained.” (unofficial translation). The statement was reported in the same wording by Hürriyet (DHA, 18.50) and Anka (19.13) (hurriyet.com.tr, ankahaber.net); the original post could not be opened, and no text was found on the Ministry of Justice website.

Wording. The statement uses the words “on its own” (tek başına) and “legal liability” (hukuki sorumluluk). It contains no payment timetable, no amounts and no reference to Law No. 7596, and it does not say whether “voluntary refund” refers to the SPK’s voluntary return accounts or to other refunds. The public bodies’ statement in the Planning and Budget Committee report and the Minister’s remarks of 6 October 2026, as reported in the press, point in the same direction (see Voluntary refunds).

Official Gazette (as at 25 October 2026). The Law did not appear in the issues of 24 October 2026 (No. 33410) or 25 October 2026 (No. 33411) either; there was no duplicate issue (24 Oct, 25 Oct). The Law was published on 27 October 2026 (see the 27 October card). At that date no new statement on voluntary refunds by the SPK, the Treasury, the TMSF or the Directorate of Communications has been found.

23OctPaymentPrimary source

Hedef Portföy: distribution visible in three more funds in the TEFAS record of 23 October

In the complete TEFAS record of 23 October 2026 the unit price of HKM and HMK fell sharply while the number of investors did not change; HEH reappears at a residual price. The list now shows 18 Hedef funds as “Paid”; the count matches the Government’s 18 of 31, but it has not been confirmed that the funds are the same. No distribution is visible in HKJ, HPH and KSA.

18 / 31Hedef funds shown as “Paid” (TEFAS, record of 23 Oct)
3HKJ, HPH, KSA: no distribution

When paid?Fund list

Details

Hedef Portföy, TEFAS 23 October 2026. The TEFAS record of 23 October 2026 was incomplete on the morning of 23 October; in the completed record, 34 of 2,017 funds are shown at a price of 0. In that record the unit price of HKM fell from 2.623305 to 0.078001 (≈ −97.0%) and that of HMK from 200.511599 to 2.229649 (≈ −98.9%); the number of investors and of units in circulation did not change, and the portfolios fell to TRY 841,882 and TRY 543,845. HEH, all of whose values were 0 in the complete record of 22 October 2026, reappears in the record of 23 October 2026 at a residual price of TRY 0.000149 (21 October 2026: TRY 3.348108; portfolio TRY 16,383), which is consistent with a residual after a distribution. These three funds are marked “Paid” in the list on the basis of what TEFAS shows; no statement by the company or the SPK on these payments has been found, and the amount and rate paid are not known.

The unit price also fell sharply in HIM (≈ −89.5%) and NFK (≈ −95.4%); but as their portfolios, at about TRY 28.6 million and TRY 46.2 million, remain above a residual amount, these two funds are not marked “Paid”; their portfolios have fallen substantially. In HPL the unit price fell by ≈ 22.4%; whether this is a distribution or a valuation movement is not clear. In HMV and HPF all values are 0 in the record of 23 October 2026; a price of 0 has not been treated as a payment (HPF was already marked “Paid” because of its sharp fall in the record of 22 October 2026). No distribution is visible in HKJ, HPH and KSA. The list thus shows 18 of Hedef’s 31 funds as “Paid”. According to the 7th Fund Coordination Board, the liquidation of 18 of the 31 funds had been completed as at 21 October 2026; as the Government has not said which funds those are, the fact that the counts match does not show that the two groups consist of the same funds. A TEFAS price does not show the amount paid to investors, and the record date is not the payment date.

22OctLawPrimary source

Bill adopted: Law No. 7596

The TBMM General Assembly adopted Articles 6–9 unchanged and the bill as a whole by electronic vote. The Law was sent to the Presidency the same day and was published in the Official Gazette of 27 October 2026 (see the 27 October card).

7596Law number · adopted 22 Oct 2026
27 OctOfficial Gazette No. 33413 · entry into force

Record of the Law Text of the Law (TBMM)Law 7596

Details

TBMM General Assembly, 22 October 2026 (10th sitting). Articles 6, 7, 8 and 9 in the second part were put to the vote one by one and adopted; every amendment tabled to them was rejected, including one that would have changed the wording of the commencement article (art. 8). The bill as a whole was adopted by electronic vote: “The bill has been adopted and has become law.” The sitting closed at 20.03 (unrevised record). The vote counts are not given in the unrevised record.

Record of the Law. According to the TBMM’s record of the Law, it is Law No. 7596, the Law on Certain Investment Funds Whose Liquidation Has Been Ordered (Tasfiyesine Karar Verilen Bazı Yatırım Fonları Hakkında Kanun), adopted on 22 October 2026 and sent to the Presidency on 22 October 2026. At that date the Official Gazette date and number fields in the record were blank. Compared with Report No. 294, the text of the Law published by the TBMM differs only in paragraph 5 of Article 3: the semicolon after “Fon pay sahipliği” at the start of the paragraph became a comma, and the PBLK sentence adopted on 21 October 2026 was added at the end of the paragraph. The other articles (arts. 1, 2, 4 and 5–9) and the other paragraphs of Article 3 are the same as in Report No. 294; the net investment amount, the TRY 1,000,000 interim payment cap and the voluntary return provisions in Article 4 are unchanged.

Publication and entry into force. The Law did not appear in the Official Gazette of 23 October 2026 (No. 33409), 24 October 2026 (No. 33410), 25 October 2026 (No. 33411) or 26 October 2026 (No. 33412) (23 Oct, 24 Oct, 25 Oct, 26 Oct). It was published in Official Gazette No. 33413 of 27 October 2026 (resmigazete.gov.tr) and, under art. 8, entered into force the same day, with effect from 17 September 2026. The date beneath the text is 26 October 2026. The calendar calculation of the 15-day period under art. 89 of the Constitution given in earlier versions of this note became moot on publication. The interim payment may be made in the funds and in the manner the SPK determines (art. 4(2), 7(2)); as at the morning of 5 November 2026 there was no SPK implementing decision.

22OctPaymentPress report

7th Fund Coordination Board: 47 funds still in liquidation

Since the start of the process, liquidation payments in kind and in cash totalling TRY 49.7 billion have been made to 55,755 accounts. The liquidation of 18 of Hedef Portföy’s 31 funds had been completed as at 21 October 2026; work on the remaining 13 funds is to be completed “swiftly”. No date was given.

47funds in liquidation (from 131)
18 / 31Hedef funds completed (Government)

aa.com.tr Payments Fund list

Details

7th meeting of the Fund Coordination Board. According to the Directorate of Communications statement as reported by Anadolu Agency (aa.com.tr), since the start of the process the number of funds in liquidation has fallen from 131 to 47, and liquidation payments in kind and in cash totalling TRY 49.7 billion have been made to 55,755 accounts. The liquidation of 18 of Hedef Portföy’s 31 funds had been completed as at 21 October 2026, with TRY 8.9 billion paid to 10,008 accounts; work on the liquidation of the remaining 13 funds is to be completed “swiftly”. The statement stressed that, once the bill is adopted, the processes for the interim payments in the remaining funds will be taken forward “swiftly”. These are targets; no date was given. A Deputy Minister of Treasury and Finance was assigned to monitor the liquidation daily at technical level and to coordinate the institutions involved. The original text of the statement could not be found on the Directorate of Communications website.

Reading the figures. The unit in the statement is the “account”, not the person. The total of TRY 49.7 billion corresponds to the roughly TRY 40.8 billion announced on 18 October 2026 for the 66 funds of A1 Capital, Bulls and Pardus plus the TRY 8.9 billion announced for Hedef. The 47 funds still in liquidation are consistent with the 34 Tera, Pusula and Atlas funds covered by the interim payment plus Hedef’s remaining 13 funds; no official list of funds has been published, however. The Government has not said which 18 Hedef funds have been completed; on the basis of TEFAS, the fund list in this note shows 15 Hedef funds as “Paid” on the record of 22 October 2026, 18 on the record of 23 October 2026 and 19 on the record of 26 October 2026. It has not been confirmed that the funds in the list are the ones the Government meant (see the note below the list).

22OctSPKPrimary source

SPK: blocked units on equal terms with other unitholders

The SPK stated that settlement finality (SPKn art. 79) does not cover every TEFAS instruction. Persons with a share-block entry are among the 455,758 unitholders and are not a separate group; in the liquidation they will be assessed “on equal terms with the other unitholders”. This is the authority’s view, not a court ruling.

455,758unitholders; PBLK holders are within this figure
Art. 79settlement finality: in the SPK’s view, does not cover every TEFAS instruction

spk.gov.tr Scenario 2 Open questions

Details

SPK press release, 22 October 2026. The SPK said that the bill being debated in the General Assembly had given rise to uncertainty about settlement finality and share blocks (spk.gov.tr). According to the release, the settlement-finality provision in SPKn art. 79(1) does not mean that it must apply to all instructions given through TEFAS “regardless of the stage the transaction has reached”; not every sale instruction given on TEFAS is in itself a completed settlement. Settlement is completed when, after the instruction, the cash is credited to the investor’s account and the record of unitholding is removed.

According to the SPK, persons with a share-block entry are also among the 455,758 fund unitholders and “do not form an additional group”. The provision does not affect completed transactions and covers only instructions whose settlement has not been completed; those instructions will be assessed on the amounts obtained in the liquidation “on equal terms with the other unitholders”. The SPK described the provision as a “necessary and proportionate” approach. That is the view the SPK has stated; it is not a court ruling. In the General Assembly, opposition members had argued that the provision conflicts with the principle of settlement finality. The number of investors and the amounts affected have not been disclosed.

22OctPaymentPrimary source

Hedef Portföy: distribution visible in 10 more funds on TEFAS

In the TEFAS record of 22 October 2026 the portfolios of the HBV, HDA, HPI, HFI, HKP, HPF, FNT, HVC, DUH and HPZ funds fell to residual amounts. No company statement on these funds has been found. No distribution is visible in HKJ, HPH and KSA.

15 / 31Hedef funds with a visible distribution (TEFAS, record of 22 Oct); 18 / 31 on the record of 23 Oct
3HKJ, HPH, KSA: no distribution

When will they be paid?Fund list

Details

Hedef Portföy, TEFAS 22 October 2026. In the TEFAS record of 22 October 2026 the unit price of the HBV, HDA, HPI, HFI, HKP, HPF, FNT, HVC, DUH and HPZ funds fell sharply, while the numbers of investors and of units in circulation did not change, and the portfolios fell to residual amounts. This is the same pattern as the distribution seen in HYV, HDK, HAT and HGH on 20–21 October 2026. In HMV and HVB the portfolio also fell significantly, but assets above a residual amount are still shown, so these two funds are not marked “Paid” in the list. No company statement on these payments has been found; the amount and percentage paid are not known. The TEFAS price does not show the amount paid to investors; as a TEFAS record is based on the valuation of the previous business day, the record date is not the payment date.

No distribution is visible in the money market funds HKJ and HPH or in KSA in the TEFAS record of 22 October 2026; this does not fully match the order the company announced (money market funds first), and no reason has been given. The TEFAS record of 22 October 2026 was incomplete on the morning of 22 October; the complete record, retrieved again on 23 October 2026, confirmed the table above. In HEH the price, portfolio and units in circulation are 0 in the complete record as well; as no payment has been confirmed, this fund is not shown as “Paid”. According to the 7th Fund Coordination Board, the liquidation of 18 of Hedef’s 31 funds had been completed as at 21 October 2026 (see the 22 October card on the 7th Fund Coordination Board).

21OctTBMMPrimary source

General Assembly adopts Articles 1–5; PBLK sentence added

The first part of the bill was voted on. A sentence was added to Article 3 stating that those whose units have been blocked are subject to the liquidation provisions “in their capacity as fund unitholders”; an amendment giving them priority payment was rejected. Articles 6–9 and the bill as a whole were adopted the next day, 22 October 2026 (see the 22 October card).

5 / 9articles adopted (21 Oct)
22 Octbill adopted as a whole (Law 7596)

Record (unrevised)Law 7596 A/6

Details

TBMM General Assembly, 21 October 2026 (9th sitting). Articles 1, 2, 3, 4 and 5 in the first part of the bill were put to the vote one by one and adopted (unrevised record; the final record has not yet been published). Articles 1, 2, 4 and 5 were adopted as in Report No. 294; an amendment that would have deleted the words “without indexation” from Article 4 was also rejected.

Article 3 changed. On 21 October 2026 the General Assembly added the following sentence to paragraph 5 of Article 3 of the bill by amendment and adopted the article in that form: “Provided that, in respect of instructions concerning the funds subject to liquidation that were transmitted to TEFAS on or before 17/9/2026 but could not be executed because of the default of the fund concerned and/or the non-publication of its unit price, those whose units have been blocked shall be subject to the liquidation provisions of this Law in their capacity as fund unitholders.” (unofficial translation) The sentence appears in the same wording in the text of Law No. 7596 published in the Official Gazette (27 October 2026, No. 33413). According to the reasons given for the amendment, these instructions became “invalid” because they could not be executed, and the provision “does not affect transactions whose payment has been completed”. An amendment stating that these investors’ claims are protected by settlement finality (SPKn art. 79) and that they are to be paid “with priority and immediately in cash” from the first cash available in the liquidation account was rejected; the adopted text provides no separate creditor ranking or priority for these investors. In the General Assembly, opposition members argued that the sentence conflicts with the principle of settlement finality. In a press release of 22 October 2026 the SPK stated that the settlement-finality provision in SPKn art. 79 does not mean that it must apply to all instructions given through TEFAS “regardless of the stage the transaction has reached”, and that settlement is completed when the cash is credited to the investor’s account and the record of unitholding is removed. According to the SPK, persons with a share-block entry are among the 455,758 fund unitholders and “do not form an additional group”; their instructions will be assessed on the amounts obtained in the liquidation “on equal terms with the other unitholders” (spk.gov.tr). That is the view the SPK has stated; it is not a court ruling. Law No. 7596, adopted by the General Assembly on 22 October 2026, was published in Official Gazette No. 33413 of 27 October 2026 and entered into force the same day, with effect from 17 September 2026 (art. 8); the Official Gazette text is identical to the text adopted by the TBMM.

The debate on the second part (Articles 6–9, including the commencement article) has not begun. The sitting closed at 00.02 on 22 October 2026; the General Assembly is to meet at 14.00 on 22 October 2026. This is an Assembly work plan, not a date of adoption of the bill. On the morning of 22 October 2026 the bill had not yet been enacted or published in the Official Gazette (the Official Gazette of 22 October 2026, No. 33408, was checked). On 22 October 2026 the General Assembly adopted Articles 6–9 and the bill as a whole, and the bill became Law No. 7596 (see the 22 October card).

21OctSPKPrimary source

Activities of three brokerage firms suspended

The SPK temporarily suspended the activities of Alnus, Bulls and Pusula Yatırım Menkul Değerler AŞ from 00.01 on 21 October 2026. These are brokerage firms, not Bulls Portföy and Pusula Portföy, the founders of the funds.

3brokerage firms
2026/72SPK Bulletin, 20 Oct 2026

SPK Bulletin 2026/72 Payments

Details

SPK Bulletin 2026/72 (20 October 2026). The capital market activities of Alnus Yatırım Menkul Değerler AŞ, Bulls Yatırım Menkul Değerler AŞ and Pusula Yatırım Menkul Değerler AŞ were temporarily suspended from 00.01 on 21 October 2026 under art. 97(1) SPKn and the capital adequacy rules for brokerage firms (PDF). These are brokerage firms providing investment services; they should not be confused with Bulls Portföy Yönetimi A.Ş. and Pusula Portföy Yönetimi A.Ş., the founders of funds in liquidation. Liquidation proceeds are sent to the bank or brokerage firm where the units are held; it has not been announced how payments will reach those who hold accounts with the suspended firms. The bulletin contains no decision on the start of the interim payment, on the application of A/6 or on TMV.

20OctPaymentPress report Primary source

Hedef Portföy: payments made in four funds

According to the company, about TRY 6.03 billion was paid in cash in the HYV, HDK, HAT and HGH funds. Payments are made on the basis of the current portfolio values arising in the liquidation, not at the prices of 16 September 2026. No date has been announced for the other Hedef funds.

4 fundsHYV, HDK, HAT, HGH
≈ TRY 6.03 bnpaid in cash (company statement)

When will the funds be paid?Fund list

Details

Payments at Hedef Portföy. According to a company statement reported in the press, HYV (Hedef Portföy Para Piyasası (TL) Fonu) had been 97.04% liquidated, HDK 97.95%, HAT 90.80% and HGH 85.98%, and cash payments totalling TRY 6,034,354,535.10 had been made. According to the statement, payments are made on the basis of the current portfolio values arising from the liquidation, not at the prices of 16 September 2026, and the remaining funds will be paid in stages. According to the company’s statement of 19 October 2026, the liquidation of its 31 funds is conducted by T.C. Ziraat Bankası A.Ş.; the order is money market funds first, then from the fund with the most investors to the fund with the fewest, and distribution is made pro rata to unitholdings to reconciled individual custody accounts. The company’s statements could not be found on its own website or on KAP.

The TEFAS record of 21 October 2026 supports this: HYV’s portfolio fell from TRY 6.20 billion to TRY 0.18 billion and its unit price from 6.697765 to 0.198244, while the number of investors (6,244) did not change. The portfolios of HDK, HAT and HGH also fell to residual amounts. The low unit price shown on TEFAS does not show the amount paid to investors. The TRY 1 million interim payment and the net investment construct do not apply to the Hedef funds (70/1821). As at 21 October 2026 no distribution is visible on TEFAS in the other Hedef funds, including HKJ, HPH and KSA.

20OctTBMMPrimary source

Bill in the General Assembly: no article voted on 20 Oct

The bill was moved to first place on the agenda; the debates on the bill as a whole and on the first part were completed. No article was put to the vote on 20 October.

0articles voted on (morning of 21 Oct)
21–22 OctAssembly work plan; not a date of adoption

Record (unrevised)Law 7596

Details

TBMM General Assembly, 20 October 2026 (8th sitting). By a group motion that was adopted, the Planning and Budget Committee’s report (Report No. 294) was moved to first place in the “Bills” part of the agenda, and the bill is to be debated as a basic law in two parts (arts. 1–5 and arts. 6–9). At the same sitting the debate on the bill as a whole was completed and the Assembly voted to proceed to the articles; the debate on the first part was also completed. The sitting then closed. No article was put to the vote (unrevised record; the final record has not yet been published).

Under the adopted work plan, the General Assembly is to sit on 21 October 2026 until the votes on the articles in the second part are completed and on 22 October 2026 until the debate on the bill is completed. This is a decision on the Assembly’s working schedule, not the date on which the bill will be adopted. On the agenda for 21 October 2026 (9th sitting, 14.00) the bill is in first place (tbmm.gov.tr). At this note’s data cut-off (the morning of 21 October 2026) the bill had not been enacted or published in the Official Gazette; amendments adopted in the General Assembly may change its text.

19OctLawPrimary source

Committee report published (Report No. 294)

The adopted text is now in an official source: unitholding is to be determined by the records of MKK and of the institution charged with the liquidation; the “untrue value” test has been dropped from the voluntary return provision. The report states that the rights of investors with a PBLK entry will be protected “in their capacity as unitholders”.

3articles changed (arts. 2, 3, 4)
TRY 1 millionceiling on the interim payment only

Report (PDF)Law 7596

Details

The text adopted in committee. The Planning and Budget Committee’s report dated 19 October 2026 (Report No. 294, S.Sayısı 294) was distributed on 20 October 2026. According to the report: (i) the definition of unitholder now rests on “reconciliation of the records of MKK and of the institution charged with the liquidation” (art. 2(c); the original text also listed the records of Takasbank, TEFAS, the custodians and the distributors); (ii) unitholding is determined fund by fund and account by account by the institutions charged with the liquidation, by reconciliation with the MKK records (art. 3(5)); (iii) for voluntary returns the benchmark became the average of the changes in TÜFE and Yİ-ÜFE, and the original wording “on the basis of values that arose contrary to the truth” was dropped; for gains on shares, the reference is to shares the SPK has made the subject of arts. 104, 106 and 107 of Law No. 6362 (art. 4(4)). The words “from the liquidation assets of the fund concerned” in the interim payment provision were retained (art. 4(2)). Art. 1 and arts. 5–9, including the commencement provision, were adopted unchanged.

Statements of the public authorities in the report. According to the statements set out in the report, the payment obligations arising from sales matched at a price and completed on 14, 15 and 16 September were met; a share block (PBLK) entry does not mean that cash has reached the investor’s account; these instructions are treated as falling within the liquidation under the SPK announcement of 28 September 2026, and the rights of these investors will be protected within the liquidation “in their capacity as unitholders”. TRY 1 million is a ceiling only on the interim payment, not on total payments; the indexation not applied to the interim payment will be applied to the final payment. All decisions and acts of the SPK are subject to review by the administrative courts; persons excluded from payment may bring an action. Payments will be met only from the fund assets and amounts collected from those responsible. These statements are not part of the text of the law; how the PBLK statement relates to the priority payment under A/6 is not explained.

19OctPaymentPrimary source Press report

Payments in 23 more Bulls and Pardus funds; target for the interim payment

In the TEFAS record of 19 October 2026 the portfolios of 23 funds fell to residual amounts. The Economic Coordination Board said it expects the interim payments to begin “as soon as possible” after enactment; there is no firm date.

23 fundsBulls 8, Pardus 15 (TEFAS)
65 / 66funds with residual or zero portfolios

Fund list Payment rule

Details

A1 Capital, Bulls and Pardus. In the TEFAS record of 19 October 2026 the portfolios of the Bulls (BLA, BP5, BOH, BBN, BDO, IHY, BIK, BSN) and Pardus (AP6, BHH, AC7, PCH, PDH, DHI, DRH, PKU, POF, POB, PPO, OHI, POU, PST, CSH) funds fell to residual amounts. Of the 66 funds of these three founders on TEFAS, 65 now have residual or zero portfolios; one fund still shows assets above a residual amount. This is consistent with the Government’s statement of 18 October 2026 that the liquidation of 66 funds has been completed. A TEFAS record is based on the valuation of the previous business day; the record date is not the payment date. The low unit price does not show the amount paid to investors.

Economic Coordination Board. According to a statement reported in the press, the Board said: “We expect the interim payments to begin as soon as possible after the bill has been debated and enacted by the TBMM General Assembly” (unofficial translation). This is a target; no firm date was given. No distribution is visible on TEFAS in the 34 funds of Tera, Pusula and Atlas.

SPK Bulletin 2026/71. The SPK decided that, of the voting rights frozen because Tera Yatırım Holding AŞ failed to meet its obligation to make a mandatory tender offer in a real estate investment trust, those attaching to the THF, DOH, T3B and TLY funds under liquidation are to be released (PDF); the decision does not concern liquidation payments.

18OctPaymentPress report

A1 Capital, Bulls and Pardus: liquidation completed in 66 funds

According to the Government, liquidation transactions in kind and in cash of about TRY 40.8 billion were completed for more than 45,000 people in 66 funds; the number of funds in liquidation fell from 131 to 65. In the Hedef funds, payments are planned next week, “starting with those in the money market funds”; payments began on 20 October 2026 (see the 20 October card).

65funds still in liquidation (18 Oct; 47 on 22 Oct)
≈ TRY 40.8 bncompleted in 66 funds

When will the funds be paid?Fund list

Details

6th meeting of the Fund Coordination Board. According to a Directorate of Communications statement reported in the press, Ziraat Bankası completed liquidation transactions in kind and in cash of about TRY 40.8 billion for more than 45,000 people in the 66 funds of A1 Capital, Bulls and Pardus Portföy; the number of funds in liquidation fell from 131 to 65 (ankahaber.net). The statement said that the Hedef funds had been made subject to the same rules by the SPK decision of 15 October 2026, and that in this context payments to as many people as possible are planned next week, starting with those in the money market funds. The bill is expected to be debated in the General Assembly. The meeting also made a first assessment of a draft providing for permanent and comprehensive amendments to the Capital Markets Law; the draft has not been made public.

According to TEFAS data, the portfolios of the A1 Capital (BHN, BYZ, CBD, CHY, SEH), Bulls (BI5, BUC, YLZ) and Pardus (AC8, BSE, KRH, PHY, PO7, PO8, PO9, POI, PSR, SHI, PYD, PYI) funds fell to residual amounts on 16 October 2026; Pardus’s MGE fund has shown this pattern since 13 October 2026. The very low unit price shown on TEFAS reflects the residual amount left in the fund; it does not show the amount paid to investors. The word “in kind” in the statement indicates that some investors may have received capital market instruments instead of cash; the funds in which this was done have not been announced.

15OctSPKPrimary source

SPK 70/1821: Hedef funds moved to ordinary liquidation

The Hedef Portföy funds were removed from the scope of the interim payment decision (64/1775); their liquidation now follows the rules set for A1 Capital, Bulls and Pardus (64/1770). According to the company, payments began on 20 October 2026 (see the 20 October card).

31 fundsHedef Portföy
64/1770rules applied

SPK Bulletin 2026/70 Payments

Details

SPK decision 70/1821. According to SPK Bulletin 2026/70 (16 October 2026), by its decision of 15 October 2026 the Board removed the funds founded by Hedef Portföy Yönetimi A.Ş. from the scope of decision 64/1775 and decided to start liquidation proceedings for them; the liquidation is subject to the rules set by decision 64/1770 for the A1 Capital, Bulls and Pardus funds (PDF). Accordingly, the liquidation starts with the funds whose names include the words “para piyasası” (money market), proceeds from the fund with the most investors to the fund with the fewest, and the cash is distributed pro rata. For the Hedef funds, the TRY 1 million interim payment and the net investment construct no longer apply. The reasons for the decision have not been published. The founders that remain within the interim payment scheme are Tera, Pusula and Atlas.

The same bulletin also contains a two-year trading ban on Tera Yatırım Menkul Değerler A.Ş. and Tera Portföy Yönetimi A.Ş., limited to transactions in a particular share on their own account; that decision does not concern the liquidation of the funds.

14OctLawPrimary source

Bill adopted by the Planning and Budget Committee

Unitholding is now to be determined by reconciliation with the MKK records; the benchmark for voluntary returns is tied to inflation. The TRY 1 million interim payment cap is unchanged. The General Assembly debate began on 20 October 2026; the bill was adopted on 22 October 2026 (Law No. 7596).

3articles changed in committee (Report No. 294)
20 OctGeneral Assembly debate began

TBMM news item Law 7596

Details

Adopted in committee. Bill No. 2/3939 was adopted by the TBMM Planning and Budget Committee on 14 October 2026 (TBMM news item). The TBMM’s summary of the adopted text showed two differences from the original text: (i) unitholding is to be determined fund by fund and account by account by the institutions in charge of the liquidation by reconciliation with the MKK records (the original text listed the records of MKK, Takasbank, TEFAS, the custodians and the distributors); (ii) for voluntary returns, the benchmark is now the average of the changes in TÜFE and Yİ-ÜFE instead of the return of comparable funds and indices. The net investment amount, the TRY 1,000,000 interim payment cap, the money market exemption and the payment bar appeared unchanged from the original text. According to the committee report of 19 October 2026 (Report No. 294), the definition of unitholder (art. 2(c)) also changed in the same direction; see the 19 October card.

Statements in the debate (TBMM news item). The member of parliament who was the bill’s first signatory said that Takasbank and TEFAS officials had confirmed that receivables arising from instructions transmitted to TEFAS on 14, 15 and 16 September and matched at a price had been paid, and that there were also records left unpaid after the funds defaulted; that merely having given a sell instruction does not end a person’s unitholding; and that these investors’ rights over the fund assets will be protected in the liquidation. He repeated that no Treasury resources will be used. The Deputy Minister of Treasury and Finance said that the interim payment and the net investment amount are not defined in the existing legislation, which is why a law is needed. How these statements relate to the priority payment under A/6 has not been explained.

BDDK (16 October 2026). In the BDDK Chairman’s briefing to the committee, without naming banks, the phrase “banks whose management has been transferred to the TMSF” appears (bddk.org.tr).

13OctPaymentPrimary source

TRY 6.4 billion paid to 43,643 investors in 17 funds

5th meeting of the Fund Coordination Board: the target was to complete the liquidation of the remaining 49 funds of A1 Capital, Bulls and Pardus by the end of the week; interim payments to follow once the bill is enacted.

TRY 6.4 bnpaid in 17 funds
49 fundsend-of-week target

iletisim.gov.tr

Details

5th meeting of the Fund Coordination Board. According to the Directorate of Communications, TRY 6.4 billion was paid to 43,643 investors in the A1 Capital, Bulls and Pardus funds; the target was to complete the liquidation, worth TRY 34.1 billion, of these three companies’ remaining 49 funds by the end of the week (iletisim.gov.tr). The statement said that “once the bill on the TBMM’s agenda is enacted, the aim is also to complete without delay the interim payments for the other 65 funds in the liquidation process” (unofficial translation). At that date those 65 funds included the Hedef funds; since 15 October 2026 only the Tera, Pusula and Atlas funds remain within the interim payment scheme (70/1821). The Board’s 4th meeting was held on 9 October 2026 and reviewed the technical preparations for interim payments of up to TRY 1 million (iletisim.gov.tr).

09OctLawPrimary source

Bill No. 2/3939 submitted to parliament

Where cash falls short, payments would follow an inflation-indexed net investment amount rather than unit value, and the interim payment would gain a statutory basis. The bill was adopted on 22 October 2026 as Law No. 7596; the Law was published in the Official Gazette and entered into force on 27 October 2026.

TRY 1,000,000interim payment cap, per investor in each fund
14.10Planning and Budget Committee

Diagram and article-by-article summary Worked examples

Details

Bill No. 2/3939. AK Parti members of parliament submitted the “Bill on Certain Investment Funds Whose Liquidation Has Been Ordered” to the Speaker of the Grand National Assembly (TBMM) (bill record, text). The bill lays down special rules for the funds whose liquidation the SPK ordered on 17 September 2026 and whose liquidation is not completed when the law is published. Where cash does not cover the total value at the unit price at the end of the day before the liquidation decision, payments would follow an inflation-indexed net investment amount calculated by MKK rather than the value of the units, and the interim payment of up to TRY 1,000,000 per investor for each fund would gain a statutory basis. No payment would be made to persons whom the SPK determines to have committed, in connection with the funds, the acts in SPKn arts. 104, 106 or 107; value unlawfully extracted would be collected by the TMSF, and seized assets would go to the fund or to a recovery account that cannot be attached. The law would take effect from 17 September 2026. The bill is before the Planning and Budget Committee, which is to discuss it on 14 October 2026. (Note of 23 October 2026: the bill was adopted by the TBMM General Assembly on 22 October 2026 as Law No. 7596. Note of 27 October 2026: the Law was published in Official Gazette No. 33413 of 27 October 2026.) Details: Law No. 7596; for an article-by-article reading with hypothetical worked examples, see our news article on the bill.

08OctPaymentPress report Primary source

A1 Capital, Bulls and Pardus: payments in 17 funds

Ziraat Bankası transferred the liquidation proceeds to the banks and brokerage firms holding investors’ accounts, which are to credit them. The process continues in the other funds.

17 fundsproceeds transferred to institutions
09.10residual portfolios on TEFAS

List of funds FAQ

Details

Payments in the 17 funds of A1 Capital, Bulls and Pardus. According to a Directorate of Communications statement reported in the press, T.C. Ziraat Bankası A.Ş. transferred the liquidation proceeds of the A1 Capital (AJ1, CAH, P1A, PAB), Bulls (BMU, BOS, BPZ) and Pardus (AC4, AC5, BRT, BST, IAU, KHA, PAO, PMP, POS, PYR) funds to the banks and brokerage firms holding investors’ accounts; those institutions are to credit the amounts to investors’ accounts. On TEFAS the portfolios of these 17 funds fell to residual amounts on 9 October 2026; the very low unit price shown from that date does not show the amount paid to investors. The process continues in the other funds.

07OctTBMMPrimary source

Government statement in parliament: interim payment tied to the bill

If the bill is enacted, the interim payment is expected “within October”; final liquidation is targeted within “five to six months”. The speech said that “no Treasury resources will be used”.

455,758unique investors (131 funds)
43,643investors to be paid under ordinary rules (17 funds)
56,614people: Atlas’s 16 funds, subject to collateral

Transcript Payment rule

Details

Government statement in parliament. The Vice President addressed the TBMM General Assembly and made the interim payment conditional on the bill being enacted:

“… taslak kanun teklifinin yasalaşması hâlinde ekim ayı içinde 1 milyon liraya kadar anapara ödemelerinin yapılabileceğini öngörüyoruz.”
TBMM General Assembly transcript, 07.10.2026 (original Turkish)

“… if the draft bill is enacted, we expect payments of principal up to TRY 1 million to be made within October.”
(unofficial translation)

According to the speech, the 131 funds have 455,758 unique investors: 151,247 in the 125 funds for whose liquidation Ziraat Bankası is responsible and 388,718 in the 6 funds for which İş Bankası is responsible (the sum is higher because an investor may hold more than one fund). The banks have formally taken over custody. It was stated that 43,643 investors in the 17 funds of A1 Capital, Bulls and Pardus would be paid under ordinary liquidation rules, that the 49 private funds of these companies, with 2,098 investors, would be dealt with separately, and that if the necessary collateral is obtained, payments in Atlas’s 16 funds, covering 56,614 people, would also be made under ordinary liquidation rules. Final liquidation is targeted within “five to six months”, and the speech said that “no Treasury resources will be used”. It also stated that outflows of securities and cash from the accounts of 6 brokerage firms and 7 portfolio management companies were being handled under control, under an SPK decision, by joint decision of MKK, Borsa İstanbul and Takasbank; the SPK’s decision and the names of the firms have not been published.

06OctSPKPrimary source

SPK statement on Borsa İstanbul notifications

The SPK replied to a press claim that the notifications had been disregarded and gave its 2026 enforcement figures.

174persons subject to criminal complaints (2026)
96complaints concerning fund-related transactions

spk.gov.tr

Details

SPK statement. Replying to a press claim that Borsa İstanbul’s notifications had been disregarded, the SPK stated that criminal complaints had been filed against 174 persons since the start of 2026 and that 96 of the complaints made in 2026 concerned fund-related transactions (spk.gov.tr).

04OctSPKPrimary source

SPK: the YTM asset-protection provision is not new

The claim that the provision was introduced for the first time in July 2026 is unfounded; it has been in the SPKn since 2012.

30.12.2012in the SPKn
06.06.2013in the YTM regulations

spk.gov.tr YTM

Details

SPK statement. The SPK stated that the claim that the provision protecting the assets of the Investor Compensation Centre was introduced for the first time in July 2026 is unfounded; the provision has been in the SPKn since 30 December 2012 and in the YTM regulations since 6 June 2013 (spk.gov.tr).

03OctSPKPrimary source

SPK Bulletin 2026/68: margin relief extended

The relaxed equity ratio for margin transactions was extended. Bulletins 2026/68 and 2026/69 contain no new decision on the liquidation.

30.10.2026end of the relief; not a time limit for investors

PDF

Details

SPK Bulletin 2026/68. The measure introduced by decision 57/1706 relaxing the equity ratio for margin (credit) transactions was extended to the end of the session on 30 October 2026 (PDF). Neither Bulletin 2026/68 nor Bulletin 2026/69 of 7 October 2026 contains any new decision on the liquidation procedure, the start of the interim payment or the application of A/6.

01OctSPKPrimary source

Voluntary return accounts opened

For persons who made excessive gains to return them to the fund voluntarily. Not for payments to investors.

131funds listed with TEFAS codes

SPK announcement FAQ

Details

Voluntary return accounts. The SPK announced that accounts had been opened in the name of each fund so that persons who made excessive gains may voluntarily return those gains to the fund. These accounts are not for payments to investors. The list in the announcement also gives the TEFAS codes of the 131 funds.

30SepPaymentPrimary source

Interim payment decision (64/1775)

For reconciled unitholders in the Tera, Pusula, Atlas and Hedef funds (Hedef was removed from its scope by 70/1821 on 15 October 2026), based on the net investment amount to be calculated by MKK. No payment date has been announced.

TRY 1 millionper investor, separately for each fund
Money marketfunds first

Bulletin 2026/67 64/1775

Details

Interim payment (64/1775). In the funds of Tera, Pusula, Atlas and Hedef Portföy, an interim payment will be made to unitholders whose reconciliation has been completed, based on the net investment amount to be calculated by MKK and capped at TRY 1 million per investor, separately for each fund. Payments will begin with the money market funds; no units are redeemed in return for the interim payment. No payment date has been announced.

30SepSPKPrimary source

A1 Capital, Bulls and Pardus: order of liquidation (64/1770)

Funds with “para piyasası” (money market) in their names first, then from the most investors to the fewest. Funds outside the list that were closed may be reopened later.

SPK announcement 64/1770

Details

A1 Capital, Bulls and Pardus funds (64/1770). The liquidation will proceed starting with the funds whose names include the words “para piyasası” (money market), and then from the fund with the most investors to the fund with the fewest. Funds of these founders that are outside the liquidation but were closed on 17 September 2026 may be reopened to trading at a later stage.

30SepTMSF · BDDKPrimary source

Measures concerning Tera Yatırım and three banks

The SPK temporarily suspended Tera Yatırım Menkul Değerler; the BDDK decided that certain shareholder rights in three banks are to be exercised by the TMSF. In the BDDK’s briefing of 16 October 2026, without naming banks, the phrase “banks whose management has been transferred to the TMSF” appears.

3 banksDestek, Hedef and Tera Yatırım Bankası

BDDK decision

Details

Measures concerning institutions. The SPK temporarily suspended the capital market activities of Tera Yatırım Menkul Değerler A.Ş. The BDDK decided that the shareholder rights other than dividend rights attaching to certain qualifying shareholdings in Destek, Hedef and Tera Yatırım Bankası are to be exercised by the TMSF (Savings Deposit Insurance Fund). In the BDDK’s briefing of 16 October 2026, without naming banks, the phrase “banks whose management has been transferred to the TMSF” appears (bddk.org.tr).

28SepSPKPrimary source

Instructions of 17 September: paid pro rata

Instructions given on 17 September 2026 were cancelled by TEFAS; those transmitted on or before 16 September 2026 and not executed because of default or no published price fall under A/6.

16.09and earlier: within A/6
17.09cancelled; paid pro rata

A/6 Scenario 1 Scenario 4

Details

Instructions of 17 September. The SPK stated that, because the funds were closed to trading on TEFAS on 17 September 2026, all instructions given on that day were cancelled by TEFAS:

“… iptal edilen talimatların sahiplerine; tasfiye bakiyesinden, fondaki katılma payı sahipliği oranında ödeme yapılacaktır.”
SPK announcement, 28.09.2026 (original Turkish)

“… the holders of the cancelled instructions will be paid out of the liquidation balance, pro rata to their unitholdings in the fund.”
(unofficial translation)

According to the same announcement, instructions transmitted to TEFAS on or before 16 September 2026 but not executed because the fund defaulted or did not publish a price fall within the liquidation for the purposes of A/6. Scenarios 1, 2 and 4 have been updated in light of this announcement.

✎NoteCorrection

Three points corrected in this note

1 October 2026 (A/3) is not a deadline for investors; the liquidation list has 131 funds, not 130 (THF was added); the TEFAS code of Global MD Portföy Berrak Serbest Fon is BSM.

FAQ: 1 October 2026 BSM

Details

Three points in the previous version of this note have been corrected: 1 October 2026 (A/3) is not a deadline for applications by investors; Bulletin 2026/60 ordered the liquidation of 130 funds, and Bulletin 2026/61 brought the list to 131 by adding THF; the TEFAS code of Global MD Portföy Berrak Serbest Fon is BSM, not GMD.

06 · Law

The fund liquidation law: Law No. 7596 in force (Official Gazette 27.10.2026, No. 33413)

Has the fund liquidation law passed? Yes; it has been published and is in force. The TBMM General Assembly adopted the bill on 22 October 2026 as Law No. 7596 on Certain Investment Funds Whose Liquidation Has Been Ordered (Tasfiyesine Karar Verilen Bazı Yatırım Fonları Hakkında Kanun). Articles 6–9 were adopted unchanged, every amendment being rejected, and the bill as a whole was adopted by electronic vote. The Law was sent to the Presidency the same day and was published in Official Gazette No. 33413 of 27 October 2026 (resmigazete.gov.tr); under art. 8 it entered into force the same day, with effect from 17 September 2026. The Official Gazette text is identical to the text adopted by the TBMM. The Law leaves the implementing rules to the SPK (art. 4(2), 4(4), 7(2)); by decision 76/1903 of 27 October 2026 the SPK set the procedures and principles for the liquidation and payments: the interim payment will be made in the funds under liquidation founded by Tera, Pusula and Atlas Portföy (details). The decision gives no date; according to the Directorate of Communications, the first interim payments are expected to begin on 30 October 2026 (as reported in the press). The calculation period, method and accounts for voluntary returns (art. 4(4)) had not been set as at 5 November 2026. The bill had been submitted to the Speaker of the TBMM on 9 October 2026 and adopted by the Planning and Budget Committee on 14 October 2026; the committee report was distributed as Report No. 294 on 20 October 2026; on 21 October 2026 the General Assembly adopted Articles 1–5 and added a sentence to Article 3 by amendment (below). What follows is based on the text of the Law published in the Official Gazette (identical to the text published by the TBMM as adopted by the General Assembly) and on the committee report (Report No. 294). Quotations are unofficial translations.

Article-by-article reading and hypothetical worked examples: our news article on the bill.

09.10.2026Submitted to the TBMM91 signatories; lead committee Planning and Budget
14.10.2026Planning and Budget CommitteeAdopted; arts. 2, 3 and 4 changed. Report: No. 294 (19.10.2026)
21.10.2026General Assembly: Articles 1–5Adopted; PBLK sentence added to Article 3 (unrevised record)
22.10.2026General Assembly: Articles 6–9 and the bill as a wholeAdopted; Law No. 7596. All amendments rejected (unrevised record, record of the Law). Sent to the Presidency the same day
27.10.2026Publication in the Official Gazette and entry into forceOfficial Gazette of 27 October 2026, No. 33413 (resmigazete.gov.tr); the date beneath the text is 26.10.2026. In force on the date of publication, with effect from 17.09.2026 (art. 8). The text is identical to the text adopted by the TBMM
27.10.2026SPK implementing decision: 76/1903Procedures and principles for the liquidation and payments (SPK Bulletin 2026/76): interim payment in the Tera, Pusula and Atlas funds; funds named “para piyasası” first (details)
Date not knownVoluntary returns: SPK decision on period, method and accounts (art. 4(4))76/1903 does not deal with these matters; no decision as at 5 November 2026

Provisions changed in committee · 14.10.2026 · Report No. 294

Unitholder and unitholding (arts. 2(c), 3(5))

Original text: reconciliation of the records of MKK, Takasbank, TEFAS, the portfolio custodians, the distributors and the institution charged with the liquidation.

Adopted: reconciliation of the records of MKK and of the institution charged with the liquidation; the institutions charged with the liquidation determine unitholding fund by fund and account by account by reconciliation with the MKK records. Persons against whom the SPK makes a determination barring payment under art. 3(6) fall outside the definition.

Voluntary returns (art. 4(4))

Original text: the gain exceeding a benchmark return, of persons who redeemed their units “on the basis of values that arose contrary to the truth”.

Adopted: the return of persons who redeemed their units to the fund before the liquidation date, in excess of their inflows updated by the average of the changes in TÜFE and Yİ-ÜFE. The “untrue value” qualification no longer appears. Returns are voluntary.

Gains on shares (art. 4(4))

Original text: shares whose prices the SPK finds to have arisen contrary to the truth; an index or objective market benchmark.

Adopted: gains on shares the SPK has made the subject of arts. 104, 106 and 107 of Law No. 6362, in excess of the purchase cost updated by the same average; voluntary return to the general share return account.

Adopted unchanged

Art. 1 and arts. 5–9 (including commencement) were adopted unchanged. The net investment amount, the TRY 1,000,000 interim payment cap and the words “from the liquidation assets of the fund concerned” (art. 4(2)), the money market exemption, the payment bar (art. 3(6)) and the TMSF and YTM provisions did not change.

Source: Planning and Budget Committee report, Report No. 294 (19 October 2026), “Decision of the Committee on the articles” and comparison table (PDF). The committee text contained no specific provision on unexecuted redemption instructions (A/6); for the sentence added to Article 3 in the General Assembly, see below. The Law covers funds whose liquidation is not completed on the date of its publication (27 October 2026); whether the 66 funds whose liquidation has been announced as completed, the 18 Hedef funds whose liquidation the Government says had been completed as at 21 October 2026, and other funds whose liquidation may have been completed before publication, remain within the provisions on voluntary returns, TMSF collection and the recovery account is unclear.

Statements of the public authorities in the report (not part of the text of the law): TRY 1 million is a ceiling only on the interim payment, not on total payments, and applies fund by fund; the interim payment does not end unitholding, and the indexation not applied to the interim payment will be applied to the final payment; a share block (PBLK) entry does not mean that cash has reached the investor’s account, and the rights of these investors will be protected within the liquidation “in their capacity as unitholders”; all decisions and acts of the SPK are subject to review by the administrative courts, and persons excluded from payment may bring an action; voluntary returns do not result in an amnesty, release or impunity.

Provision changed in the General Assembly · 21.10.2026 · text of Law No. 7596 (TBMM)

Blocked units (art. 3(5), last sentence)

Report No. 294: unitholding is determined fund by fund and account by account by the institutions charged with the liquidation, through reconciliation with the MKK records.

Added in the General Assembly: “Provided that, in respect of instructions concerning the funds subject to liquidation that were transmitted to TEFAS on or before 17/9/2026 but could not be executed because of the default of the fund concerned and/or the non-publication of its unit price, those whose units have been blocked shall be subject to the liquidation provisions of this Law in their capacity as fund unitholders.” (unofficial translation)

In the text of the Law, the semicolon after “Fon pay sahipliği” at the start of the paragraph became a comma; the wording of the added sentence is the same as in the unrevised record of 21 October 2026.

Reasons for the amendment and the rejected amendment

According to the reasons given, instructions whose settlement was completed were paid in the ordinary course; instructions that could not be executed because of a default or the non-publication of the price became “invalid”, and those holding units in the TEFAS transaction block sub-account are also within the liquidation “in their capacity as fund unitholders”; the provision “does not affect transactions whose payment has been completed”. An amendment treating these investors’ claims as protected by settlement finality (SPKn art. 79) and providing for payment “with priority and immediately in cash” from the first cash available in the liquidation account was rejected. The adopted text contains no separate creditor ranking or priority.

Adopted unchanged

Articles 1, 2, 4 and 5 were adopted as in Report No. 294; the other paragraphs of Article 3 (including the payment bar in art. 3(6)) did not change. An amendment to delete the words “without indexation” from Article 4 was rejected. Articles 6–9 were adopted on 22 October 2026 in the wording of Report No. 294, all 20 amendments tabled to them being rejected.

The SPK’s view (22.10.2026)

In a press release of 22 October 2026 the SPK stated that the settlement-finality provision in SPKn art. 79 does not mean that it must apply to all instructions given through TEFAS “regardless of the stage the transaction has reached”, and that settlement is completed when the cash is credited to the investor’s account and the record of unitholding is removed. According to the SPK, persons with a share-block entry are among the 455,758 fund unitholders and “do not form an additional group”; their instructions will be assessed on the amounts obtained in the liquidation “on equal terms with the other unitholders” (spk.gov.tr). That is the view the SPK has stated; it is not a court ruling.

Source: unrevised record of the TBMM General Assembly, 9th sitting (21 October 2026) (tbmm.gov.tr) and the text of Law No. 7596 as adopted by the General Assembly and published by the TBMM (tbmm.gov.tr). The text of the Law was compared with Report No. 294; the only difference is in art. 3(5). The text published in the Official Gazette of 27 October 2026 (No. 33413) is identical to the TBMM text; these provisions have been in force since 27 October 2026.

The payment rule in Law No. 7596 (art. 4), step by stepIn force · Official Gazette 27.10.2026

1Cash test
Does distributable cash cover the total value at the unit price “valid at the end of the day before the liquidation decision”?

Yes → the Law’s net investment rule does not apply; pro rata distribution under 57/1708 A/5No → the net investment amount is taken into account (step 2)
2Net investment amount
Each cash inflow into the fund and each outflow from it is updated to the liquidation date by the arithmetic average of the changes in TÜFE and Yİ-ÜFE (pro rata temporis); where inflows exceed outflows, outflows are deducted first-in, first-out. Calculated by MKK.
3Interim payment cap
In funds designated by the SPK, the payment may exceed none of these three limits:
- TRY 1,000,000per investor, separately for each fund
- Net investment amountcalculated without indexation
- Current value of the unitsend of the previous day, Takasbank price; in the Law this limit does not apply to funds of a money market nature. SPK 76/1903 art. 6: if cash is insufficient, for funds named “para piyasası” the amount calculated as at the end of the day before 17.09.2026
payment = the lowest
4If cash falls short
The SPK may order payment starting from the unitholder with the lowest net investment amount and/or set a minimum interim amount for all. No units are redeemed in return for the interim payment. SPK decision 76/1903 details this step: an order from the smallest to the largest interim payment amount and/or a minimum interim payment amount, with the Board’s approval (art. 8); the order of payment is in art. 4 and art. 7 (details).
5Final payment
Payments previously made from the liquidation assets, the recovery account or through other legal avenues are deducted (art. 4(5)).

Payment bar (art. 3(6))No payment from the liquidation and the recovery account to persons and institutions the SPK determines to have committed, in connection with the funds, the acts in SPKn arts. 104, 106 or 107, or to have acted together with them.

Recovery account (art. 6)Amounts in the account held at the TMSF are transferred to the YTM after the liquidation and paid out “in proportion to unitholding” — not by net investment amount.

Out of scope and not addressedFunds not on the liquidation list (e.g. TMV) are outside the Law. The Law makes no reference to the priority payment under A/6; under the sentence added to Article 3 in the General Assembly, those whose units have been blocked are subject to the liquidation provisions “in their capacity as fund unitholders” (amendment).

Value on 17 September 2026 and current value by number of units: Fund value calculator. Under the Law MKK calculates the net investment amount; how the calculation will be shown to investors has not been announced.

RecordBill No. 2/3939; received by the Speaker on 9 October 2026. According to the TBMM bill record, all 91 signatories are AK Parti members of parliament. Lead committee: Planning and Budget; secondary committees: Justice, and Industry, Trade, Energy, Natural Resources, Information and Technology. The Planning and Budget Committee has placed the bill on the agenda of its meeting of 14 October 2026 at 10.00 (committee agenda). The committee report is dated 19 October 2026 and was distributed as Report No. 294 on 20 October 2026; the General Assembly debate began on 20 October 2026; Articles 1–5 were adopted on 21 October 2026, and Articles 6–9 and the bill as a whole on 22 October 2026 (Law No. 7596; 28th Parliamentary Term, 5th Legislative Year, 10th sitting). The Law was sent to the Presidency on 22 October 2026 and published in Official Gazette No. 33413 of 27 October 2026. The secondary committees did not report.
NatureA nine-article, case-specific and stand-alone law. It does not amend the Capital Markets Law No. 6362, the Banking Law No. 5411 or the Code of Criminal Procedure No. 5271; it refers to tools in those laws. According to the explanatory memorandum, no public or budget resources will be used for payments.
TextLaw No. 7596 (Official Gazette 27.10.2026, No. 33413) · Record of Law No. 7596 (TBMM) · Text of the Law (TBMM, as adopted by the General Assembly; Turkish) · TBMM bill record · Text and explanatory memorandum (PDF, Turkish) · Committee report and adopted text, Report No. 294 (PDF, Turkish)

Article by article (arts. 1–9)purpose, definitions, payment bar, net investment, personal liability, recovery account, entry into force

Art. 1
Purpose and scope. The liquidation of the investment funds whose liquidation the SPK ordered by its decisions of 17 September 2026 and whose liquidation is not completed on the date the law is published, the recovery of value unlawfully extracted from them, and the payment of recovered amounts to unitholders.

“The provisions of this Law do not create a general or permanent liquidation and liability regime for investment funds other than those specified in the first paragraph.”
Law No. 7596, art. 1(2)
Art. 2
Definitions and abbreviations. Under the text adopted in committee, a “unitholder” is, subject to art. 3(6), the holder of fund participation units whose right to payment from the liquidation balance of the fund concerned is established through reconciliation of the records of MKK and of the institution charged with the liquidation (art. 2(c)). The original text also listed the records of Takasbank, TEFAS, the portfolio custodians and the distributors; according to the report, the aim of the change is consistent practice, as the records are kept at MKK. The “recovery account” is a special account held at the TMSF, separate from the TMSF’s own assets, with a separate sub-account for each fund; amounts paid into the SPK’s voluntary return accounts are also tracked in it.
Art. 3
Conduct of the liquidation. The liquidation is carried out under SPK supervision; the SPK sets the stages, valuation principles, the determination of unitholding, interim and final payments and the order of distribution. Where the exchange price does not reflect real value, methods such as buy-backs, block sales and off-exchange sales may be ordered. Institutions asked for information cannot refuse it on grounds of confidentiality or secrecy. Unitholding is determined fund by fund and account by account by the institutions charged with the liquidation, through reconciliation with the MKK records (art. 3(5)). On 21 October 2026 the General Assembly added to this paragraph a sentence stating that, where instructions transmitted to TEFAS on or before 17 September 2026 could not be executed because the fund defaulted and/or its unit price was not published, those whose units have been blocked are subject to the liquidation provisions “in their capacity as fund unitholders” (full text).

Payment bar (art. 3(6)).

“Where the acts set out in Articles 104, 106 or 107 of Law No. 6362 are committed by the funds whose liquidation was ordered by the Board’s decisions of 17/9/2026, or by acting together with these funds, or with the participation of the funds, no payment shall be made … from the liquidation and the recovery account to the persons and institutions determined by the Board to have committed these acts or to have acted together with them.”
Bill No. 2/3939, art. 3(6)

The bar applies only where the act was committed in connection with the funds, and it turns on an administrative determination by the SPK; the Law requires no court ruling and lays down no procedure or objection route for the determination. According to the statement of the public authorities in the committee report, all decisions and acts of the SPK are subject to review by the administrative courts; persons excluded from payment may bring an action and, if the decision is annulled, benefit from the payment. SPKn art. 104 (market-disruptive acts) is an administrative infringement punished by fines; arts. 106 (insider dealing) and 107 (market manipulation) are criminal offences.
Art. 4
Net investment amount. Where distributable cash does not cover the total value at the unit price “valid at the end of the day before the liquidation decision”, payments take account of the net investment amount: each cash inflow actually made into the fund and each cash outflow from it is updated to the liquidation date, pro rata temporis, by the arithmetic average of the rates of change in the consumer price index (TÜFE) and the domestic producer price index (Yİ-ÜFE); where inflows exceed outflows, each outflow is deducted “on a first-in, first-out basis”. MKK makes the calculation. According to the explanatory memorandum, the amount does not create a new claim; it is a ceiling and distribution criterion for the stage at which cash is insufficient.

Interim payment (art. 4(2)–(3)). In funds designated by the SPK, an interim payment may be made from the relevant fund’s liquidation assets: the full net investment amount where it is below TRY 1,000,000, and at most TRY 1,000,000 where it is higher. Because the payment comes from the relevant fund’s assets, the cap applies per investor in each fund separately, as the SPK’s announcement of 1 October 2026 also states (the memorandum’s reference to “per person” should be read in that light); the words “from the liquidation assets of the fund concerned” appear twice in the text adopted in committee. According to the committee report, TRY 1 million is a ceiling only on the interim payment, not on total payments, and the indexation not applied to the interim payment will be applied to the final payment. The interim payment may not exceed the net investment amount calculated without indexation and, except in funds of a money market nature, the value of the units in the account at the end of the previous day at a price calculated by Takasbank. If cash falls short, the SPK may order payment starting from the unitholder with the lowest net investment amount and/or set a minimum interim amount for all. No units are redeemed in return for the interim payment. The SPK set the funds in which the interim payment is made and the implementing rules by decision 76/1903 of 27 October 2026: the funds under liquidation founded by Tera, Pusula and Atlas Portföy (details).

Voluntary returns and deduction (art. 4(4)–(5)). Under Law No. 7596 (Official Gazette 27.10.2026, No. 33413; in force), persons who received payment by redeeming their units to the fund before the liquidation date may voluntarily return to accounts announced by the SPK the return in excess of their inflows updated, pro rata temporis, by the arithmetic average of the changes in TÜFE and Yİ-ÜFE. The original qualification “on the basis of values that arose contrary to the truth” does not appear in the adopted text. For gains on shares, the reference is to shares the SPK has made the subject of arts. 104, 106 and 107 of Law No. 6362; the gain in excess of the purchase cost updated by the same average may be returned voluntarily to the general share return account. According to the memorandum and the committee report, a return does not result in an amnesty, release or impunity, nor is it an acknowledgement of debt. The calculation period, the method and the other procedures and principles are to be set by the SPK; as at 5 November 2026 the SPK had not taken that decision (76/1903 does not deal with these matters). More: Voluntary refunds.

“In the final payment, payments previously made to the unitholder from the liquidation assets, the recovery account or through other legal avenues shall be deducted.”
Law No. 7596, art. 4(5)
Art. 5
Unlawfully extracted value and personal liability. Value transferred out of a fund through unfunded or sham loans, guarantees, transfers, assignments, sales, repos and similar transactions that breach the rules, or comply in form but have no genuine economic purpose, is deemed unlawfully extracted. “The portfolio management company that is the founder and/or manager of the fund is primarily liable for the loss.” If recovery fails, the natural and legal persons whose responsibility the SPK determines are personally liable. For cases not covered by art. 6, the SPK determines the loss and the persons liable and notifies the TMSF, which pursues collection under Law No. 6183 on the Collection of Public Receivables. The Istanbul administrative courts have jurisdiction over related actions.
Art. 6
Seized and confiscated assets; recovery account. Cash and capital market instruments that can be returned directly to a fund are returned to the fund or the recovery account under CMK art. 131; reports supporting the SPK’s criminal complaints count as the report under CMK art. 128. The TMSF may be appointed trustee over other assets and sell them “without waiting for the outcome of the case”. Confiscated assets that a court finds came from a fund go to the fund or the recovery account without being recorded as Treasury revenue. Amounts in the recovery account “cannot be attached even for public receivables, and no interim injunction or precautionary attachment may be imposed on them.” After the liquidation is completed, they are transferred to the YTM and paid out “in proportion to unitholding”; that distribution is pro rata, not by net investment amount.
Art. 7
Implementation. The SPK and the YTM may procure outside legal, accounting and software services; the SPK sets the implementing rules (taking the TMSF’s opinion on matters within the TMSF’s remit) (art. 7(2)); the SPK set the procedures and principles for the liquidation and payments by decision 76/1903 of 27 October 2026. Where the Law is silent, Laws Nos. 6362, 5271 and 5411 apply.
Art. 8
“This Law shall enter into force on the date of its publication, with effect from 17/9/2026.”
Law No. 7596, art. 8 (adopted unchanged in committee and in the General Assembly). The Law was published in the Official Gazette of 27 October 2026 and entered into force the same day
Art. 9
Execution. The President executes the law.

What the Law does not addressA/6, custodians and distributors, YTM, funds outside the scope, procedure

Unexecuted redemption instructions (A/6). The Law makes no reference either to A/6 or to the SPK’s announcement of 28 September 2026. The committee text contained no provision on the matter; on 21 October 2026 the General Assembly added to Article 3 a sentence stating that those whose units were blocked under instructions that could not be executed because of a default or the non-publication of the price are subject to the liquidation provisions “in their capacity as fund unitholders”, and rejected an amendment giving these investors priority payment (amendment). The Law entered into force on 27 October 2026; as at 5 November 2026 it had not been explained how this sentence will affect the priority payment provision in A/6; SPK decision 76/1903 contains no provision on A/6 or on blocked units.
Liability of custodians and distributors. Art. 5 targets the portfolio management company and persons the SPK holds liable; there is no specific provision on the liability of portfolio custodians (SPKn art. 56) or of the banks and brokerage firms that sold the units.
YTM compensation scheme. SPKn arts. 82–85 are unchanged. The YTM’s new task is to pay out, pro rata, the amounts in the recovery account after the liquidation is completed; this is not compensation.
Funds outside the scope. The Law covers only the funds whose liquidation was ordered by the decisions of 17 September 2026; funds not on the liquidation list, such as TMV, are outside it. For the 49 private funds of A1 Capital, Bulls and Pardus the Government has announced a separate solution; the Law contains no specific provision on them. The liquidation appointments made by the SPK in Bulletin 2026/75 of 26 October 2026 for the funds of Tera Portföy and Pusula Portföy outside the decisions of 17 September 2026 also rest on the SPKn; these funds are outside the scope of Law No. 7596 (art. 1).
Procedure for investors. There is no route to see or contest MKK’s net investment calculation, no payment deadline and no transitional provision for pending actions. No new offence or administrative fine is created.

Open questionsretroactivity, art. 3(6), administrative actions, funds whose liquidation is completed, nil net investment, money market funds

These are questions, not conclusions; which of them will matter in practice depends on how the SPK applies the Law. The text published in the Official Gazette (27 October 2026) is identical to the text adopted by the TBMM.

Retroactive effect. The Law entered into force on 27 October 2026 with effect from 17 September 2026. How will replacing the pro rata distribution under 57/1708 A/5 by a later statute be assessed under the principle of legal certainty (Constitution, art. 2) and the right to property (art. 35)? Will the move from unit value to net investment amount be regarded as a proportionate interference?
Art. 3(6). The payment bar turns on an SPK determination; the procedure, notification, right of defence and objection route are not regulated. How will this exclusion be assessed under the presumption of innocence (art. 38) and the right of access to court (art. 36)? What happens to payments made before a determination, and to the effect of a later acquittal or annulment?
Administrative actions. How will actions brought, or still to be brought, against 57/1708, the SPK announcement of 28 September 2026 or 64/1775 be affected by the effect from 17 September 2026? The Law has no transitional provision. The calendar calculations for 16, 27 and 30 November 2026 do not change by reason of the Law alone.
Funds whose liquidation is completed. The Law applies only to funds whose liquidation was not completed on publication (27 October 2026). The Government has announced that the liquidation of the 66 funds of A1 Capital, Bulls and Pardus has been completed; residual portfolios still appear on TEFAS in these funds. Payments in the Hedef funds began on 20 October 2026; according to the Government, the liquidation of 18 of the 31 Hedef funds had been completed as at 21 October 2026. Will funds whose liquidation was completed before that date remain within the provisions on voluntary returns, TMSF collection and the recovery account? In the General Assembly debate of 20 October 2026 a member of parliament said that these funds would not fall within the law; that is the view of a member of parliament, and there is no official interpretation.
Blocked units and settlement finality. In the General Assembly, opposition members argued that the sentence added to Article 3 conflicts with the principle of settlement finality in SPKn art. 79. The SPK, for its part, stated in a press release of 22 October 2026 that the settlement-finality provision does not mean that it must apply to all TEFAS instructions “regardless of the stage the transaction has reached”, that persons with a share-block entry are among the 455,758 fund unitholders, and that they will be assessed “on equal terms with the other unitholders” (spk.gov.tr); that is the authority’s view, not a court ruling. Now that it is in force (27 October 2026), how will this sentence be assessed under the right to property (Constitution, art. 35) and the principle of legal certainty (art. 2)? How many investors and what amounts the provision affects has not been officially disclosed.
Nil or negative net investment. The text does not expressly say what a unitholder whose outflows exceed inflows receives at the final distribution.
“Funds of a money market nature”. The text does not say which funds are exempt from the current-unit-value cap on the interim payment (for example short-term debt funds whose names do not include “para piyasası”).

Opposition bill. Bill No. 2/3895, submitted on 28 September 2026 by a Yeni Parti member with a single signature, proposes an independent liquidation board, an “equal treatment date” and distribution in proportion to net investment updated by the consumer price index; in the Planning and Budget Committee, a motion to combine it with Bill No. 2/3939 was not adopted (Report No. 294).

07 · Voluntary refunds

Voluntary refunds (gönüllü / isteğe bağlı iade): the text of the Law, the SPK accounts and official statements

Voluntary refunds are provided for in Article 4(4) of Law No. 7596 as a “voluntary” (isteğe bağlı) return: persons who received payment by redeeming their units to the fund before the liquidation date may return, to accounts announced by the SPK, the return in excess of their inflows updated by the average of the changes in TÜFE and Yİ-ÜFE, and gains on shares that the SPK has made the subject of arts. 104, 106 and 107 of Law No. 6362 may be returned to the extent that they exceed the same benchmark. The Law was published in Official Gazette No. 33413 of 27 October 2026; this provision too entered into force that day, with effect from 17 September 2026. The calculation period, the method and the “accounts announced by the Board” are to be set by the SPK (art. 4(4)); as at 5 November 2026 the SPK had not set them. SPK decision 76/1903 of 27 October 2026 does not deal with these matters; it only sets the order in which amounts transferred to the general share return account are distributed to the funds (art. 11). This section sets out, with sources, the text of the Law, the SPK’s announcement of 1 October 2026, the public bodies’ statement in the committee report and the Minister of Justice’s statements; it does not assess, or give any guidance on, making or not making a refund.

Text of the Law · Law 7596 art. 4(4) · in force (Official Gazette 27.10.2026)

The paragraph provides for two separate returns. Fund returns: in the funds whose liquidation the SPK ordered by its decisions of 17 September 2026, the return made by persons who received payment by redeeming their units to the fund before the liquidation date, in excess of the amount found by updating their inflows to the liquidation date, pro rata temporis (kıstelyevm), by the arithmetic average of the changes in TÜFE and Yİ-ÜFE, “may be returned on a voluntary basis to the accounts announced by the Board” (Kurulca ilan edilen hesaplara isteğe bağlı olarak iade edilebilir). Share gains: the return made by persons who gained from shares held in these funds’ assets that the SPK has made the subject of arts. 104, 106 and 107 of Law No. 6362, in excess of the purchase cost for the holding period updated by the same average, “may be returned on a voluntary basis to the general share return account announced by the Board” (genel hisse iade hesabı). Primary source

“The Board is authorised to determine the calculation period, the method to be used in determining the amount to be returned and the other procedures and principles for the application of this paragraph.”
Law No. 7596, art. 4(4), last sentence (Official Gazette 27.10.2026, No. 33413; unofficial translation)

In the text, the return is “voluntary”; there is no provision on the consequences of not making a return, on criminal liability or on effective repentance (etkin pişmanlık). Under the Law, amounts paid into the voluntary return accounts and the general share return accounts are held in the recovery account at the TMSF, in a separate sub-account for each fund (art. 2(ç)); once the liquidation is completed, the amounts in the recovery account are transferred to the YTM and paid “in proportion to unitholdings” (art. 6). Earlier payments are deducted in the final payment (art. 4(5)). These provisions have been in force since 27 October 2026. The benchmark changed in committee: committee amendments · article by article.

SPK announcement · 1 October 2026

According to the SPK’s “Announcement on Voluntary Return Accounts” (İsteğe Bağlı İade Hesaplarına İlişkin Duyuru), “Voluntary Return Accounts” were opened in the name of the TMSF at Birleşik Fon Bankası, one for each fund, to meet the requests of “those who made excessive gains [fahiş kazanç] and wish of their own accord to return that gain to the fund concerned” from redemptions in the period before the liquidation decision. Amounts paid in “will be included only in the liquidation assets of the fund concerned and cannot be transferred to another fund or account”, and will be passed to Ziraat Bankası and İş Bankası, the banks charged with the liquidation, for use in payments to the fund’s unitholders. A separate “General Share Return Account” was opened for excessive profits from trading in listed shares (spk.gov.tr; the account numbers in the announcement are not for payments to investors and are not reproduced in this note). Primary source

The announcement predates the Law; it uses the term “excessive gains” as its benchmark and does not refer to the TÜFE and Yİ-ÜFE benchmark in the Law. Since the Law was adopted and entered into force, the SPK has not said, as at 5 November 2026, whether these accounts will be used as the “accounts announced by the Board” under art. 4(4); the SPK’s announcement of 1 October 2026 has not changed. To be confirmed

SPK 76/1903 · art. 11 · general share return account

Under the decision, in distributing “amounts transferred to the general share return account” to the funds under liquidation, priority goes first, in order to complete the interim payments, to the money market funds with the lowest coverage of interim payments and the largest number of investors whose net investment amount is below TRY 1 million; the distribution is made so as to “provide the interim payment of as many investors as possible”; any amount left in the account is distributed to the other funds on the same principles (SPK Bulletin 2026/76). The decision makes no express reference to art. 4(4) and announces no accounts. Primary source

Committee report · Report No. 294 · public bodies’ statement

“that the voluntary return mechanism in no way results in amnesty, release or impunity [af, ibra veya cezasızlık], that the Bill contains no provision on effective repentance, that the criminal and legal liability [cezai ve hukuki sorumluluk] under Law No. 6362 and the Turkish Criminal Code of those who make returns to the designated accounts continues, and that whether the provisions on effective repentance apply lies exclusively within the discretion of the judiciary, that the return was made voluntary rather than compulsory in view of concerns about unconstitutionality, …”
Planning and Budget Committee report, Report No. 294, p. 22 · statement by public bodies, not the text of the Law; unofficial translation

In the same report, opposition members argued that the mechanism is “unclear as to its conditions and the consequences of not making a return” and proposed compulsory collection (PDF). Primary source

Statements by the Minister of Justice, Akın Gürlek · as reported in the press

25 October 2026. Press report In a statement on his social media account concerning the fund investigations, the Minister of Justice, Akın Gürlek, said:

“Making a voluntary refund [gönüllü iade] does not, on its own, remove the legal liability [hukuki sorumluluk] of any natural or legal person. These refunds, which contribute to redressing the losses suffered, do not stand in the way of the conduct of the investigations or the assessment of the evidence. Our priority is that the refunded amounts reach the true rightholders [gerçek hak sahipleri]. In this context, the source, timing and amount of the refunds and the way in which they are passed on to the true rightholders will be examined meticulously; the allegations concerning the persons and transactions involved will also be assessed separately in law in the light of the evidence obtained.”
Reported by Hürriyet (DHA), 25.10.2026 18.50, and Anka, 25.10.2026 19.13; the original post could not be opened; unofficial translation

The wording of the statement includes “on its own” (tek başına) and “legal liability” (hukuki sorumluluk). It contains no payment timetable, no amounts and no reference to Law No. 7596, and it does not say whether “voluntary refund” refers to the SPK’s voluntary return accounts or to other refunds. Sources: hurriyet.com.tr · ankahaber.net; no text was found on the Ministry of Justice website.

6 October 2026. Answering a question on voluntary refunds at the Anadolu Agency’s Editors’ Desk, Minister Gürlek said: “An account has been opened at the Savings Deposit Insurance Fund [TMSF] for those who wish to return money voluntarily”, and added: “The perception that no action will be taken against those who have made good the loss is wrong” (Zararı giderenler hakkında bir işlem yapılmayacak algısı yanlış.). Press report (Reported by İstiklal, istiklal.com.tr; the AA’s own page could not be opened; unofficial translation.)

Not yet announced · as at 5 November 2026

Law No. 7596 entered into force on 27 October 2026; art. 4(4) is in force. The SPK, however, has not set the calculation period, the method for determining the amount to be returned or the other procedures and principles under art. 4(4), and has not announced the “accounts announced by the Board” under art. 4(4). Primary source
It has not been announced whether the accounts opened on 1 October 2026 will be used as the “accounts announced by the Board” under the Law, or whether amounts paid into them will go to the liquidator banks or to the recovery account at the TMSF. To be confirmed
No new statement on voluntary refunds by the SPK, the Treasury, the TMSF or the Directorate of Communications has been found since the announcement of 1 October 2026, nor any new statement by the Minister of Justice since 25 October 2026. Primary source
Whether funds whose liquidation was completed before the Law was published (27 October 2026) remain within this provision is unclear (open questions).

This section sets out the text of the Law and official statements with their sources; it does not assess, or give any guidance on, making or not making a voluntary refund. It does not name persons who are the subject of the investigations and gives no number of persons who have made refunds and no amounts.

08 · Framework

How does fund liquidation work? The regulatory framework

The liquidation framework set by the decisions of the Capital Markets Board of Türkiye (Sermaye Piyasası Kurulu, SPK), its stages, rule A/6 and the other provisions. Law No. 7596, in force since 27 October 2026, has added special statutory rules to this framework; the implementing rules are to be set by the SPK.

17.09.2026 · Bulletin 2026/6057/1706 · 57/1707
The SPK closed the funds founded by seven portfolio management companies to both subscriptions and redemptions on TEFAS (Turkey Electronic Fund Trading Platform) and ordered the liquidation of 130 funds.
17.09.2026 · Bulletin 2026/6157/1708
The list was updated to 131 funds by adding THF, and the liquidation rules were set out as A/1–A/9.
20.09.2026 · Bulletin 2026/6259/1710
The maximum liquidation period was extended from three to six months.
30.09.2026 · Bulletin 2026/6764/1775 · 64/1770
Procedures for an interim payment and for the order of liquidation were added to the general rules.
27.10.2026 · Official Gazette No. 33413Law No. 7596
Bill 2/3939 was adopted on 22.10.2026; the Law was published on 27.10.2026 and entered into force with effect from 17.09.2026 (see Law No. 7596).

Stages of the liquidation · as at 05.11.2026

1
Decision17.09.2026 · 57/1706–57/1708
The funds were closed to trading on TEFAS; the liquidation of 131 funds was ordered. Liquidator: Türkiye İş Bankası A.Ş. for the Tera Portföy funds, T.C. Ziraat Bankası A.Ş. for the funds of the other founders.
done
2
ReconciliationA/2 · A/3
The MKK–bank reconciliation (units, encumbrances, unexecuted orders) ended on 21.09.2026; the period for the inter-institutional reconciliation of the funds’ debts and receivables ended on 01.10.2026. Later requests are in the nature of a correction.
periods expired
3
Conversion into cashA/5 · 64/1770
The liquidator bank converts the fund assets into cash. In the A1 Capital, Bulls and Pardus funds: money market funds first, then from the most investors to the fewest.
ongoing
4
Interim payment64/1775 · 7596 art. 4
For reconciled unitholders in the Tera, Pusula and Atlas funds (since 15 October 2026 the Hedef funds follow the 64/1770 rules), up to TRY 1 million for each fund; money market funds first. Law No. 7596 entered into force on 27.10.2026; the same day the SPK set the procedures for the interim payment by decision 76/1903; paid by İş Bankası (Tera) and Ziraat Bankası (Pusula, Atlas). The decision gives no date; according to the Directorate of Communications, the first interim payments are expected to begin on 30.10.2026 (as reported in the press).
first payments expected 30 Oct
5
Final paymentA/5 · A/8
Cash is transferred to reconciled accounts pro rata to unitholdings (under Law No. 7596, net investment applies in funds where cash falls short); the interim payment is deducted and units are redeemed at this stage. Maximum period ≈ 17.03.2027. In the A1 Capital, Bulls and Pardus funds the liquidation was completed according to the Government’s statement of 18.10.2026; in the Hedef funds payments began on 20.10.2026 and, according to the Government, the liquidation of 18 of the 31 funds had been completed as at 21.10.2026 (as reported in the press).
pending

A/6: unexecuted redemption instructions

First sentence. Redemption instructions transmitted after 13.30 on 17 September 2026 in the case of notice-period funds, and after the end-of-day value-date cut-off stated in the prospectus in the case of money market funds, fall within the liquidation rules.

Second sentence (full text, with an unofficial translation):

“Tasfiye kararı verilen fonlardan, Takasbank TEFAS Platformu üzerinden fon satım emri verilen ve gerçekleştirilmeyen iade talimatları karşılığında oluşan tutar fon hesabına borç olarak tahakkuk ettirilir ve banka tarafından yukarıdaki (5) nolu maddede yer verilen yöntemlerle elde edilen nakit ile öncelikli olarak bu borçlar ödenir.”
SPK decision 57/1708, liquidation rules, A/6 (original Turkish)

“In funds for which a liquidation decision has been made, the amount corresponding to redemption instructions for which a fund sell order was placed through the Takasbank TEFAS Platform and which were not executed shall be accrued as a liability of the fund, and these liabilities shall be paid in priority out of the cash obtained by the bank by the methods set out in item (5) above.”
(unofficial translation)

The provision requires all three elements together:

(i)The fund is one for which a liquidation decision has been made (the SPK Bulletin 2026/61 list).
(ii)The sell order was placed through the Takasbank TEFAS Platform.
(iii)The order was not executed.

The SPK’s statement of 28 September 2026. According to the SPK, instructions transmitted to TEFAS on or before 16 September 2026 but not executed because the fund defaulted or did not publish a price fall within the liquidation for the purposes of A/6; instructions given on 17 September 2026, by contrast, were cancelled by TEFAS, and their holders will be paid out of the liquidation balance pro rata to their unitholdings (spk.gov.tr).

The committee report (Report No. 294). According to the statements of the public authorities set out in the Planning and Budget Committee’s report (Report No. 294), a share block (PBLK) entry does not mean that cash has reached the investor’s account; these instructions are treated as falling within the liquidation under the SPK announcement of 28 September 2026, merely having given a sale instruction does not end unitholding, and the rights of these investors will be protected within the liquidation “in their capacity as unitholders”. The report also records the view that these instructions could not have been met “even if no liquidation decision had been taken”; that is the view of the authorities, not a court ruling. How this statement relates to the priority payment under A/6 is not explained. The text of Bill No. 2/3939 adopted in committee contains no provision on A/6 either (PDF).

The General Assembly and Law No. 7596. On 21 October 2026 the General Assembly added the following sentence to paragraph 5 of Article 3 of the bill by amendment and adopted the article in that form: “Provided that, in respect of instructions concerning the funds subject to liquidation that were transmitted to TEFAS on or before 17/9/2026 but could not be executed because of the default of the fund concerned and/or the non-publication of its unit price, those whose units have been blocked shall be subject to the liquidation provisions of this Law in their capacity as fund unitholders.” (unofficial translation) The sentence appears in the same wording in the text of Law No. 7596 published in the Official Gazette (27 October 2026, No. 33413). According to the reasons given for the amendment, these instructions became “invalid” because they could not be executed, and the provision “does not affect transactions whose payment has been completed”. An amendment stating that these investors’ claims are protected by settlement finality (SPKn art. 79) and that they are to be paid “with priority and immediately in cash” from the first cash available in the liquidation account was rejected; the adopted text provides no separate creditor ranking or priority for these investors. In the General Assembly, opposition members argued that the sentence conflicts with the principle of settlement finality. In a press release of 22 October 2026 the SPK stated that the settlement-finality provision in SPKn art. 79 does not mean that it must apply to all instructions given through TEFAS “regardless of the stage the transaction has reached”, and that settlement is completed when the cash is credited to the investor’s account and the record of unitholding is removed. According to the SPK, persons with a share-block entry are among the 455,758 fund unitholders and “do not form an additional group”; their instructions will be assessed on the amounts obtained in the liquidation “on equal terms with the other unitholders” (spk.gov.tr). That is the view the SPK has stated; it is not a court ruling. Law No. 7596, adopted by the General Assembly on 22 October 2026, was published in Official Gazette No. 33413 of 27 October 2026 and entered into force the same day, with effect from 17 September 2026 (art. 8); the Official Gazette text is identical to the text adopted by the TBMM. (unrevised record of 21 October 2026; text of the Law).

Cases: Cancelled order (1) · Order left blocked (2) · Settlement date passed (4) · Sample A/6 application

Other provisions: A/1, A/2, A/3, A/5, A/8, A/9, 64/1775, 64/1770and the pricing rule (III-52.1 art. 14(5))

A/1
The liquidator bank is authorised to carry out the acts and transactions that the legislation assigns to the fund founder and that are necessary for the liquidation. Its liability as portfolio custodian is unaffected.
A/2
Within 2 business days after the rules enter into force, MKK and the banks carry out a reconciliation. The reconciliation covers participation units, encumbrances such as pledges, attachments and injunctions, and unexecuted orders. The period expired on 21 September 2026; requests made after that date are in the nature of a correction.
A/3
The reconciliation of the debts and receivables arising from all of the funds’ transactions (repos, deposits, borrowings and the like) is carried out between the previous custodian, the bank and Takasbank and is to be completed within 10 business days after the Board’s decision at the latest (1 October 2026). This period concerns the reconciliation between institutions; it is not a time limit for applications by investors.
A/5
Cash obtained from the sale of assets is transferred to the reconciled individual custody accounts pro rata to unitholdings.
A/8
Amended by decision 59/1710: the maximum liquidation period was extended from 3 to 6 months (≈ 17 March 2027). The other provisions remain in force unchanged.
64/1775
Interim payment (30 September 2026; Tera, Pusula and Atlas funds; the Hedef funds were removed from its scope by 70/1821 on 15 October 2026). An interim payment is made to all unitholders whose reconciliation has been completed, on account of the payment to which they will be entitled at the end of the liquidation. The reference amount is the net investment amount as at the payment date, to be calculated by MKK; the payment may not exceed that amount or TRY 1 million (separately for each fund, according to the SPK’s announcement of 1 October 2026). Payments begin with the money market funds; no units are redeemed in return for the interim payment, and units are redeemed on the final liquidation payment. On 7 October 2026 the Government made the interim payment conditional on the enactment of Bill No. 2/3939; the bill was adopted on 22 October 2026 as Law No. 7596. For the formula and limits in the Law, see the payment rule.
64/1770
Order of liquidation (30 September 2026; A1 Capital, Bulls and Pardus funds). The liquidation proceeds starting with the funds whose names include the words “para piyasası” (money market), and then from the fund with the most investors to the fund with the fewest. Funds of these founders that are outside the liquidation but were closed on 17 September 2026 may be reopened to trading once the liquidation has been completed, on a date and on terms to be set by the founder; the SPK’s announcement of 1 October 2026 states that these funds may also be reopened by the liquidator bank.
A/9
Where the liquidation rules are silent, art. 11(f) of the Guidelines on Investment Funds (i-SPK.52.4) and other Board regulations apply. No redemptions are executed outside TEFAS for the funds closed by decision 57/1707. Portfolio instructions given on or before 17 September 2026 and not yet settled are executed in the ordinary course.

Pricing rule. Under art. 14(5) of the Communiqué on Principles Regarding Investment Funds (III-52.1) and the fund prospectuses, the price applicable to a redemption instruction is the unit price determined at the first calculation following the instruction. Whether prices formed later in the liquidation may be applied to instructions given before the decision is open to dispute.

AbbreviationsSPK, TEFAS, Takasbank, MKK, KAP, KEP, BDDK, YTM, TSPB, TBMM, TMSF and the statutes cited

Abbreviations. SPK: Capital Markets Board of Türkiye (Sermaye Piyasası Kurulu) · TEFAS: Turkey Electronic Fund Trading Platform · Takasbank: İstanbul Takas ve Saklama Bankası A.Ş., which operates TEFAS · MKK: Central Registry Agency (Merkezi Kayıt Kuruluşu) · KAP: Public Disclosure Platform (Kamuyu Aydınlatma Platformu) · KEP: registered electronic mail (kayıtlı elektronik posta) · BDDK: Banking Regulation and Supervision Agency · YTM: Investor Compensation Centre · TSPB: Turkish Capital Markets Association · TBMM: Grand National Assembly of Türkiye (parliament) · TMSF: Savings Deposit Insurance Fund · GMY: deputy general manager’s office · SPKn: Capital Markets Law No. 6362 · TBK: Turkish Code of Obligations No. 6098 · TTK: Turkish Commercial Code No. 6102 · HMK: Code of Civil Procedure No. 6100 · İİK: Enforcement and Bankruptcy Law No. 2004 · İYUK: Administrative Procedure Law No. 2577 · TCK: Turkish Criminal Code No. 5237 · CMK: Code of Criminal Procedure No. 5271 · KVKK: Personal Data Protection Law No. 6698 · TKHK: Consumer Protection Law No. 6502. The “founder” of a fund is the portfolio management company that established it; the “distributor” is the bank or brokerage firm through which units are bought and sold.

Fund list. The full list of the 131 funds is annexed to SPK Bulletin 2026/61. This note carries the full list with TEFAS codes and payment status; in case of doubt, whether a fund is on the list should be checked against the official PDF. The bulletin gives no fund codes; the SPK’s announcement on voluntary return accounts of 1 October 2026 lists the 131 funds with their TEFAS codes (the account numbers in that list are not for payments to investors). Values for the funds on the list: fund value calculator.

09 · Avenues

Institutions and avenues of application

What each institution does and which request a unitholder may address to it. The order does not indicate priority or the likelihood of any outcome. KEP (registered electronic mail) addresses have been compiled from the institutions’ own websites and should be checked through the KEP address search before sending.

direct avenue of applicationconditional role / under Law No. 7596The cards and the table give the detail.

Who does what?

Records and payment
Liquidator bank

Carries out the acts necessary for the liquidation (A/1); converts the assets into cash and transfers it to the reconciled accounts (A/5). Tera Portföy funds: Türkiye İş Bankası A.Ş. · A1 Capital, Atlas, Bulls, Hedef, Pardus and Pusula funds: T.C. Ziraat Bankası A.Ş.

Request, timing and KEP

Request: A/6 application: recording of the priority claim, correction of the A/2 reconciliation, a reserve for the duration of the dispute, and information on the price and timetable.

Timing: Immediately; before any interim payment or distribution is made.

KEP: isbankasi@hs02.kep.tr · ziraatbank@hs01.kep.trThe address as published on the bank’s website is reported to contain an invisible character; it should be typed by hand rather than copied.

Sample text Row in the table
Records and payment
Distributor

The bank or brokerage firm through which the order was placed and where the units are held. These institutions credit the liquidation proceeds to investors’ accounts (Directorate of Communications, 8 October 2026). The activities of Alnus, Bulls and Pusula Yatırım Menkul Değerler AŞ have been temporarily suspended from 21 October 2026 (SPK Bulletin 2026/72); it has not been announced how payments will reach accounts held with those brokerage firms.

Request, timing and KEP

Request: Order number, time of transmission, TEFAS status, cancellation message and account statement; preservation of the records; A/6 notification; formal notice.

Timing: Immediately, allowing a reasonable period (e.g. 7 days).

KEP: depends on the institution — KEP addresses

Sample text Row in the table
Records
MKK

Keeps the unit records; the A/2 reconciliation is carried out between MKK and the banks (the period expired on 21 September 2026). Under 64/1775 and Law No. 7596, MKK calculates the net investment amount.

Request, timing and KEP

Request: Confirmation of whether the unexecuted order appears in the reconciliation record, an annotation of dispute where necessary, the registry and sub-account (PBLK, RHVN) records; matching by ISIN where fund names differ.

Timing: Immediately (a “correction” request, as the A/2 period has passed).

KEP: mkk@hs03.kep.tr

Sample text Row in the table
Records
Takasbank (TEFAS)

Operates the TEFAS Platform; the order, matching, cancellation and settlement records are held there. Under Law No. 7596, the unit-value cap on the interim payment uses the value calculated by Takasbank.

Request, timing and KEP

Request: The TEFAS order, matching, cancellation and settlement logs; the source and time of the cancellation instruction; preservation of the records; A/6 notification.

Timing: Immediately.

KEP: takasbank@hs01.kep.tr and takasbank.haberlesme@hs03.kep.trMessages are to be sent to both addresses together.

Sample text Row in the table
Records and payment
Fund founder

The portfolio management company that established the fund. Under Law No. 7596, the portfolio management company that is the founder and/or manager of the fund is primarily liable for the loss (art. 5). The SPK temporarily suspended the capital market activities of Tera Portföy and Pusula Portföy on 26 October 2026 (Bulletin 2026/75).

Request, timing and KEP

Request: Formal notice — its main function is evidential and to establish default (TBK art. 117).

Timing: Immediately.

Tera Portföy: teraportfoy@hs03.kep.tr · Hedef Portföy: hedefportfoyyonetimi@hs03.kep.tr

Row in the table Fund not on the list (Scenario 8)
Supervision
SPK

Sets and supervises the liquidation rules; under Law No. 7596, in force since 27 October 2026, it also sets the interim and final payments, the order of distribution, the funds in which the interim payment is made and the art. 3(6) determinations. It set the procedures and principles for the liquidation and payments by decision 76/1903 of 27 October 2026; the art. 3(6) determinations have not been made public. An SPK application is not a route to compensation; the SPK does not award damages.

Request, timing and KEP

Request: Complaint and application under art. 10 İYUK: determination of the scope of A/6, instructions to the liquidators, a reserve, an investigation; where appropriate, a request for a criminal referral under SPKn art. 115.

Timing: No reply within 60 days counts as an implied refusal; an administrative action may then be brought within 60 days.

KEP: spk@hs01.kep.trRouting note: Yatırım Fonları Dairesi Başkanlığı (Investment Funds Department)

Sample text Row in the table
Disputes
Courts

Administrative court / Council of State: action for annulment against 57/1708 (16 November 2026, preclusive). Commercial court: damages action after mandatory mediation, preservation of evidence; interim injunctions or attachments only against the assets of the founder, managers and other persons liable — not against fund assets (SPKn art. 53). Consumer arbitration committee / consumer court: where the investor counts as a consumer.
Administrative Damages Injunction Evidence Consumer
Disputes
Criminal route

For SPKn arts. 107 and 110, a criminal complaint by the SPK is a precondition; for offences under the TCK, a complaint to the Chief Public Prosecutor’s Office; joining any existing investigation as a complainant.

Request, timing and KEP

Timing: TCK art. 155(1) requires a complaint: 6 months from learning of the act and the offender (TCK art. 73).

Row in the table
Disputes
Arbitration panels and complaints

TSPB Customer Disputes Arbitration Panel · TBB Individual Customer Arbitration Panel (where the distribution channel is a bank) · BDDK (where a written application to the bank goes unanswered) · KVKK data subject request (access to transaction and communication records).

Request, timing and KEP

Timing: Each starts with a written application to the institution; the time limits are in the table.

TSPB TBB BDDK KVKK
Conditional role
TMSF and YTM

TMSF: under a BDDK decision, exercises certain shareholder rights in Destek, Hedef and Tera Yatırım Bankası; the voluntary return accounts were opened in the TMSF’s name. Under Law No. 7596, it holds the recovery account and collects from the persons the SPK holds liable under Law No. 6183. YTM: only where the SPK determines that an investment firm cannot deliver and a compensation decision is made; losses from the fund liquidation are outside its scope (SPKn art. 84(2)). Under the Law, it pays out the recovered amounts pro rata after the liquidation.

Request, timing and KEP

YTM KEP: ytm@hs01.kep.tr

YTM row FAQ

General notes

Separation of fund assets (art. 53 SPKn). A fund’s assets are separate from those of the portfolio management company and the custodian; in a liquidation, payment is made only to unitholders, in proportion to the amount realised. Unitholders’ protection rests on this separation; there is no public mechanism that makes good any shortfall.
No avenue guarantees an outcome. The amount distributed in the liquidation is limited to what the fund’s assets realise when converted into cash; losses caused by market price movements are not compensated; damages claims depend on proof of fault and causation; and even a favourable judgment leaves open whether it can actually be enforced.
Procedural errors can decide a case before the merits are reached. Skipping mandatory mediation where it is a precondition to suit, or suing directly in a dispute below the consumer arbitration committee threshold, leads to dismissal on procedural grounds.
Note on jurisdiction. For investors shown as “Nitelikli Yatırımcı” (qualified investor) in the MKK records, recourse to the consumer courts is open to question, and the commercial courts and mandatory mediation come into play instead. Whether an investor is a consumer has to be assessed on the facts of each case.

Table of avenues of application17 avenues · addressee, time limit / timing and legal basis

#	Avenue	Addressee	Time limit / timing	Legal basis
1	A/6 application to the liquidator bank: recording of the priority claim, correction of the A/2 reconciliation, a reserve for the duration of the dispute, and information on price and timetableSample: A/6 application to the liquidator bank	T.C. Ziraat Bankası A.Ş. (funds of founders other than Tera) / Türkiye İş Bankası A.Ş. (Tera funds)	At the outset, and before any interim payment or distribution is made. The inter-institutional reconciliation under A/3 was completed on 1 October 2026; no separate time limit is laid down for applications by investors.	57/1708 A/1, A/2, A/3, A/5, A/6; SPK announcement of 28.09.2026; 64/1775
2	Application to MKK: the reconciliation record, whether the unexecuted order is included, an annotation of dispute where necessary, and the registry and sub-account (PBLK, RHVN) recordsSample: Request to MKK for reconciliation and registry information	Merkezi Kayıt Kuruluşu A.Ş. — Piyasa Operasyonları GMY	At the outset (as a request for correction, the A/2 period having expired)	A/2
3	Application to Takasbank: TEFAS order / matching / cancellation / settlement logs, the source and time of the cancellation instruction, preservation of the records, A/6 notificationSample: Request to Takasbank for TEFAS records	İstanbul Takas ve Saklama Bankası A.Ş. — Piyasalar ve Operasyon GMY / Fon Platformları Ekibi (TEFAS)	At the outset	A/6; preservation of evidence
4	Complaint to the SPK and application under art. 10 İYUK: determination of the scope of A/6, instructions to the liquidators, a reserve, an investigation and, where appropriate, a request that the SPK file a criminal complaint under art. 115 SPKnSample: Complaint and application to the SPK under art. 10 İYUK	The SPK (the application is addressed to the Board as a legal entity; unit concerned: Yatırım Fonları Dairesi Başkanlığı)	At the outset. If the authority does not reply within 60 days, the application is treated as impliedly rejected; an administrative action may then be brought within 60 days.	SPKn arts. 96, 128; İYUK art. 10. Note: an application to the SPK is not a route to compensation. The SPK reviews compliance with the legislation and does not award damages. Under Law No. 7596 (in force since 27 October 2026): the SPK has power to decide interim and final payments, the order of distribution, a minimum interim payment, payment starting from the lowest net investment amount, and the determinations under art. 3(6); applications to the SPK may also concern those decisions. The SPK set the procedures and principles for implementing the Law by decision 76/1903 of 27 October 2026 (details).
5	Formal notice, document request and A/6 notification to the distributor (bank or brokerage firm): order number, time of transmission, TEFAS status, cancellation message, account statement; preservation of the recordsSample: Records request and A/6 notification to the bank or brokerage firm	The bank or brokerage firm through which the order was placed	At the outset, allowing a reasonable period (for example, 7 days)	III-37.1, III-39.1, TBK art. 506
6	Formal notice to the fund founder (its main function is to secure evidence and establish default)	Tera Portföy Yönetimi A.Ş. / Hedef Portföy Yönetimi A.Ş. / the founder concerned	At the outset	TBK art. 117
7	TSPB Customer Disputes Arbitration Committee	Türkiye Sermaye Piyasaları Birliği (Turkish Capital Markets Association)	First a written complaint to the institution → 30 days to await a reply → application to the Committee within 60 days. The Committee’s decision may be challenged before the SPK.	TSPB Müşteri Uyuşmazlıkları Hakem Heyeti Yönergesi (the Committee’s directive)
8	Interim injunction / precautionary attachment against the assets of the founder, its managers or other persons liable (not against the fund’s assets)	Asliye Ticaret Mahkemesi (Commercial Court of First Instance) (enforcement office)	Ancillary to a damages claim; security may be required	HMK art. 389 et seq., art. 392; İİK art. 257. SPKn art. 53: fund assets cannot be attached, made subject to an interim injunction or included in a bankruptcy estate. A request to hold the claimed amount back from distribution (a reserve) is therefore made in the first instance to the liquidator bank and the SPK. Under Law No. 7596: the recovery account held at the TMSF “cannot be attached even for public receivables” and may not be made subject to an interim injunction or precautionary attachment (art. 6(5)); the TMSF collects from the persons the SPK holds liable under Law No. 6183 on the Collection of Public Receivables (art. 5(4)). The Law does not address what happens where an investor’s precautionary attachment and TMSF collection target the same assets.
9	Court-ordered preservation of evidence	Asliye Ticaret / Sulh Hukuk Mahkemesi (Commercial Court of First Instance / Civil Court of Peace)	If the records are not provided	HMK art. 400
10	Administrative courts: action for annulment following rejection or implied rejection under art. 10 İYUK; action for annulment of 57/1708 with a request for a stay of execution; full remedy action	İdare Mahkemesi (Administrative Court) / Danıştay (Council of State) (jurisdiction to be confirmed)	For 57/1708, 60 days from publication → 16 November 2026 (preclusive). Calendar calculation: 27 November 2026 for the SPK announcement of 28.09.2026; 30 November 2026 for 64/1770 and 64/1775 (whether these can be challenged in court needs to be assessed separately). The provision of Law No. 7596 giving it effect from 17 September 2026 does not by itself change these calendar calculations; the Law does not address its effect on actions already brought or still to be brought. According to the statement of the public authorities in the committee report, all decisions and acts of the SPK are subject to review by the administrative courts; persons excluded from payment may bring an action and, if the decision is annulled, benefit from the payment (Report No. 294). The Law provides no separate objection procedure.	İYUK arts. 7, 10, 12–13
11	Mandatory mediation and action for damages (founder, distributor, responsible managers)	Mediation office → Asliye Ticaret Mahkemesi	Once the liquidation distributions are clear. Limitation depends on the basis of the claim: TBK art. 72 (tort: 2 years from knowledge, 10 years in any event; if the act is a criminal offence, the criminal limitation period), TBK arts. 146–147 (contractual claims), TTK art. 560 (managers’ liability: 2 years from knowledge, 5 years from the act). Under Law No. 7596: the Law does not bar such actions, but payments previously received “through other legal avenues” are deducted from the final liquidation payment (art. 4(5)).	TTK art. 5/A (mediation as a precondition to suit); TBK arts. 49, 112, 506; TTK art. 553; SPKn arts. 52, 56 (liability of the portfolio custodian)
12	Criminal route: request that the SPK file a criminal complaint (for SPKn arts. 107 and 110 a complaint by the SPK is a precondition); complaint to the Chief Public Prosecutor’s Office for offences under the TCK; where an investigation is already under way, participation in it as a complainant	SPK; Cumhuriyet Başsavcılığı (Chief Public Prosecutor’s Office)	In parallel with the SPK’s review. TCK art. 155(1) (simple breach of trust) is prosecuted only on complaint: 6 months from knowledge of the act and the offender (TCK art. 73). The aggravated forms (TCK art. 155(2), art. 158) are prosecuted ex officio.	SPKn art. 115 (investigation of offences defined in the SPKn requires a written application by the SPK to the public prosecutor, a procedural precondition; the SPK becomes an intervening party once the indictment is accepted); TCK; CMK art. 237 (intervention)
13	Yatırımcı Tazmin Merkezi (YTM, Investor Compensation Centre)	YTM	Only where the SPK determines that an investment firm (brokerage firm / bank) is unable to return cash or capital market instruments held in its custody and a compensation decision is made. A portfolio management company is not an “investment firm” within the YTM scheme, and losses arising from the liquidation of funds and from market price movements are outside its scope (SPKn art. 84(2)). Claim period: 1 year from the announcement of the compensation decision (art. 85). Maximum for 2026: TRY 2,065,145 per investor. Tera Yatırım Menkul Değerler AŞ (27 October 2026): By SPK Bulletin 2026/77 (27 October 2026) it was decided “to cancel all activity permits and the authorisation certificate” of Tera Yatırım Menkul Değerler AŞ (a brokerage firm), “to compensate its investors and to liquidate the Brokerage Firm gradually” (PDF). According to the YTM’s notice of 28 October 2026, from 27 October 2026 the duties and powers of the firm’s statutory bodies are performed by the YTM until the liquidation is concluded; the application form and the rules for compensation claims will be published separately on ytm.gov.tr; objections to the schedule of creditors prepared by the YTM may be made within thirty days of its announcement; compensation payments will be made within three months of the announcement of the schedule, a period that may be extended by up to three months with the Board’s approval in compelling cases (ytm.gov.tr). The YTM’s compensation covers claims arising from the failure to meet obligations to pay cash or deliver capital market instruments held or managed by the investment firm on the investor’s behalf. The decision concerns a brokerage firm; it does not concern the fund founder Tera Portföy Yönetimi AŞ. No statement has been made on fund units held at this firm or on liquidation payments to be made to such accounts. The activities of Alnus, Bulls and Pusula Yatırım Menkul Değerler AŞ have also been temporarily suspended from 21 October 2026; as at 5 November 2026 no compensation decision had been published for those firms (SPK Bulletins 2026/72–2026/77). Under Law No. 7596: the YTM’s new role is not compensation but paying out, after the liquidation is completed, the amounts in the recovery account “in proportion to unitholding” (art. 6(6)); the YTM compensation scheme is unchanged.	SPKn arts. 82–85
14	Complaint to the BDDK (deficient banking service, e.g. an undisclosed transfer to a pledge sub-account)	BDDK	If a written application to the bank goes unanswered	Banking Law No. 5411
15	TBB Individual Customer Arbitration Committee (where the distribution channel is a bank, for disputes concerning banking services)	Türkiye Bankalar Birliği (Banks Association of Türkiye)	First a written application to the bank (30 days to reply) → application to the Committee within 60 days	Banking Law No. 5411, art. 80
16	Consumer arbitration committee / consumer court (where the investor qualifies as a consumer)	Provincial or district consumer arbitration committee; consumer court	For 2026, disputes below TRY 186,000 must go to the arbitration committee; above that amount, mediation is a precondition to suit (TKHK art. 73/A)	Consumer Protection Law No. 6502 (TKHK), arts. 3, 68, 73
17	Data subject access request under the KVKK (access to transaction and communication records)	The institution as data controller → if no reply, the Kişisel Verileri Koruma Kurulu (Personal Data Protection Board)	The institution must reply within 30 days at the latest	Personal Data Protection Law No. 6698 (KVKK), arts. 11, 13, 14

KEP addresses and notes on institutionsdistributor banks and brokerage firms, central addressees, founders · KEP practice

Institution where the units are held (distributor)

Akbank T.A.Ş.

KEP: akbank@akbank.hs03.kep.tr
Records that may be requested from the distributor: Order number, number of units, and the time the instruction was received and transmitted to TEFAS (or the reason it was not transmitted)
Status received from TEFAS and any cancellation message, with times
The relevant account statement and transaction receipts
Preservation of the instruction, order and log records
Notification of the instruction by the distributor, in that capacity, to the liquidator bank, Takasbank and MKK under A/6
Legal basis: III-37.1, III-39.1, TBK art. 506; for access to records, KVKK art. 11. Sample: Records request and A/6 notification to the bank or brokerage firm.

Türk Ekonomi Bankası A.Ş.

KEP: turkekonomibankasi@hs03.kep.tr
Records that may be requested from the distributor: Order number, number of units, and the time the instruction was received and transmitted to TEFAS (or the reason it was not transmitted)
Status received from TEFAS and any cancellation message, with times
The relevant account statement and transaction receipts
Preservation of the instruction, order and log records
Notification of the instruction by the distributor, in that capacity, to the liquidator bank, Takasbank and MKK under A/6
Legal basis: III-37.1, III-39.1, TBK art. 506; for access to records, KVKK art. 11. Sample: Records request and A/6 notification to the bank or brokerage firm.

QNB Bank A.Ş.

KEP: qnb@hs05.kep.trThe former qnbfinansbank@… address should not be used.
Records that may be requested from the distributor: Order number, number of units, and the time the instruction was received and transmitted to TEFAS (or the reason it was not transmitted)
Status received from TEFAS and any cancellation message, with times
The relevant account statement and transaction receipts
Preservation of the instruction, order and log records
Notification of the instruction by the distributor, in that capacity, to the liquidator bank, Takasbank and MKK under A/6
Legal basis: III-37.1, III-39.1, TBK art. 506; for access to records, KVKK art. 11. Sample: Records request and A/6 notification to the bank or brokerage firm.

Fibabanka A.Ş.

KEP: fibabanka.resmikurumlar@hs03.kep.trAddress compiled from a secondary source (to be confirmed); it should be verified against the tax identification number (VKN) through the KEP address search.
Records that may be requested from the distributor: Order number, number of units, and the time the instruction was received and transmitted to TEFAS (or the reason it was not transmitted)
Status received from TEFAS and any cancellation message, with times
The relevant account statement and transaction receipts
Preservation of the instruction, order and log records
Notification of the instruction by the distributor, in that capacity, to the liquidator bank, Takasbank and MKK under A/6
Legal basis: III-37.1, III-39.1, TBK art. 506; for access to records, KVKK art. 11. Sample: Records request and A/6 notification to the bank or brokerage firm.

Türkiye İş Bankası A.Ş.

KEP: isbankasi@hs02.kep.trThe address as published on the bank’s website is reported to contain an invisible character; it should be typed by hand rather than copied.
Records that may be requested from the distributor: Order number, number of units, and the time the instruction was received and transmitted to TEFAS (or the reason it was not transmitted)
Status received from TEFAS and any cancellation message, with times
The relevant account statement and transaction receipts
Preservation of the instruction, order and log records
Notification of the instruction by the distributor, in that capacity, to the liquidator bank, Takasbank and MKK under A/6
Legal basis: III-37.1, III-39.1, TBK art. 506; for access to records, KVKK art. 11. Sample: Records request and A/6 notification to the bank or brokerage firm.
Note on this institution: Türkiye İş Bankası A.Ş. is also the portfolio custodian and liquidator of the Tera Portföy funds.

T.C. Ziraat Bankası A.Ş.

KEP: ziraatbank@hs01.kep.tr
Records that may be requested from the distributor: Order number, number of units, and the time the instruction was received and transmitted to TEFAS (or the reason it was not transmitted)
Status received from TEFAS and any cancellation message, with times
The relevant account statement and transaction receipts
Preservation of the instruction, order and log records
Notification of the instruction by the distributor, in that capacity, to the liquidator bank, Takasbank and MKK under A/6
Legal basis: III-37.1, III-39.1, TBK art. 506; for access to records, KVKK art. 11. Sample: Records request and A/6 notification to the bank or brokerage firm.
Note on this institution: T.C. Ziraat Bankası A.Ş. is also the portfolio custodian and liquidator of the A1 Capital, Atlas, Bulls, Hedef, Pardus and Pusula funds.

İnfo Yatırım Menkul Değerler A.Ş.

KEP: infoyatirim@hs01.kep.tr
Records that may be requested from the distributor: Order number, number of units, and the time the instruction was received and transmitted to TEFAS (or the reason it was not transmitted)
Status received from TEFAS and any cancellation message, with times
The relevant account statement and transaction receipts
Preservation of the instruction, order and log records
Notification of the instruction by the distributor, in that capacity, to the liquidator bank, Takasbank and MKK under A/6
Legal basis: III-37.1, III-39.1, TBK art. 506; for access to records, KVKK art. 11. Sample: Records request and A/6 notification to the bank or brokerage firm.
Note on this institution: The press reported that on 22 September 2026 the SPK made cash and asset outflows at certain brokerage firms, İnfo Yatırım among them, subject to its control. On 7 October 2026 the Vice President told parliament that, under an SPK decision, outflows of securities and cash from the accounts of 6 brokerage firms and 7 portfolio management companies were being handled under control; the SPK’s decision has not been published and the firms have not been officially named. According to the shareholding structure disclosed on KAP, a significant part of the company’s capital is held by Hedef Holding and Hedef funds; the distributor and Hedef Portföy belong to the same group.

Tera Yatırım Bankası A.Ş. (Terabank)

KEP: terayatirim.bankasi@hs01.kep.trThe address teramenkul@hs01.kep.tr belongs to a different company, Tera Yatırım Menkul Değerler A.Ş.
Records that may be requested from the distributor: Order number, number of units, and the time the instruction was received and transmitted to TEFAS (or the reason it was not transmitted)
Status received from TEFAS and any cancellation message, with times
The relevant account statement and transaction receipts
Preservation of the instruction, order and log records
Notification of the instruction by the distributor, in that capacity, to the liquidator bank, Takasbank and MKK under A/6
Legal basis: III-37.1, III-39.1, TBK art. 506; for access to records, KVKK art. 11. Sample: Records request and A/6 notification to the bank or brokerage firm.
Note on this institution: Tera Yatırım Bankası A.Ş. (Terabank; MKK member code TAE) belongs to the Tera group. The e-Yatırımcı records should be checked to see whether the units have been transferred to the pledge (RHVN) sub-account at MKK; if they have, the legal basis for the transfer should be requested in writing. If the written application goes unanswered, a complaint to the BDDK becomes available.

Other bank

KEP: The institution’s registered KEP address (to be confirmed through the KEP address search).
Records that may be requested from the distributor: Order number, number of units, and the time the instruction was received and transmitted to TEFAS (or the reason it was not transmitted)
Status received from TEFAS and any cancellation message, with times
The relevant account statement and transaction receipts
Preservation of the instruction, order and log records
Notification of the instruction by the distributor, in that capacity, to the liquidator bank, Takasbank and MKK under A/6
Legal basis: III-37.1, III-39.1, TBK art. 506; for access to records, KVKK art. 11. Sample: Records request and A/6 notification to the bank or brokerage firm.
Note on this institution: The institution’s registered KEP address should be confirmed through the KEP address search.

Other brokerage firm

KEP: The institution’s registered KEP address (to be confirmed through the KEP address search).
Records that may be requested from the distributor: Order number, number of units, and the time the instruction was received and transmitted to TEFAS (or the reason it was not transmitted)
Status received from TEFAS and any cancellation message, with times
The relevant account statement and transaction receipts
Preservation of the instruction, order and log records
Notification of the instruction by the distributor, in that capacity, to the liquidator bank, Takasbank and MKK under A/6
Legal basis: III-37.1, III-39.1, TBK art. 506; for access to records, KVKK art. 11. Sample: Records request and A/6 notification to the bank or brokerage firm.
Note on this institution: The institution’s registered KEP address should be confirmed through the KEP address search.

Central addressees, founders and other addresses

Merkezi Kayıt Kuruluşu A.Ş. (MKK) — Piyasa Operasyonları GMYmkk@hs03.kep.tr
İstanbul Takas ve Saklama Bankası A.Ş. (Takasbank) — Piyasalar ve Operasyon GMY / Fon Platformları Ekibi (TEFAS)takasbank@hs01.kep.tr and takasbank.haberlesme@hs03.kep.trMessages are to be sent to both addresses together.
Sermaye Piyasası Kurulu (SPK; the application is addressed to the Board as a legal entity; routing note: Yatırım Fonları Dairesi Başkanlığı)spk@hs01.kep.tr
Yatırımcı Tazmin Merkezi (YTM, Investor Compensation Centre)ytm@hs01.kep.tr
Tera Portföy Yönetimi A.Ş.teraportfoy@hs03.kep.tr
Hedef Portföy Yönetimi A.Ş.hedefportfoyyonetimi@hs03.kep.tr
TSPB Müşteri Uyuşmazlıkları Hakem Heyeti (Customer Disputes Arbitration Committee of the Turkish Capital Markets Association)No KEP address has been published; applications are made on the form provided or electronically.

Institutional notes

The SPK has no unit called the “Kurumsal Yatırımcılar Dairesi” (Institutional Investors Department); the unit responsible for funds is the Yatırım Fonları Dairesi Başkanlığı (Investment Funds Department). The application is addressed to the Board as a legal entity, with the department named in a routing note. The SPK is based in Ankara.
MKK has no unit called “fon operasyonları” (fund operations); custody services come under the Piyasa Operasyonları GMY (Market Operations).
At Takasbank, correspondence on TEFAS is addressed to the “Fon Platformları Ekibi” (Fund Platforms Team).
KEP practice: the message type “Kep” should be selected (not “E-Yazışma”); the subject line appears on the proof of delivery; after sending, the proof of delivery should be downloaded and kept.

10 · Fund list

Full list of the 131 funds in liquidation

All 131 funds in SPK Bulletin 2026/61: TEFAS code, fund name (in its official Turkish form), founder, the bank conducting the liquidation and payment status. Search by code or name; filter by founder. Codes and numbers of investors are from TEFAS, as at 05.11.2026.

Search funds 131 funds

No.	Code	Fund	Founder · liquidator	Investors	Status
1	BHN	A1 Capital Portföy Bankacılık Sektörü Dışı Şirketler Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateA1 Capital Portföy Paid · 16.10.2026	A1 Capital PortföyT.C. Ziraat Bankası	41	Paid · 16.10.2026
2	BYZ	A1 Capital Portföy BIST 100 Dışı Şirketler Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateA1 Capital Portföy Paid · 16.10.2026	A1 Capital PortföyT.C. Ziraat Bankası	40	Paid · 16.10.2026
3	CBD	A1 Capital Portföy BIST 30 Dışı Şirketler Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateA1 Capital Portföy Paid · 16.10.2026	A1 Capital PortföyT.C. Ziraat Bankası	17	Paid · 16.10.2026
4	CAH	A1 Capital Portföy Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateA1 Capital Portföy Paid · 08.10.2026	A1 Capital PortföyT.C. Ziraat Bankası	170	Paid · 08.10.2026
5	CHY	A1 Capital Portföy İkinci Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateA1 Capital Portföy Paid · 16.10.2026	A1 Capital PortföyT.C. Ziraat Bankası	41	Paid · 16.10.2026
6	AJ1	A1 Capital Portföy İstatistiksel Arbitraj Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateA1 Capital Portföy Paid · 08.10.2026	A1 Capital PortföyT.C. Ziraat Bankası	81	Paid · 08.10.2026
7	PAB	A1 Capital Portföy Para Piyasası (TL) Fonu CalculateA1 Capital Portföy Paid · 08.10.2026	A1 Capital PortföyT.C. Ziraat Bankası	720	Paid · 08.10.2026
8	P1A	A1 Capital Portföy Para Piyasası (TL) Serbest Fon CalculateA1 Capital Portföy Paid · 08.10.2026	A1 Capital PortföyT.C. Ziraat Bankası	342	Paid · 08.10.2026
9	SEH	A1 Capital Portföy Sanayi Sektörü Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateA1 Capital Portföy Paid · 16.10.2026	A1 Capital PortföyT.C. Ziraat Bankası	45	Paid · 16.10.2026
10	LGO	Atlas Portföy Algo Toros Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	11	Interim payment · SPK 76/1903
11	BSH	Atlas Portföy Bankacılık Sektörü Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	120	Interim payment · SPK 76/1903
12	AP5	Atlas Portföy Beşinci Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	14	Interim payment · SPK 76/1903
13	BAC	Atlas Portföy Birinci Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	12	Interim payment · SPK 76/1903
14	AP4	Atlas Portföy Dördüncü Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	11	Interim payment · SPK 76/1903
15	ABG	Atlas Portföy Dördüncü Serbest (TL) Fon CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	181	Interim payment · SPK 76/1903
16	LAI	Atlas Portföy İkinci Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	12	Interim payment · SPK 76/1903
17	KHD	Atlas Portföy İkinci Katılım Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	12	Interim payment · SPK 76/1903
18	BTJ	Atlas Portföy İstatistiksel Arbitraj Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	49	Interim payment · SPK 76/1903
19	KLH	Atlas Portföy Katılım Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	1,782	Interim payment · SPK 76/1903
20	PPT	Atlas Portföy Para Piyasası (TL) Fonu CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	3,818	Interim payment · SPK 76/1903
21	PSE	Atlas Portföy Para Piyasası Serbest Fon CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	4,834	Interim payment · SPK 76/1903
22	SNY	Atlas Portföy Sanayi Sektörü Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	370	Interim payment · SPK 76/1903
23	DFI	Atlas Portföy Serbest Fon CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	47,645	Interim payment · SPK 76/1903
24	GCD	Atlas Portföy Ufuk Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	19	Interim payment · SPK 76/1903
25	UHS	Atlas Portföy Üçüncü Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateAtlas Portföy Interim payment · SPK 76/1903	Atlas PortföyT.C. Ziraat Bankası	13	Interim payment · SPK 76/1903
26	BLA	Bulls Portföy Algoritmik Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateBulls Portföy Paid · 19.10.2026	Bulls PortföyT.C. Ziraat Bankası	15	Paid · 19.10.2026
27	BOS	Bulls Portföy Altıncı Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateBulls Portföy Paid · 08.10.2026	Bulls PortföyT.C. Ziraat Bankası	638	Paid · 08.10.2026
28	BBO	Bulls Portföy Bankacılık Sektörü Dışı Şirketler Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateBulls Portföy Completed · 18.10.2026	Bulls PortföyT.C. Ziraat Bankası	8	Completed · 18.10.2026
29	BP5	Bulls Portföy Beşinci Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateBulls Portföy Paid · 19.10.2026	Bulls PortföyT.C. Ziraat Bankası	11	Paid · 19.10.2026
30	BOH	Bulls Portföy BIST 30 Dışı Şirketler Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateBulls Portföy Paid · 19.10.2026	Bulls PortföyT.C. Ziraat Bankası	11	Paid · 19.10.2026
31	BI5	Bulls Portföy BIST 50 Dışı Şirketler Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateBulls Portföy Paid · 16.10.2026	Bulls PortföyT.C. Ziraat Bankası	10	Paid · 16.10.2026
32	BBN	Bulls Portföy Birinci Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateBulls Portföy Paid · 19.10.2026	Bulls PortföyT.C. Ziraat Bankası	12	Paid · 19.10.2026
33	BDO	Bulls Portföy Dördüncü Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateBulls Portföy Paid · 19.10.2026	Bulls PortföyT.C. Ziraat Bankası	11	Paid · 19.10.2026
34	IHY	Bulls Portföy GMS Hisse Senedi Serbest Özel Fon (Hisse Senedi Yoğun Fon) CalculateBulls Portföy Paid · 19.10.2026	Bulls PortföyT.C. Ziraat Bankası	1	Paid · 19.10.2026
35	BIK	Bulls Portföy İkinci Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateBulls Portföy Paid · 19.10.2026	Bulls PortföyT.C. Ziraat Bankası	14	Paid · 19.10.2026
36	BMU	Bulls Portföy Mutlak Getiri Hedefli Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateBulls Portföy Paid · 08.10.2026	Bulls PortföyT.C. Ziraat Bankası	1,901	Paid · 08.10.2026
37	BPZ	Bulls Portföy Para Piyasası (TL) Fonu CalculateBulls Portföy Paid · 08.10.2026	Bulls PortföyT.C. Ziraat Bankası	2,376	Paid · 08.10.2026
38	BSN	Bulls Portföy Sanayi Şirketleri Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateBulls Portföy Paid · 19.10.2026	Bulls PortföyT.C. Ziraat Bankası	17	Paid · 19.10.2026
39	BUC	Bulls Portföy Üçüncü Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateBulls Portföy Paid · 16.10.2026	Bulls PortföyT.C. Ziraat Bankası	22	Paid · 16.10.2026
40	YLZ	Bulls Portföy Yıldız Pazar Şirketleri Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateBulls Portföy Paid · 16.10.2026	Bulls PortföyT.C. Ziraat Bankası	10	Paid · 16.10.2026
41	HLR	Hedef Portföy Ada Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 21.10.2026	Hedef PortföyT.C. Ziraat Bankası	13	Paid · 21.10.2026
42	HEH	Hedef Portföy Algo Everest İstatistiksel Arbitraj Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 23.10.2026	Hedef PortföyT.C. Ziraat Bankası	1,316	Paid · 23.10.2026
43	HAT	Hedef Portföy Atlas İstatistiksel Arbitraj Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 21.10.2026	Hedef PortföyT.C. Ziraat Bankası	73	Paid · 21.10.2026
44	HKM	Hedef Portföy Başak Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 23.10.2026	Hedef PortföyT.C. Ziraat Bankası	809	Paid · 23.10.2026
45	HIM	Hedef Portföy Birinci İstatistiksel Arbitraj Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Ordinary liquidation · no date announced	Hedef PortföyT.C. Ziraat Bankası	186	Ordinary liquidation · no date announced
46	HPL	Hedef Portföy Çınar Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 26.10.2026	Hedef PortföyT.C. Ziraat Bankası	24	Paid · 26.10.2026
47	HDH	Hedef Portföy Doğu Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Ordinary liquidation · no date announced	Hedef PortföyT.C. Ziraat Bankası	16	Ordinary liquidation · no date announced
48	HBV	Hedef Portföy Doruk Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 22.10.2026	Hedef PortföyT.C. Ziraat Bankası	17	Paid · 22.10.2026
49	HDA	Hedef Portföy Dördüncü İstatistiksel Arbitraj Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 22.10.2026	Hedef PortföyT.C. Ziraat Bankası	480	Paid · 22.10.2026
50	HVA	Hedef Portföy Ece Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Ordinary liquidation · no date announced	Hedef PortföyT.C. Ziraat Bankası	16	Ordinary liquidation · no date announced
51	HMK	Hedef Portföy Ege Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 23.10.2026	Hedef PortföyT.C. Ziraat Bankası	37	Paid · 23.10.2026
52	HGH	Hedef Portföy Güneş Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 21.10.2026	Hedef PortföyT.C. Ziraat Bankası	19	Paid · 21.10.2026
53	HGJ	Hedef Portföy Güney Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Ordinary liquidation · no date announced	Hedef PortföyT.C. Ziraat Bankası	12	Ordinary liquidation · no date announced
54	HPI	Hedef Portföy İdeal Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 22.10.2026	Hedef PortföyT.C. Ziraat Bankası	14	Paid · 22.10.2026
55	HFI	Hedef Portföy İkinci Katılım Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 22.10.2026	Hedef PortföyT.C. Ziraat Bankası	125	Paid · 22.10.2026
56	—	Hedef Portföy İkinci Para Piyasası (TL) FonHedef Portföy Ordinary liquidation · no date announced	Hedef PortföyT.C. Ziraat Bankası	—	Ordinary liquidation · no date announced
57	—	Hedef Portföy İnci Hisse Senedi Serbest Özel Fon (Hisse Senedi Yoğun Fon)Hedef Portföy Ordinary liquidation · no date announced	Hedef PortföyT.C. Ziraat Bankası	—	Ordinary liquidation · no date announced
58	HKP	Hedef Portföy Katılım Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 22.10.2026	Hedef PortföyT.C. Ziraat Bankası	65	Paid · 22.10.2026
59	KSA	Hedef Portföy Kısa Vadeli Serbest (TL) Fon CalculateHedef Portföy Ordinary liquidation · no date announced	Hedef PortföyT.C. Ziraat Bankası	3,894	Ordinary liquidation · no date announced
60	HPF	Hedef Portföy Kuzey Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 22.10.2026	Hedef PortföyT.C. Ziraat Bankası	12	Paid · 22.10.2026
61	HMV	Hedef Portföy Mavi Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Ordinary liquidation · no date announced	Hedef PortföyT.C. Ziraat Bankası	13	Ordinary liquidation · no date announced
62	FNT	Hedef Portföy Model Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 22.10.2026	Hedef PortföyT.C. Ziraat Bankası	1,547	Paid · 22.10.2026
63	NFK	Hedef Portföy Nehir Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Ordinary liquidation · no date announced	Hedef PortföyT.C. Ziraat Bankası	60	Ordinary liquidation · no date announced
64	HYV	Hedef Portföy Para Piyasası (TL) Fonu CalculateHedef Portföy Paid · 21.10.2026	Hedef PortföyT.C. Ziraat Bankası	6,244	Paid · 21.10.2026
65	HPH	Hedef Portföy Para Piyasası Katılım Fonu CalculateHedef Portföy Ordinary liquidation · no date announced	Hedef PortföyT.C. Ziraat Bankası	6,593	Ordinary liquidation · no date announced
66	HKJ	Hedef Portföy Para Piyasası Serbest Fon CalculateHedef Portföy Ordinary liquidation · no date announced	Hedef PortföyT.C. Ziraat Bankası	1,813	Ordinary liquidation · no date announced
67	HVB	Hedef Portföy Pusula Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Ordinary liquidation · no date announced	Hedef PortföyT.C. Ziraat Bankası	13	Ordinary liquidation · no date announced
68	HVC	Hedef Portföy Rota Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 22.10.2026	Hedef PortföyT.C. Ziraat Bankası	16	Paid · 22.10.2026
69	DUH	Hedef Portföy Ufuk Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 22.10.2026	Hedef PortföyT.C. Ziraat Bankası	356	Paid · 22.10.2026
70	HDK	Hedef Portföy Vega İstatistiksel Arbitraj Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculateHedef Portföy Paid · 21.10.2026	Hedef PortföyT.C. Ziraat Bankası	120	Paid · 21.10.2026
71	HPZ	Hedef Portföy Zen Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun) CalculateHedef Portföy Paid · 22.10.2026	Hedef PortföyT.C. Ziraat Bankası	18	Paid · 22.10.2026
72	AP6	Pardus Portföy Altıncı Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 19.10.2026	Pardus PortföyT.C. Ziraat Bankası	45	Paid · 19.10.2026
73	PAO	Pardus Portföy Anadolu Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 08.10.2026	Pardus PortföyT.C. Ziraat Bankası	205	Paid · 08.10.2026
74	BST	Pardus Portföy Bankacılık Sektörü Dışı Şirketler Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 08.10.2026	Pardus PortföyT.C. Ziraat Bankası	525	Paid · 08.10.2026
75	PHY	Pardus Portföy Batı Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 16.10.2026	Pardus PortföyT.C. Ziraat Bankası	45	Paid · 16.10.2026
76	BRT	Pardus Portföy Bereket Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 08.10.2026	Pardus PortföyT.C. Ziraat Bankası	305	Paid · 08.10.2026
77	BHH	Pardus Portföy Beşinci Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 19.10.2026	Pardus PortföyT.C. Ziraat Bankası	71	Paid · 19.10.2026
78	PBY	Pardus Portföy BIST 100 Dışı Şirketler Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Completed · 18.10.2026	Pardus PortföyT.C. Ziraat Bankası	54	Completed · 18.10.2026
79	BSE	Pardus Portföy BIST 30 Dışı Şirketler Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 16.10.2026	Pardus PortföyT.C. Ziraat Bankası	65	Paid · 16.10.2026
80	BDI	Pardus Portföy BIST 50 Dışı Şirketler Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Completed · 18.10.2026	Pardus PortföyT.C. Ziraat Bankası	72	Completed · 18.10.2026
81	AC7	Pardus Portföy Birinci Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 19.10.2026	Pardus PortföyT.C. Ziraat Bankası	44	Paid · 19.10.2026
82	PCH	Pardus Portföy Capital Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 19.10.2026	Pardus PortföyT.C. Ziraat Bankası	56	Paid · 19.10.2026
83	PDH	Pardus Portföy Doğu Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 19.10.2026	Pardus PortföyT.C. Ziraat Bankası	78	Paid · 19.10.2026
84	DHI	Pardus Portföy Dokuzuncu Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 19.10.2026	Pardus PortföyT.C. Ziraat Bankası	46	Paid · 19.10.2026
85	DRH	Pardus Portföy Dördüncü Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 19.10.2026	Pardus PortföyT.C. Ziraat Bankası	70	Paid · 19.10.2026
86	PGE	Pardus Portföy Güney Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Completed · 18.10.2026	Pardus PortföyT.C. Ziraat Bankası	45	Completed · 18.10.2026
87	KHA	Pardus Portföy İkinci Hisse Senedi (TL) Fonu (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 08.10.2026	Pardus PortföyT.C. Ziraat Bankası	25,138	Paid · 08.10.2026
88	AC8	Pardus Portföy İkinci Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 16.10.2026	Pardus PortföyT.C. Ziraat Bankası	96	Paid · 16.10.2026
89	IAU	Pardus Portföy İkinci İstatistiksel Arbitraj Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 08.10.2026	Pardus PortföyT.C. Ziraat Bankası	188	Paid · 08.10.2026
90	AC5	Pardus Portföy İstatistiksel Arbitraj Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 08.10.2026	Pardus PortföyT.C. Ziraat Bankası	142	Paid · 08.10.2026
91	KRH	Pardus Portföy Kartal Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 16.10.2026	Pardus PortföyT.C. Ziraat Bankası	41	Paid · 16.10.2026
92	PKU	Pardus Portföy Kuzey Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 19.10.2026	Pardus PortföyT.C. Ziraat Bankası	45	Paid · 19.10.2026
93	PMH	Pardus Portföy Marmara Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Completed · 18.10.2026	Pardus PortföyT.C. Ziraat Bankası	43	Completed · 18.10.2026
94	PMP	Pardus Portföy Model Portföy Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 08.10.2026	Pardus PortföyT.C. Ziraat Bankası	347	Paid · 08.10.2026
95	MGE	Pardus Portföy Mutlak Getiri Hedefli Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 13.10.2026	Pardus PortföyT.C. Ziraat Bankası	67	Paid · 13.10.2026
96	POF	Pardus Portföy Onaltıncı Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 19.10.2026	Pardus PortföyT.C. Ziraat Bankası	45	Paid · 19.10.2026
97	POS	Pardus Portföy Onbeşinci Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 08.10.2026	Pardus PortföyT.C. Ziraat Bankası	305	Paid · 08.10.2026
98	POB	Pardus Portföy Onbirinci Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 19.10.2026	Pardus PortföyT.C. Ziraat Bankası	42	Paid · 19.10.2026
99	PO9	Pardus Portföy Ondokuzuncu Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 16.10.2026	Pardus PortföyT.C. Ziraat Bankası	126	Paid · 16.10.2026
100	PPO	Pardus Portföy Ondördüncü Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 19.10.2026	Pardus PortföyT.C. Ziraat Bankası	44	Paid · 19.10.2026
101	POI	Pardus Portföy Onikinci Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 16.10.2026	Pardus PortföyT.C. Ziraat Bankası	42	Paid · 16.10.2026
102	PO8	Pardus Portföy Onsekizinci Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 16.10.2026	Pardus PortföyT.C. Ziraat Bankası	45	Paid · 16.10.2026
103	OHI	Pardus Portföy Onuncu Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 19.10.2026	Pardus PortföyT.C. Ziraat Bankası	44	Paid · 19.10.2026
104	POU	Pardus Portföy Onüçüncü Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 19.10.2026	Pardus PortföyT.C. Ziraat Bankası	73	Paid · 19.10.2026
105	PO7	Pardus Portföy Onyedinci Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 16.10.2026	Pardus PortföyT.C. Ziraat Bankası	43	Paid · 16.10.2026
106	AC4	Pardus Portföy Para Piyasası (TL) Fon CalculatePardus Portföy Paid · 08.10.2026	Pardus PortföyT.C. Ziraat Bankası	4,106	Paid · 08.10.2026
107	PST	Pardus Portföy Sanayi Sektörü Dışı Şirketler Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 19.10.2026	Pardus PortföyT.C. Ziraat Bankası	48	Paid · 19.10.2026
108	PSR	Pardus Portföy Sanayi Şirketleri Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 16.10.2026	Pardus PortföyT.C. Ziraat Bankası	45	Paid · 16.10.2026
109	SHI	Pardus Portföy Sekizinci Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 16.10.2026	Pardus PortföyT.C. Ziraat Bankası	46	Paid · 16.10.2026
110	CSH	Pardus Portföy Üçüncü Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 19.10.2026	Pardus PortföyT.C. Ziraat Bankası	54	Paid · 19.10.2026
111	PYD	Pardus Portföy Yirmibirinci Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 16.10.2026	Pardus PortföyT.C. Ziraat Bankası	44	Paid · 16.10.2026
112	PYI	Pardus Portföy Yirmiikinci Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 16.10.2026	Pardus PortföyT.C. Ziraat Bankası	44	Paid · 16.10.2026
113	PYR	Pardus Portföy Yirminci Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePardus Portföy Paid · 08.10.2026	Pardus PortföyT.C. Ziraat Bankası	998	Paid · 08.10.2026
114	PHB	Pusula Portföy Beşinci Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePusula Portföy Interim payment · SPK 76/1903	Pusula PortföyT.C. Ziraat Bankası	15	Interim payment · SPK 76/1903
115	PBH	Pusula Portföy Birinci Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePusula Portföy Interim payment · SPK 76/1903	Pusula PortföyT.C. Ziraat Bankası	12	Interim payment · SPK 76/1903
116	PDG	Pusula Portföy Doğu Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePusula Portföy Interim payment · SPK 76/1903	Pusula PortföyT.C. Ziraat Bankası	11	Interim payment · SPK 76/1903
117	PDC	Pusula Portföy Dördüncü Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePusula Portföy Interim payment · SPK 76/1903	Pusula PortföyT.C. Ziraat Bankası	15	Interim payment · SPK 76/1903
118	PGH	Pusula Portföy Güney Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePusula Portföy Interim payment · SPK 76/1903	Pusula PortföyT.C. Ziraat Bankası	12	Interim payment · SPK 76/1903
119	PHN	Pusula Portföy İkinci Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePusula Portföy Interim payment · SPK 76/1903	Pusula PortföyT.C. Ziraat Bankası	18	Interim payment · SPK 76/1903
120	PKD	Pusula Portföy İkinci Katılım Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePusula Portföy Interim payment · SPK 76/1903	Pusula PortföyT.C. Ziraat Bankası	91	Interim payment · SPK 76/1903
121	PNU	Pusula Portföy İkinci Para Piyasası (TL) Fonu CalculatePusula Portföy Interim payment · SPK 76/1903	Pusula PortföyT.C. Ziraat Bankası	20,164	Interim payment · SPK 76/1903
122	PKZ	Pusula Portföy Kuzey Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculatePusula Portföy Interim payment · SPK 76/1903	Pusula PortföyT.C. Ziraat Bankası	17	Interim payment · SPK 76/1903
123	PRY	Pusula Portföy Para Piyasası (TL) Fonu CalculatePusula Portföy Interim payment · SPK 76/1903	Pusula PortföyT.C. Ziraat Bankası	38,751	Interim payment · SPK 76/1903
124	PKM	Pusula Portföy Para Piyasası Katılım (TL) Fonu CalculatePusula Portföy Interim payment · SPK 76/1903	Pusula PortföyT.C. Ziraat Bankası	348	Interim payment · SPK 76/1903
125	PCS	Pusula Portföy Üçüncü Hisse Senedi Serbest Fon (Hisse Senedi Yoğun Fon) CalculatePusula Portföy Interim payment · SPK 76/1903	Pusula PortföyT.C. Ziraat Bankası	28	Interim payment · SPK 76/1903
126	TLY	Tera Portföy Birinci Serbest Fon CalculateTera Portföy Interim payment · SPK 76/1903	Tera PortföyTürkiye İş Bankası	104,210	Interim payment · SPK 76/1903
127	DOH	Tera Portföy Dördüncü Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon) CalculateTera Portföy Interim payment · SPK 76/1903	Tera PortföyTürkiye İş Bankası	43,813	Interim payment · SPK 76/1903
128	THF	Tera Portföy Hisse Senedi (TL) Fonu (Hisse Senedi Yoğun Fon) CalculateTera Portföy Interim payment · SPK 76/1903	Tera PortföyTürkiye İş Bankası	214,402	Interim payment · SPK 76/1903
129	TP2	Tera Portföy Para Piyasası (TL) Fonu CalculateTera Portföy Interim payment · SPK 76/1903	Tera PortföyTürkiye İş Bankası	169,233	Interim payment · SPK 76/1903
130	TLV	Tera Portföy Para Piyasası Katılım (TL) Fonu CalculateTera Portföy Interim payment · SPK 76/1903	Tera PortföyTürkiye İş Bankası	12,177	Interim payment · SPK 76/1903
131	T3B	Tera Portföy Üçüncü Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun) CalculateTera Portföy Interim payment · SPK 76/1903	Tera PortföyTürkiye İş Bankası	16	Interim payment · SPK 76/1903

NoteWhat the “Paid” date rests on depends on the source. 08.10.2026: the day on which, according to the Directorate of Communications statement, the liquidation proceeds were transferred to banks and brokerage firms. 13.10, 16.10, 19.10, 21.10, 22.10, 23.10 and 26.10.2026: the first day on which the fund’s portfolio appears at a residual amount in the TEFAS record; as a TEFAS record is based on the valuation of the previous business day, this date is not the payment date. The 23 funds dated 19.10.2026 are Bulls and Pardus funds. In Pardus’s PGE fund the portfolio fell sharply in the 19 October 2026 record but still shows assets above a residual amount; the list shows it as “Completed” on the strength of the Government’s statement. Of the Hedef funds dated 21.10.2026, the company has stated that payments in HYV, HDK, HAT and HGH were made on 20.10.2026 (as reported in the press); for HLR, the fall of the portfolio to a residual amount is visible only on TEFAS, and the company’s statement does not mention this fund. For the 10 Hedef funds dated 22.10.2026 (HBV, HDA, HPI, HFI, HKP, HPF, FNT, HVC, DUH and HPZ) the 3 Hedef funds dated 23.10.2026 (HKM, HMK and HEH) and HPL, dated 26.10.2026, the date is the TEFAS record day on which the portfolio appears at a residual amount (HPL: unit price from 0.216490 to 0.009398, portfolio from ≈ TRY 63.2 million to TRY 2.74 million); no company statement on these funds has been found. All values of HEH were 0 in the complete record of 22.10.2026; as it reappears in the record of 23.10.2026 at a residual price of TRY 0.000149 (21.10.2026: TRY 3.348108), it is marked “Paid” with that record day; the payment has not been confirmed by the company or the SPK. Hedef’s funds marked “Paid” thus number 19 of 31. Liquidation work “largely” completed in 27 according to the 8th Fund Coordination Board (as at 23 October 2026), 19 in the list (TEFAS, record of 05.11.2026). The 7th Fund Coordination Board had given 18 as at 21 October 2026. According to the 7th Fund Coordination Board (22 October 2026, as reported in the press), the liquidation of 18 of Hedef’s 31 funds had been completed as at 21 October 2026; the Government has not said which 18 funds those are and has not given a new count since. The “Paid” marks in the list rest only on what TEFAS shows and relate to a later record date; as the two counts do not share a basis or a date they cannot be compared, and it has not been confirmed that the funds in the list are the ones the Government meant. In KSA, HPH and HKJ the unit price fell by 55–73% in the record of 26.10.2026 while the numbers of investors and units in circulation did not change; part of the portfolio appears to have been distributed, but as assets above a residual amount remain (≈ TRY 3.45 billion, 1.11 billion and 3.27 billion) and no payment has been announced, these funds are not marked “Paid”. The cause of the ≈ −18.9% fall in HDH in the record of 26.10.2026 is unclear. In HIM and NFK the unit price fell sharply on 23.10.2026, but their portfolios (≈ TRY 28.6 million and 46.2 million) remain above a residual amount and show no movement in the record of 26.10.2026; in HMV and HVB the portfolio fell significantly on 22.10.2026 while assets above a residual amount were still shown; HVB shows no movement in the record of 26.10.2026, and in HMV all values are 0. The two Hedef funds without a code cannot be followed on TEFAS. None of these is marked “Paid”. Funds shown at a price of 0 have not been treated as paid; in HPF all values are 0 in the record of 23.10.2026, and the fund is marked “Paid” because of its sharp fall on 22.10.2026. The TEFAS records of 22 and 23 October 2026 were incomplete when first retrieved; the list uses the completed records. The record of 27 October 2026 was incomplete when first retrieved (630 funds at a price of 0); the list and the calculation data have been updated with the completed records up to the record of 28 October 2026; no new fund is marked “Paid” in the records of 27 and 28 October 2026. HPH’s unit price fell by a further ≈ 8.5% in the record of 27 October 2026, and the fall in HDH continued in the records of 27 and 28 October 2026; the causes are unclear, and these funds are not marked “Paid”. “Completed” marks the A1 Capital, Bulls and Pardus funds whose liquidation the Government’s statement of 18 October 2026 reported as completed (press report). TEFAS data run to the record of 05.11.2026; official statements to the evening of 5 November 2026. The two funds without a code are private funds not traded on TEFAS. The “Calculate” link in each row opens the fund in the fund value calculator.

11 · Funds

Fund cards: TP2, THF, TLY, DOH, HKJ, KSA and others

Data compiled from public TEFAS, KAP and SPK sources. Price changes are calculated from TEFAS prices; the bar shows the value remaining relative to the first price. Fund names are given in their official Turkish form. Value by number of units: fund value calculator.

THFIn liquidation · İş Bankası

Tera Portföy Hisse Senedi (TL) Fonu (Hisse Senedi Yoğun Fon)

TEFAS price 15.09 → 24.09≈ −73.8%

Investors214,402ISINTRYTRPY00140

Details and applications

Full name: Tera Portföy Hisse Senedi (TL) Fonu (Hisse Senedi Yoğun Fon)
ISIN: TRYTRPY00140
SPK 2026/61 list number: 128 (not on the 2026/60 list; the only fund added by 2026/61)
Founder: Tera Portföy Yönetimi A.Ş.
Liquidator: Türkiye İş Bankası A.Ş. — KEP isbankasi@hs02.kep.tr
Settlement / cut-off: Redemptions settle at T+2. The instruction cut-off time should be confirmed from the prospectus.
TEFAS price: 15.09.2026: 2.933679 → 24.09.2026: 0.768118 (≈ −73.8%); since 25.09.2026 the price has been shown as 0 on TEFAS.
Number of investors: 214,402 (TEFAS, 21.10.2026)
TEFAS: TEFAS fund analysis: THF
Specific notes: The press reported Tera Portföy’s announcement on the evening of 16 September 2026 that redemption payments in THF and TP2 had gone into default.
As this fund settles at T+2, Scenario 4 (pricing by reference to the order date) is relevant to orders whose payment date fell before the Board’s decision; the SPK’s announcement of 28 September 2026 treats instructions transmitted on or before 16 September 2026 and not executed because of the fund’s default as falling within the liquidation for the purposes of A/6.
As a Tera Portföy fund, it is covered by the interim payment under SPK decision 76/1903 (27 October 2026); payment is made by Türkiye İş Bankası AŞ, and interim payments begin with funds whose names include the words “para piyasası”. Under Law No. 7596 (art. 4(2)), the interim payment in this fund, which is not a money market fund, may not exceed the value of the units in the account at the end of the previous day, at a price calculated by Takasbank; under the decision, among funds other than money market funds, payment begins with the fund with the highest ratio of distributable cash to total interim payment obligations (art. 7).
Applications relevant to this fund: For orders placed through TEFAS on or before 16 September 2026 and not executed: an A/6 application to Türkiye İş Bankası A.Ş. (sample), applications to MKK (sample) and Takasbank (sample), a records request to the distributor (sample) and an application to the SPK (sample). Where no instruction was given: pro rata distribution and confirmation of the MKK record (Scenario 10).

TP2In liquidation · İş Bankası

Tera Portföy Para Piyasası (TL) Fonu

Last price 16.09.2026: 2.243343; no price calculated since 17.09.2026

Investors169,233ISINTRYTRPY00132

Details and applications

Full name: Tera Portföy Para Piyasası (TL) Fonu
ISIN: TRYTRPY00132
SPK 2026/61 list number: 129
Founder: Tera Portföy Yönetimi A.Ş.
Liquidator: Türkiye İş Bankası A.Ş. — KEP isbankasi@hs02.kep.tr
Settlement / cut-off: Redemptions settle at T+0. As this is a money market fund, the threshold under the first sentence of A/6 is the end-of-day value-date cut-off stated in the prospectus.
TEFAS price: 16.09.2026: 2.243343; no price has been calculated since 17.09.2026.
Number of investors: 169,233 (TEFAS, 21.10.2026)
TEFAS: TEFAS fund analysis: TP2
Specific notes: A default in redemption payments was announced on the evening of 16 September 2026 (as reported in the press).
As its name includes the words “para piyasası”, under SPK decision 76/1903 it belongs to the group of funds with which the interim payments begin (art. 4); payment is made by Türkiye İş Bankası AŞ. Under the decision, if distributable cash is insufficient, the interim payment in this fund may not exceed the lowest of the net investment amount, “the amount calculated as at the end of the day before 17.09.2026” and TRY 1 million (art. 6). The decision gives no fund codes.
Orders placed on the evening of 16 September 2026 after the cut-off time may be treated as rolled over to the next value date (Scenario 2).
Applications relevant to this fund: An A/6 application to Türkiye İş Bankası A.Ş. (sample), and applications to MKK (sample), Takasbank (sample), the distributor (sample) and the SPK (sample).

TLYList position to be confirmed

Tera Portföy Birinci Serbest Fon

No price published on TEFAS since 17.09.2026

Investors104,210

Details and applications

Full name: Tera Portföy Birinci Serbest Fon
ISIN: Not given in this note; to be confirmed on TEFAS.
SPK 2026/61 list number: To be confirmed from SPK Bulletin 2026/61.
Founder: Tera Portföy Yönetimi A.Ş.
Liquidator: If the fund is on the list, for Tera Portföy funds: Türkiye İş Bankası A.Ş. — KEP isbankasi@hs02.kep.tr
TEFAS price: No price has been published on TEFAS since 17.09.2026.
Number of investors: 104,210 (TEFAS, 21.10.2026)
TEFAS: TEFAS fund analysis: TLY
Specific notes: This note does not give the fund’s list number or settlement terms; they should be confirmed from SPK Bulletin 2026/61 and the fund prospectus.
As this is a hedge (serbest) fund, under Law No. 7596 (art. 4(2)) the interim payment may not exceed the value of the units in the account at the end of the previous day (money market funds are exempt from that cap). As a Tera Portföy fund it is covered by the interim payment under SPK decision 76/1903; payment is made by Türkiye İş Bankası AŞ.
Applications relevant to this fund: If the fund is confirmed to be on the list, the avenues for Tera Portföy funds apply: an A/6 application to Türkiye İş Bankası A.Ş. (sample), and applications to MKK (sample), Takasbank (sample), the distributor (sample) and the SPK (sample).

DOHIn liquidation · İş Bankası

Tera Portföy Dördüncü Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon)

TEFAS price 15.09 → 24.09≈ −84.8%

Investors43,813ISINTRYTRPY00165

Details and applications

Full name: Tera Portföy Dördüncü Hisse Senedi Serbest (TL) Fon (Hisse Senedi Yoğun Fon)
ISIN: TRYTRPY00165
SPK 2026/61 list number: 127
Founder: Tera Portföy Yönetimi A.Ş.
Liquidator: Türkiye İş Bankası A.Ş. — KEP isbankasi@hs02.kep.tr
Settlement / cut-off: Settles at T+2. The instruction cut-off time should be confirmed from the prospectus.
TEFAS price: 15.09.2026: 2.579237 → 24.09.2026: 0.392329 (≈ −84.8%); since 25.09.2026 the price has been shown as 0 on TEFAS.
Number of investors: 43,813 (TEFAS, 21.10.2026)
TEFAS: TEFAS fund analysis: DOH
Specific notes: The press reported that on 16 September 2026 the fund was switched to monthly pricing and payment on the 10th business day; on TEFAS, however, daily prices continued to be published until 24 September 2026. If the prospectus amendment was announced after the order, it can be argued that it cannot apply retrospectively (Scenario 4).
Under Law No. 7596 (art. 4(2)), the interim payment in this fund, which is not a money market fund, may not exceed the value of the units in the account at the end of the previous day, at a price calculated by Takasbank. As a Tera Portföy fund it is covered by the interim payment under SPK decision 76/1903; payment is made by Türkiye İş Bankası AŞ.
Applications relevant to this fund: An A/6 application to Türkiye İş Bankası A.Ş., including a claim for pricing by reference to the order date (sample), and applications to the distributor (sample), Takasbank (sample), MKK (sample) and the SPK (sample).

HKJOrdinary liquidation · Ziraat

Hedef Portföy Para Piyasası Serbest Fon

TEFAS price 15.09 → 28.10≈ −54.5%

Investors1,813ISINTRYHDFP00789

Details and applications

Full name: Hedef Portföy Para Piyasası Serbest Fon
ISIN: TRYHDFP00789
SPK 2026/61 list number: 66
Founder: Hedef Portföy Yönetimi A.Ş.
Liquidator: T.C. Ziraat Bankası A.Ş. — KEP ziraatbank@hs01.kep.tr
Settlement / cut-off: Cut-off 13.30; redemptions settle at T+0.
TEFAS price: 15.09.2026: 1.445887 → 23.10.2026: 1.467764 → 26.10.2026: 0.658279 → 28.10.2026: 0.658439 (≈ −54.5% against 15.09; ≈ −55.1% against 23.10); daily prices continue to be published; no significant movement since 26.10.2026.
Number of investors: 1,813 (TEFAS, 28.10.2026; unchanged from 23.10.2026)
TEFAS: TEFAS fund analysis: HKJ
Specific notes: The fund is reported still to appear on MKK and some bank screens under its former name, “Hedef Portföy Katılım Serbest (TL) Fon”. Applications to MKK and to the liquidator should ask for matching by ISIN.
According to Hedef Portföy’s KAP statement of 21 September 2026 (as reported in the press), cash had been made available for the sell orders placed up to the moment of suspension, but the TEFAS orders were cancelled. Takasbank stated that the cancellation did not originate with it or with the TEFAS system, while the SPK stated on 28 September 2026 that all instructions given on 17 September 2026 had been cancelled by TEFAS pursuant to decision 57/1707.
By decision 70/1821 of 15 October 2026 the SPK removed the Hedef funds from the scope of the interim payment decision (64/1775) and made their liquidation subject to the rules of 64/1770. As a money market fund, this fund belongs to the priority group in the ordinary liquidation; the TRY 1 million interim payment cap no longer applies to it. Payments in the Hedef funds began on 20 October 2026; according to the company, the first money market fund paid out was HYV (as reported in the press). In the TEFAS record of 22 October 2026 the portfolios of 10 more Hedef funds fell to residual amounts; HKJ is not one of them. According to the 7th Fund Coordination Board, the liquidation of 18 of the 31 Hedef funds had been completed as at 21 October 2026; according to the 8th Fund Coordination Board (28 October 2026), the liquidation work in 27 of the 31 funds had been “largely” completed as at 23 October 2026 and work on the remaining 4 continues (as reported in the press); which funds are meant has not been disclosed. In the complete TEFAS record of 23 October 2026 a distribution is visible in three more Hedef funds (HKM, HMK and HEH); no distribution was visible for HKJ in the complete records of 22 and 23 October 2026. In the complete TEFAS record of 26 October 2026 HKJ’s unit price fell from 1.467764 to 0.658279 (≈ −55.2%) and its portfolio from about TRY 7.29 billion to TRY 3.27 billion, while the numbers of investors and units in circulation did not change. Part of the portfolio appears to have been distributed; no payment statement by the company, the liquidator bank or the SPK has been found. The fall in the portfolio does not show the amount paid. The TEFAS records of 27 and 28 October 2026 show no significant movement in HKJ (28.10.2026: 0.658439). The fund is not marked “Paid” in the list.
Applications relevant to this fund: An A/6 application to T.C. Ziraat Bankası A.Ş. (sample), an application to MKK including a request for matching by ISIN (sample), a records request to Takasbank (sample), and applications to the distributor (sample) and the SPK (sample). KAP fund page: kap.org.tr.

KSAOrdinary liquidation · Ziraat

Hedef Portföy Kısa Vadeli Serbest (TL) Fon

TEFAS price 15.09 → 28.10≈ −72.4%

Investors3,894ISINTRYHDFP00565

Details and applications

Full name: Hedef Portföy Kısa Vadeli Serbest (TL) Fon
ISIN: TRYHDFP00565
SPK 2026/61 list number: 59
Founder: Hedef Portföy Yönetimi A.Ş.
Liquidator: T.C. Ziraat Bankası A.Ş. — KEP ziraatbank@hs01.kep.tr
Settlement / cut-off: Cut-off 13.30; redemptions settle at T+0.
TEFAS price: 15.09.2026: 4.231374 → 23.10.2026: 4.315480 → 26.10.2026: 1.165359 → 28.10.2026: 1.166245 (≈ −72.4% against 15.09; ≈ −73.0% against 23.10); daily prices continue to be published; no significant movement since 26.10.2026.
Number of investors: 3,894 (TEFAS, 28.10.2026; unchanged from 23.10.2026)
TEFAS: TEFAS fund analysis: KSA
Specific notes: In the SPK lists the fund appears as “Hedef Portföy Kısa Vadeli Serbest Fon”, without “(TL)”; matching should be done by ISIN.
The statements of Hedef Portföy, Takasbank and the SPK on the cancellation of orders (see HKJ) make Takasbank’s records decisive for this fund as well.
Since 15 October 2026 the Hedef funds have been outside the scope of the interim payment (70/1821). As the fund’s name does not include the words “para piyasası” (money market), it has not been stated whether, in the order of liquidation under the 64/1770 rules, it will be dealt with alongside the money market funds or according to its number of investors. No distribution was visible in the complete TEFAS records of 22 and 23 October 2026. In the complete TEFAS record of 26 October 2026 the unit price fell from 4.315480 to 1.165359 (≈ −73.0%) and the portfolio from about TRY 12.76 billion to TRY 3.45 billion, while the numbers of investors and units in circulation did not change. Part of the portfolio appears to have been distributed; no payment statement by the company, the liquidator bank or the SPK has been found. The fall in the portfolio does not show the amount paid. The TEFAS records of 27 and 28 October 2026 show no significant movement in KSA (28.10.2026: 1.166245). The fund is not marked “Paid” in the list.
Applications relevant to this fund: An A/6 application to T.C. Ziraat Bankası A.Ş. (sample), and applications to MKK (sample), Takasbank (sample), the distributor (sample) and the SPK (sample).

TMVNot on the liquidation list

Tera Portföy Algoritmik Stratejiler Serbest Fon

TEFAS price 15.09 → 21.09≈ −51.3%

Investors10,080ISINTRYTRPY00058

Details and applications

Full name: Tera Portföy Algoritmik Stratejiler Serbest Fon
ISIN: TRYTRPY00058
SPK 2026/61 list number: Not on the list.
Founder: Tera Portföy Yönetimi A.Ş.
Liquidator: None under 57/1708. SPK Bulletin 2026/75 (26.10.2026) appointed Türkiye İş Bankası AŞ to liquidate the Tera Portföy funds other than those covered by the decisions of 17.09.2026; the bulletin names no funds or codes.
TEFAS price: 15.09.2026: 11.275491 → 21.09.2026: 5.490184 (≈ −51.3%)
Specific notes: The fund is not traded on TEFAS; no price has been published since 22.09.2026 (10,080 investors, TEFAS). A default in redemption payments on 21–22 September 2026 has been reported by more than one publication (as reported in the press).
The fund falls outside the liquidation rules of decision 57/1708 (Scenario 8). By Bulletin 2026/75 of 26 October 2026 the SPK temporarily suspended the capital market activities of Tera Portföy Yönetimi AŞ and Pusula Portföy Yönetimi AŞ under SPKn art. 97(1), and appointed Türkiye İş Bankası AŞ (for Tera) and T.C. Ziraat Bankası AŞ (for Pusula) to liquidate the investment funds, real estate investment funds and venture capital investment funds founded by these companies other than those whose liquidation was ordered by the decisions of 17 September 2026 (SPK Bulletin 2026/75). The bulletin names no funds or fund codes. These funds are outside the scope of Law No. 7596, which covers only the funds whose liquidation was ordered by the decisions of 17 September 2026 (art. 1). Whether TMV falls under that decision has not been officially stated. As at 5 November 2026 no price is published for the fund on TEFAS.
Applications relevant to this fund: A request to the SPK to lay down a procedure under art. 96 SPKn (sample), a records request to the distributor (sample) and a formal notice to the fund founder (TBK art. 117): Tera Portföy Yönetimi A.Ş., KEP teraportfoy@hs03.kep.tr.

BSMOutside the 17.09 decisions

Global MD Portföy Berrak Serbest Fon

Still traded on TEFAS

ISINTRYGMDP00191

Details and applications

Full name: Global MD Portföy Berrak Serbest Fon
ISIN: TRYGMDP00191
SPK 2026/61 list number: Outside the scope.
Founder: Global MD Portföy
Liquidator: None: the fund is not covered by the decisions of 17 September 2026.
TEFAS price: 23.10.2026: 1.903581; the fund continues to trade on TEFAS.
TEFAS: TEFAS fund analysis: BSM
Specific notes: The fund is not covered by the SPK’s decisions of 17 September 2026 (Scenario 9).
An earlier version of this note gave the fund code as GMD in error; GMD is the code of Global MD Portföy Birinci Fon Sepeti Fonu.
Applications relevant to this fund: A written enquiry may be made to the distributing bank about what has become of orders placed in this fund (sample).

Other fundsIn liquidation · list of 131

Other funds on the list (Pusula, Atlas, A1 Capital, Pardus, Bulls, Hedef and other Tera funds)

Pusula, Atlas, A1 Capital, Pardus, Bulls, Hedef and the other Tera funds · the 17 funds paid on 08.10.2026 · additional procedures (64/1775, 64/1770)

Details and applications

List: Annex to SPK Bulletin 2026/61 (official PDF). The bulletin gives no fund codes; the SPK’s announcement on voluntary return accounts of 1 October 2026 lists the 131 funds with their TEFAS codes.
Additional procedures: Tera, Pusula and Atlas funds: interim payment (64/1775, 30.09.2026; Law No. 7596 art. 4(2); SPK 76/1903, 27.10.2026). Under 76/1903, interim payments begin with funds whose names include the words “para piyasası”; in the other funds, payment begins with the fund with the highest ratio of distributable cash to total interim payment obligations; payment is made by T.C. Ziraat Bankası AŞ in the Pusula and Atlas funds and by Türkiye İş Bankası AŞ in the Tera funds (details). A1 Capital, Bulls and Pardus funds (64/1770, 30.09.2026) and, from 15 October 2026, the Hedef funds (70/1821): the liquidation proceeds starting with the money market funds and then from the fund with the most investors to the fund with the fewest.
Completed liquidations: According to the Government’s statement of 18 October 2026 (as reported in the press), the liquidation of the 66 funds of A1 Capital, Bulls and Pardus has been completed; the number of funds in liquidation fell to 65. According to the 8th Fund Coordination Board (28 October 2026, as reported in the press), the number of funds in liquidation has fallen from 131 to 38, and since the start liquidation payments in kind and in cash totalling TRY 68 billion have been made to 71,899 accounts. In the TEFAS record of 19 October 2026 the portfolios of 8 more Bulls funds and 16 more Pardus funds fell to residual amounts. Status fund by fund: full list.
Hedef Portföy payments: According to the company’s statement of 20 October 2026 (as reported in the press), payments were made in the HYV, HDK, HAT and HGH funds; they are made on the basis of the current portfolio values arising in the liquidation, not at the prices of 16 September 2026. The TEFAS record of 21 October 2026 shows the portfolios of these funds falling to residual amounts. In the TEFAS record of 22 October 2026 the portfolios of the HBV, HDA, HPI, HFI, HKP, HPF, FNT, HVC, DUH and HPZ funds also fell to residual amounts, and in the record of 23 October 2026 those of the HKM, HMK and HEH funds; no company statement on these funds has been found. According to the 7th Fund Coordination Board (22 October 2026, as reported in the press), the liquidation of 18 of the 31 funds had been completed as at 21 October 2026 and TRY 8.9 billion had been paid to 10,008 accounts; which funds those are has not been disclosed. According to the 8th Fund Coordination Board (28 October 2026, as reported in the press), the liquidation work in 27 of the 31 funds had been “largely” completed as at 23 October 2026 and TRY 27.2 billion had been paid to 26,152 accounts in total; work on the remaining 4 funds continues; which funds are meant has not been disclosed. In the complete TEFAS record of 26 October 2026 HPL’s portfolio fell to a residual amount; in KSA (≈ −73.0%), HPH (≈ −72.7%) and HKJ (≈ −55.2%) the unit price fell sharply while the numbers of investors and units in circulation did not change: part of the portfolio appears to have been distributed, but no payment has been announced. In the TEFAS record of 27 October 2026 HPH’s unit price fell by a further ≈ 8.5%; in HDH the fall continued in the records of 27 and 28 October 2026 (≈ −17.7% since 26 October 2026); the causes are unclear. HPH’s number of investors (6,593) did not change. No company statement on these funds has been found.
Payments of 8 October 2026: According to a Directorate of Communications statement reported in the press, T.C. Ziraat Bankası A.Ş. transferred the liquidation proceeds of the A1 Capital (AJ1, CAH, P1A, PAB), Bulls (BMU, BOS, BPZ) and Pardus (AC4, AC5, BRT, BST, IAU, KHA, PAO, PMP, POS, PYR) funds to the banks and brokerage firms holding investors’ accounts; those institutions are to credit the amounts to investors’ accounts. The list of funds comes from the press and was compared with TEFAS data: the portfolios of these 17 funds fell to residual amounts on 9 October 2026. On 7 October 2026 the Government had told parliament that 43,643 investors in these funds would be paid.
Liquidator: Tera Portföy funds: Türkiye İş Bankası A.Ş. — KEP isbankasi@hs02.kep.tr
A1 Capital, Atlas, Bulls, Hedef, Pardus and Pusula funds: T.C. Ziraat Bankası A.Ş. — KEP ziraatbank@hs01.kep.tr
Specific notes: The press reported that a default in redemption payments of participation units occurred in certain Pusula Portföy funds on 15 September 2026.
The identifying details of these funds (name, ISIN, settlement, cut-off time) are not set out separately in this note; they should be confirmed from the fund prospectus and TEFAS.
In the funds paid out, the very low unit price shown on TEFAS (from 9 October 2026 in the 17 funds paid on 8 October 2026, from 16 October 2026 in the A1 Capital (BHN, BYZ, CBD, CHY, SEH), Bulls (BI5, BUC, YLZ) and Pardus (AC8, BSE, KRH, PHY, PO7, PO8, PO9, POI, PSR, SHI, PYD, PYI) funds, from 19 October 2026 in the Bulls (BLA, BP5, BOH, BBN, BDO, IHY, BIK, BSN) and Pardus (AP6, BHH, AC7, PCH, PDH, DHI, DRH, PKU, POF, POB, PPO, OHI, POU, PST, CSH) funds, from 21 October 2026 in Hedef’s HYV, HDK, HAT and HGH funds, and from 22 October 2026 in the HBV, HDA, HPI, HFI, HKP, HPF, FNT, HVC, DUH and HPZ funds) reflects the residual amount left in the fund; it does not show the amount the investor received.
Of the founders’ funds that are not on the list but were closed on 17 September 2026, those of A1 Capital, Bulls and Pardus may be reopened to trading at a later stage under decision 64/1770. According to the Government’s statements of 13 and 18 October 2026, the liquidation of the 49 listed funds of these three companies has been completed.
On 7 October 2026 the Government said that, if the necessary collateral is obtained, payments in the 16 funds of Atlas Portföy, covering 56,614 people, would also be made under the ordinary liquidation rules. SPK decision 76/1903 of 27 October 2026, however, lists the funds under liquidation founded by Atlas Portföy among the funds whose liquidation begins under Law No. 7596 and in which the interim payment is made (art. 1, art. 3); their liquidation is carried out by T.C. Ziraat Bankası AŞ (art. 2).
Atlas Portföy Serbest Fon (DFI; 47,645 investors): on TEFAS the price had been shown as 0 after 24 September 2026 (TRY 0.405808); in the TEFAS record of 28 October 2026 a unit price was published again (TRY 0.280642; portfolio ≈ TRY 1.40 billion). No reason has been given.
In Tera’s TLV fund, the price of 24 September 2026 reappeared on TEFAS on 1 October 2026; from 6 October 2026 the price is again shown as 0.
By Bulletin 2026/75 of 26 October 2026 the SPK temporarily suspended the capital market activities of Tera Portföy Yönetimi AŞ and Pusula Portföy Yönetimi AŞ under SPKn art. 97(1), and appointed Türkiye İş Bankası AŞ (for Tera) and T.C. Ziraat Bankası AŞ (for Pusula) to liquidate the investment funds, real estate investment funds and venture capital investment funds founded by these companies other than those whose liquidation was ordered by the decisions of 17 September 2026 (SPK Bulletin 2026/75). The bulletin names no funds or fund codes. These funds are outside the scope of Law No. 7596, which covers only the funds whose liquidation was ordered by the decisions of 17 September 2026 (art. 1).
Applications relevant to this fund: Depending on the status of the instruction, the avenues described in Scenarios 1–10: an A/6 application to the relevant liquidator (sample), and applications to MKK (sample), Takasbank (sample), the distributor (sample) and the SPK (sample).

12 · Calendar

Payment calendar and key dates

Upcoming dates, the stages already passed and the detailed chronology with source labels. This section is the single reference point for time limits.

Upcoming dates

30.10.2026First interim payments began: 7 money market funds (up to TRY 1 million, separately for each fund)Anadolu Agency report: TRY 29.3 billion in total to 235,705 investors. Paid by İş Bankası (Tera) and Ziraat Bankası (Pusula, Atlas) · How does it work?
04.11.2026Payments continued: TRY 117.6 billion in totalAnadolu Agency and DHA reports: TRY 62.2 billion to 390,219 investors in the extraordinary liquidation; TRY 55.4 billion to 55,821 investors in the ordinary liquidation. No fund list has been published.
Mid-November (target)Remaining interim paymentsVice President’s statement of 27 October 2026 (as reported in the press). A target, not a fixed date; no fund-by-fund date has been announced.
Mid-November (target)Completion of the interim payment process of up to TRY 1 millionThe expectation stated by the Vice President at the TBMM on 27 October 2026 (as reported in the press); a target, not a date
No dateVoluntary returns: SPK decision on the calculation period, method and accounts (art. 4(4))76/1903 does not deal with these matters; no decision as at 5 November 2026 · Voluntary refunds
No dateThe remaining Hedef Portföy funds: ordinary liquidation paymentsAccording to the 8th Fund Coordination Board (28 October 2026), work on the remaining 4 funds continues; neither the list of funds nor a date has been announced. In KSA, HPH and HKJ part of the portfolio appears to have been distributed in the record of 26 October 2026, with no payment announced · Payments
30.10.2026End of the relaxed equity ratio for margin transactions (2026/68)Not a time limit for applications by fund investors
16.11.2026Action for annulment against 57/1708: last day of the 60-day period from publicationPreclusive time limit (İYUK art. 7) · Administrative route
27.11 / 30.11.2026Calendar calculation: 60 days from the SPK announcement of 28 September 2026 and from decisions 64/1770 and 64/1775 of 30 September 2026Whether these can be challenged in court needs to be assessed separately
≈ 17.03.2027End of the maximum liquidation period (the SPK may extend it)The Government’s target for final liquidation is “five to six months”

The provision of Law No. 7596 giving it effect from 17 September 2026 (art. 8) does not by itself change the İYUK calendar calculations for 16 November, 27 November and 30 November 2026. The Law’s effect on pending or future actions is not addressed in the text.

Already passed

16.09Tera Portföy announces a default on redemptions in THF and TP2 (as reported in the press)
17.09SPK decisions 57/1706, 57/1707 and 57/1708: trading suspended and 131 funds placed in liquidation
20.09SPK decision 59/1710: maximum liquidation period extended to 6 months
21.09End of the 2-business-day period for the A/2 reconciliation between MKK (Central Registry Agency) and the banks
28.09SPK announcement: instructions of 17 September cancelled, to be paid pro rata; default or absence of a price on or before 16 September falls under A/6
30.09SPK decisions 64/1775 (interim payment) and 64/1770 (order of liquidation)
01.10End of the period for the inter-institutional A/3 reconciliation of debts and receivables (not a time limit for applications by investors)
07.10Government statement in parliament: the interim payment made conditional on legislation
08.10Proceeds of the 17 A1 Capital, Bulls and Pardus funds transferred to banks and brokerage firms (as reported in the press)
09.10Bill No. 2/3939 submitted to the TBMM
13.10Announcement that TRY 6.4 billion had been paid to 43,643 investors in 17 funds
14.10Bill No. 2/3939 adopted by the Planning and Budget Committee
15.10SPK 70/1821: Hedef funds moved to ordinary liquidation
16.10TEFAS: the portfolios of 20 more A1 Capital, Bulls and Pardus funds fell to residual amounts
18.10Government: liquidation completed in 66 funds, 65 funds still in liquidation (as reported in the press)
19.10Committee report (Report No. 294); TEFAS: portfolios of 23 more Bulls and Pardus funds fell to residual amounts; Economic Coordination Board: interim payment “as soon as possible” after enactment (target)
20.10General Assembly debate began (no article voted on); Hedef Portföy: payments in the HYV, HDK, HAT and HGH funds (as reported in the press)
21.10Activities of Alnus, Bulls and Pusula Yatırım Menkul Değerler AŞ (brokerage firms) temporarily suspended (SPK Bulletin 2026/72); the General Assembly adopted Articles 1–5 of Bill No. 2/3939 (PBLK sentence added to Article 3)
22.10TEFAS: portfolios of 10 more Hedef Portföy funds fell to residual amounts (no company statement found); SPK press release: blocked units on equal terms with other unitholders; 7th Fund Coordination Board: 47 funds in liquidation, 18 of Hedef’s 31 funds completed (press report); the General Assembly adopted the bill: Law No. 7596
23.10Official Gazette (No. 33409): Law No. 7596 not in this issue; TEFAS (complete record): distribution visible in Hedef Portföy’s HKM, HMK and HEH funds (no company statement found)
24–25.10Official Gazette (Nos. 33410, 33411): Law No. 7596 not in these issues; Minister of Justice: a voluntary refund does not “on its own” remove legal liability (25.10, press report)
26.10SPK Bulletin 2026/75: activities of Tera Portföy and Pusula Portföy suspended; İş Bankası (Tera) and Ziraat Bankası (Pusula) appointed to liquidate their funds outside the 17 September decisions; TEFAS (complete record): HPL fell to a residual amount, partial falls in KSA, HPH and HKJ
27.10Law No. 7596 published in the Official Gazette (No. 33413) and in force with effect from 17 September 2026; SPK 76/1903: procedures for the interim payment (Bulletin 2026/76); SPK Bulletin 2026/77: activity permits of Tera Yatırım Menkul Değerler AŞ cancelled, compensation of its investors ordered; Vice President (TBMM): payments to begin on Friday (as reported in the press)
28.108th Fund Coordination Board: first interim payments expected to begin on 30 October 2026; 38 funds in liquidation; in Hedef, liquidation work in 27 of 31 funds “largely” completed (as reported in the press); YTM notice on the compensation of the investors of Tera Yatırım Menkul Değerler AŞ; TEFAS: a unit price published again for DFI

Detailed chronology73 entries · labelled by type of source

Source labels: Primary source SPK bulletin or announcement, TBMM record, TEFAS or KAP · Press report statement or news reported in the press; the institution’s own text should be checked separately · To be confirmed · Calculation

Date	Event	Source type
15.09.2026	A default in redemption payments of participation units was reported in certain Pusula Portföy funds.	Press report
16.09.2026 (evening)	Tera Portföy announced a default in redemption payments in THF and TP2; it was announced that DOH had been switched to monthly pricing and payment on the 10th business day (daily prices for DOH continued to be published on TEFAS until 24.09.2026).	Press report
17.09.2026	Decisions 57/1706 and 57/1707 of the SPK’s Decision-Making Body (Kurul Karar Organı), SPK Bulletin 2026/60: all funds founded by Tera, Pusula, Hedef, Atlas, A1 Capital, Pardus and Bulls Portföy Yönetimi A.Ş. were closed to both subscriptions and redemptions on TEFAS, and 130 funds were ordered to be liquidated by a method to be determined by the Board.	Primary source
17.09.2026	SPK decision 57/1708, SPK Bulletin 2026/61: the liquidation list was updated to 131 funds by adding THF; the liquidation rules were set out as A/1–A/9; redemption instructions in these funds will not be executed through channels outside TEFAS (founder, distributor) either. Liquidator: Türkiye İş Bankası A.Ş. for Tera Portföy funds and T.C. Ziraat Bankası A.Ş. for the funds of the other founders (each acting as portfolio custodian and liquidator).	Primary source
17.09.2026	The time of publication of the decision is officially unclear: the news spread between about 11.09 and 11.22, and the bulletin appears on the KAP feed at 14.10. On 28.09.2026 the SPK stated that all instructions given on 17.09.2026 had been cancelled by TEFAS.	Press report
18.09.2026	Tera Portföy KAP statement: it stated that amounts arising from TEFAS orders would be recorded as a liability of the fund and paid in priority.	Press report
20.09.2026	SPK decision 59/1710, SPK Bulletin 2026/62: A/8 amended and the maximum liquidation period extended from 3 to 6 months (≈ 17.03.2027). The other provisions remain in force unchanged. SPK press release of 21.09.2026: spk.gov.tr.	Primary source
21.09.2026	The 2-business-day period for the MKK–bank reconciliation under A/2 expired.	Primary source
21.09.2026	Hedef Portföy KAP statement: according to the founder, cash had been made available for all sell orders placed up to the moment of suspension, but Takasbank did not give permission and the TEFAS orders were cancelled; the 13 funds total ≈ TRY 31 billion, of which ≈ TRY 29.8 billion is liquid; there is no default. Takasbank, for its part, stated that the cancellation did not originate with it or with the TEFAS system.	Press report
21–22.09.2026	A default in redemption payments was reported in TMV (Tera Portföy Algoritmik Stratejiler Serbest Fon), which is not on the liquidation list.	Press report
22.09.2026	It was reported that the SPK had made cash and asset outflows at the brokerage firms Tera Yatırım, A1 Capital, Alnus, Bulls, İnfo Yatırım and Pusula subject to its control (firm names from the press). On 7 October 2026 the Vice President told parliament that, under an SPK decision, outflows of securities and cash from the accounts of 6 brokerage firms and 7 portfolio management companies were being handled under control, by joint decision of MKK, Borsa İstanbul and Takasbank under SPK supervision. The SPK’s decision has not been published and the firms have not been officially named.	Press report Primary source
23.09.2026	SPK statement: according to MKK records, the 131 funds under liquidation have 455,758 unique investors (spk.gov.tr). Higher figures quoted in the press involve double counting across funds.	Primary source
24.09.2026	Last price published on TEFAS for the Tera Portföy funds THF, DOH, T3B and TLV under liquidation; since 25.09.2026 the price has been shown as 0 (TP2 and TLY have had no price since 17.09.2026). According to the press, a note was added to the MKK e-Yatırımcı screen stating that the “0” price is not determinative.	Primary source Press report
28.09.2026	SPK announcement (spk.gov.tr): only instructions transmitted to TEFAS on or before 16.09.2026 were included in the ordinary process; all instructions given on 17.09.2026 were cancelled by TEFAS pursuant to decision 57/1707, and their holders will be paid out of the liquidation balance pro rata to their unitholdings; instructions transmitted on or before 16.09.2026 but not executed because the fund defaulted or did not publish a price fall within the liquidation for the purposes of A/6.	Primary source
28.09.2026	A single-signature bill by a Yeni Parti member, the “Bill on the Fair Liquidation of Certain Investment Funds for the Protection of Investors” (No. 2/3895), was submitted to the Speaker of the TBMM; on 1 October 2026 it was referred to the Planning and Budget Committee as lead committee. In committee, a motion to combine it with Bill No. 2/3939 was not adopted (Report No. 294).	Primary source
29.09.2026	It was announced that a “Fund Coordination Board” (Fon Koordinasyon Kurulu) chaired by a Vice President had been set up and that the State Supervisory Council (Devlet Denetleme Kurulu) had opened an inquiry. The Centre for Combating Disinformation (Dezenformasyonla Mücadele Merkezi) denied claims that investors would be charged a fee for payments.	Press report
30.09.2026	SPK Bulletin 2026/67: 64/1775, interim payment to reconciled unitholders in the funds of Tera, Pusula, Atlas and Hedef Portföy; 64/1770, order of liquidation for the A1 Capital, Bulls and Pardus funds; the capital market activities of Tera Yatırım Menkul Değerler A.Ş. were temporarily suspended as of 18.10 that day.	Primary source
30.09.2026	BDDK decision (bddk.org.tr): the shareholder rights other than dividend rights attaching to certain qualifying shareholdings in Destek, Hedef and Tera Yatırım Bankası are to be exercised by the TMSF (Savings Deposit Insurance Fund); in two factoring companies, certain shares are to be transferred within six months, with the voting rights exercised by the TMSF in the meantime.	Primary source
01.10.2026	SPK announcements: the terms of the interim payment (up to TRY 1 million per investor, separately for each fund); the liquidation process for the A1 Capital, Bulls and Pardus funds; the voluntary return accounts opened in the name of the TMSF for the 131 funds.	Primary source
01.10.2026	A/3: last day of the 10-business-day period for the reconciliation, between the previous custodian, the bank and Takasbank, of the debts and receivables arising from the funds’ own transactions. It is not a time limit for applications by investors.	Primary source Calculation
03.10.2026	SPK Bulletin 2026/68 (65/1779): the measure introduced by decision 57/1706 relaxing the equity ratio for margin (credit) transactions was extended to the end of the session on 30 October 2026. No new decision on the liquidation procedure; Bulletin 2026/69 of 7 October 2026 contains none either.	Primary source
04.10.2026	SPK press statement (spk.gov.tr): the claim that the provision protecting the assets of the Investor Compensation Centre was introduced for the first time in July 2026 is “entirely unfounded”; the provision has been in the SPKn since 30 December 2012 and in the YTM regulations since 6 June 2013.	Primary source
06.10.2026	SPK press statement (spk.gov.tr): reply to a press claim that Borsa İstanbul’s notifications had been disregarded; criminal complaints have been filed against 174 persons since the start of 2026, and 96 of the complaints made in 2026 concerned fund-related transactions. From the same date the TEFAS price of Tera’s TLV fund is again shown as 0.	Primary source
07.10.2026	TBMM General Assembly, statement by the Vice President (transcript): 455,758 unique investors in the 131 funds (151,247 in the 125 funds for which Ziraat Bankası is responsible, 388,718 in the 6 funds for which İş Bankası is responsible; an investor may hold more than one fund); the banks have formally taken over custody; 43,643 investors in the 17 funds of A1 Capital, Bulls and Pardus to be paid under ordinary liquidation rules, with the 49 private funds (2,098 people) to be dealt with separately; if collateral is obtained, ordinary liquidation also for Atlas’s 16 funds (56,614 people); the interim payment depends on legislation and, if enacted, is expected “within October”; final liquidation in “five to six months”; “no Treasury resources will be used”. The speech said the Fund Coordination Board held its second meeting on 2 October 2026 and discussed the draft bill at its third meeting.	Primary source
08.10.2026	Directorate of Communications statement reported in the press: payments have begun for 17 funds in the liquidation conducted by Ziraat Bankası; the amounts were transferred to the banks and brokerage firms holding investors’ accounts. Funds (list from the press): A1 Capital (AJ1, CAH, P1A, PAB), Bulls (BMU, BOS, BPZ) and Pardus (AC4, AC5, BRT, BST, IAU, KHA, PAO, PMP, POS, PYR). On TEFAS the portfolios of these 17 funds fell to residual amounts on 9 October 2026.	Press report Primary source
09.10.2026	AK Parti members of parliament submitted the “Bill on Certain Investment Funds Whose Liquidation Has Been Ordered” (No. 2/3939) to the Speaker of the TBMM; lead committee: Planning and Budget. Committee agenda: 14 October 2026 at 10.00 (tbmm.gov.tr). The bill was adopted by the General Assembly on 22 October 2026 (Law No. 7596).	Primary source
09.10.2026	4th meeting of the Fund Coordination Board (iletisim.gov.tr): the technical preparations for interim payments of up to TRY 1 million were reviewed.	Primary source
13.10.2026	5th meeting of the Fund Coordination Board (iletisim.gov.tr): TRY 6.4 billion had been paid to 43,643 investors in the A1 Capital, Bulls and Pardus funds; the target was to complete the liquidation of the remaining 49 funds by the end of the week and, once the bill is enacted, to complete the interim payments (at that date in 65 funds, including the Hedef funds).	Primary source
14.10.2026	Bill No. 2/3939 adopted by the Planning and Budget Committee (TBMM). According to the TBMM’s summary, unitholding is to be determined by reconciliation with the MKK records, and the benchmark for voluntary returns became the average of TÜFE and Yİ-ÜFE. In the debate, the member of parliament who sponsored the bill said it had been confirmed that receivables arising from TEFAS instructions matched on 14–16 September had been paid, and that there were also records left unpaid after the default (TBMM).	Primary source
15.10.2026	SPK decision 70/1821 (SPK Bulletin 2026/70, 16.10.2026): the Hedef Portföy funds were removed from the scope of 64/1775; their liquidation is subject to the rules of 64/1770.	Primary source
16.10.2026	BDDK (bddk.org.tr): in the Chairman’s briefing to the Planning and Budget Committee, without naming banks, the phrase “banks whose management has been transferred to the TMSF” appears. TEFAS: the portfolios of the A1 Capital (BHN, BYZ, CBD, CHY, SEH), Bulls (BI5, BUC, YLZ) and Pardus (AC8, BSE, KRH, PHY, PO7, PO8, PO9, POI, PSR, SHI, PYD, PYI) funds fell to residual amounts.	Primary source Calculation
18.10.2026	6th meeting of the Fund Coordination Board (Directorate of Communications statement reported in the press): liquidation transactions in kind and in cash of about TRY 40.8 billion were completed for more than 45,000 people in 66 funds; the number of funds in liquidation fell from 131 to 65; in this context, payments are planned next week in the Hedef funds, starting with the money market funds.	Press report
19.10.2026	The Planning and Budget Committee’s report on Bill No. 2/3939 (Report No. 294, S.Sayısı 294) is dated; it was distributed on 20.10.2026. In the adopted text, art. 2(c), art. 3(5) and art. 4(4) changed; art. 1 and arts. 5–9 were adopted unchanged. According to the statements of the public authorities set out in the report, a share block (PBLK) entry does not mean that cash has reached the investor’s account, and the rights of these investors will be protected within the liquidation “in their capacity as unitholders”; TRY 1 million is a ceiling only on the interim payment, not on total payments; all decisions and acts of the SPK are subject to review by the administrative courts.	Primary source
19.10.2026	SPK Bulletin 2026/71 (72/1870): of the voting rights frozen because Tera Yatırım Holding AŞ failed to meet its obligation to make a mandatory tender offer in a real estate investment trust, those attaching to the THF, DOH, T3B and TLY funds under liquidation were released; the voting rights of TMV and of the Tera companies remain frozen. The decision does not concern liquidation payments.	Primary source
19.10.2026	Economic Coordination Board (Ekonomi Koordinasyon Kurulu) statement: “We expect the interim payments to begin as soon as possible after the bill has been debated and enacted by the TBMM General Assembly.” This is a target; no firm date was given.	Press report
19.10.2026	Hedef Portföy statement: 31 funds are in ordinary liquidation under 70/1821; the liquidation is conducted by T.C. Ziraat Bankası A.Ş.; money market funds first, then from the fund with the most investors to the fund with the fewest; distribution pro rata to unitholdings, to reconciled individual custody accounts. No date was given.	Press report
19.10.2026	TEFAS: the portfolios of the Bulls (BLA, BP5, BOH, BBN, BDO, IHY, BIK, BSN) and Pardus (AP6, BHH, AC7, PCH, PDH, DHI, DRH, PKU, POF, POB, PPO, OHI, POU, PST, CSH) funds fell to residual amounts. Of the 66 funds of A1 Capital, Bulls and Pardus on TEFAS, 65 now have residual or zero portfolios; one fund still shows assets above a residual amount.	Primary source
20.10.2026	TBMM General Assembly (8th sitting, unrevised record): by a group motion that was adopted, Report No. 294 was moved to first place in the “Bills” part of the agenda, to be debated as a basic law in two parts (arts. 1–5 and arts. 6–9). The debate on the bill as a whole was completed and the Assembly voted to proceed to the articles; the debate on the first part was also completed. No article was put to the vote. Under the adopted work plan, the Assembly is to sit on 21.10 until the votes on the second part are completed and on 22.10 until the debate on the bill is completed; this is not a date of adoption.	Primary source
20.10.2026	SPK Bulletin 2026/72: the capital market activities of Alnus Yatırım Menkul Değerler AŞ, Bulls Yatırım Menkul Değerler AŞ and Pusula Yatırım Menkul Değerler AŞ were temporarily suspended from 00.01 on 21.10.2026 (art. 97(1) SPKn; capital adequacy rules). These are brokerage firms, not the portfolio management companies that founded the funds. The bulletin contains no decision on the start of the interim payment, on the application of A/6 or on TMV.	Primary source
20.10.2026	Hedef Portföy statement: HYV (Hedef Portföy Para Piyasası (TL) Fonu) had been 97.04% liquidated, HDK 97.95%, HAT 90.80% and HGH 85.98%; TRY 6,034,354,535.10 was paid in cash in total; payments were made on the basis of the current portfolio values arising from the liquidation, not at the prices of 16.09; the remaining funds will be paid in stages. In the TEFAS record of 21.10.2026 HYV’s portfolio fell from TRY 6.20 billion to TRY 0.18 billion and its unit price from 6.697765 to 0.198244; the portfolios of HDK, HAT and HGH also fell to residual amounts.	Press report Primary source
21.10.2026	Agenda of the TBMM General Assembly (9th sitting, 14.00): Report No. 294 is in first place in the “Bills” part (tbmm.gov.tr). At this note’s data cut-off (the morning of 21.10.2026) the bill had not been enacted or published in the Official Gazette; the Official Gazettes of 19, 20 and 21.10.2026 contain no law on the funds.	Primary source
21.10.2026	TBMM General Assembly (9th sitting, unrevised record): Articles 1, 2, 3, 4 and 5 in the first part of Report No. 294 were put to the vote one by one and adopted. An amendment adding to paragraph 5 of Article 3 a sentence stating that those whose units were blocked under instructions that could not be executed because of a default or the non-publication of the price are subject to the liquidation provisions “in their capacity as fund unitholders” was adopted (the committee left it “to the discretion” of the Assembly); an amendment that would have given these investors priority payment on the basis of settlement finality, and all other amendments, were rejected. Articles 1, 2, 4 and 5 were adopted as in Report No. 294. The second part (Articles 6–9) was not debated, and the bill as a whole was not voted on. The sitting closed at 00.02 on 22.10.2026, with the General Assembly to meet again at 14.00 the same day; this is an Assembly work plan, not a date of adoption.	Primary source
22.10.2026	In the TEFAS record of 22.10.2026, the unit price of Hedef Portföy’s HBV, HDA, HPI, HFI, HKP, HPF, FNT, HVC, DUH and HPZ funds fell sharply while the numbers of investors and of units in circulation did not change; the portfolios fell to residual amounts. In HMV and HVB the portfolio fell significantly but assets above a residual amount are still shown. No company statement on these funds has been found. No distribution is visible in HKJ, HPH and KSA. The record of 22.10.2026 was incomplete on the morning of 22 October; the complete record, retrieved again on 23 October 2026, confirmed this table. In HEH the price, portfolio and units in circulation are 0 in the complete record as well; no payment has been confirmed.	Primary source
22.10.2026	Official Gazette (No. 33408): no law on the funds (morning of 22 October 2026; the bill was then on the General Assembly’s agenda).	Primary source
22.10.2026	SPK press release (spk.gov.tr): the settlement-finality provision in SPKn art. 79 does not apply to all TEFAS instructions “regardless of the stage the transaction has reached”; settlement is completed when the cash is credited to the investor’s account and the record of unitholding is removed. Persons with a share-block entry are among the 455,758 fund unitholders and are not a separate group; their instructions will be assessed “on equal terms with the other unitholders”. The release was issued while the bill was being debated in the General Assembly.	Primary source
22.10.2026	SPK Bulletin 2026/73: criminal complaints and trading bans following two share-market investigations; Tera group companies are among those listed in the trading-ban tables. No decision on the fund liquidation, the interim payment or the implementation of Law No. 7596.	Primary source
22.10.2026	7th meeting of the Fund Coordination Board (Directorate of Communications statement, as reported by AA): the number of funds in liquidation has fallen from 131 to 47; since the start of the process, liquidation payments in kind and in cash totalling TRY 49.7 billion have been made to 55,755 accounts. The liquidation of 18 of Hedef Portföy’s 31 funds had been completed as at 21 October 2026; TRY 8.9 billion was paid to 10,008 accounts; work on the remaining 13 funds is to be completed “swiftly”. Once the bill is adopted, the processes for the interim payments in the remaining funds are to be taken forward “swiftly”; this is a target, not a date. A Deputy Minister of Treasury and Finance was assigned to monitor the process daily at technical level. The original text could not be found on the Directorate of Communications website.	Press report
22.10.2026	TBMM General Assembly (10th sitting, unrevised record): Articles 6, 7, 8 and 9 in the second part were adopted one by one in the wording of Report No. 294, all amendments to them being rejected; the bill as a whole was adopted by electronic vote: “The bill has been adopted and has become law.” The sitting closed at 20.03; the vote counts are not given in the unrevised record. According to the TBMM record of the Law: Law No. 7596, “Law on Certain Investment Funds Whose Liquidation Has Been Ordered”, adopted on 22.10.2026; sent to the Presidency on 22.10.2026; the Official Gazette date and number fields are blank.	Primary source
23.10.2026	Official Gazette (No. 33409, resmigazete.gov.tr): Law No. 7596 does not appear in this issue; no duplicate (mükerrer) issue on 22 or 23 October.	Primary source
23.10.2026	In the complete TEFAS record of 23 October 2026 (34 of 2,017 funds shown at a price of 0) the unit price of Hedef Portföy’s HKM and HMK funds fell sharply (≈ −97.0% and −98.9%) while the number of investors and of units in circulation did not change; HEH reappeared at a residual price of TRY 0.000149 (21 October 2026: TRY 3.348108). In HIM and NFK the price also fell sharply (≈ −89.5% and −95.4%), but their portfolios, at about TRY 28.6 million and TRY 46.2 million, remain above a residual amount. In HMV and HPF all values are 0. No distribution is visible in HKJ, HPH and KSA. No statement by the company or the SPK on these funds has been found.	Primary source
24.10.2026	Official Gazette (No. 33410, resmigazete.gov.tr): Law No. 7596 does not appear in this issue; no duplicate issue.	Primary source
25.10.2026	Official Gazette (No. 33411, resmigazete.gov.tr): Law No. 7596 does not appear in this issue; no duplicate issue. In the TBMM record of the Law, the fields for the date of return from the Presidency, the action taken by the President and the Official Gazette date and number are blank.	Primary source
25.10.2026	Minister of Justice Akın Gürlek, social media statement (reported by Hürriyet/DHA and Anka; the original post could not be opened): “Making a voluntary refund does not, on its own, remove the legal liability of any natural or legal person” (unofficial translation). He added that these refunds do not stand in the way of the conduct of the investigations or the assessment of the evidence, and that the source, timing and amount of the refunds and the way they are passed on to the true rightholders will be examined.	Press report
26.10.2026	Official Gazette (No. 33412, resmigazete.gov.tr): Law No. 7596 does not appear in this issue.	Primary source
26.10.2026	SPK Bulletin 2026/75: the capital market activities of Tera Portföy Yönetimi AŞ and Pusula Portföy Yönetimi AŞ were temporarily suspended under SPKn art. 97(1). Türkiye İş Bankası AŞ (Tera) and T.C. Ziraat Bankası AŞ (Pusula) were appointed to liquidate the investment funds, real estate investment funds and venture capital investment funds founded by these companies other than those whose liquidation was ordered by the decisions of 17 September 2026. The bulletin names no funds or codes; these funds are outside the scope of Law No. 7596 (art. 1). Bulletin 2026/74, published the same day, concerns an amendment to the Fund Guidelines and the professional client thresholds; it does not relate to the funds in liquidation.	Primary source
26.10.2026	In the complete TEFAS record of 26 October 2026 (34 of 2,017 funds shown at a price of 0) the unit price of Hedef Portföy’s HPL fund fell by ≈ 95.7% and its portfolio fell to a residual amount; in KSA (≈ −73.0%), HPH (≈ −72.7%) and HKJ (≈ −55.2%) the unit price fell sharply while the numbers of investors and units in circulation did not change; in these three funds part of the portfolio appears to have been distributed. The cause of the ≈ −18.9% fall in HDH is unclear; HIM, NFK and HVB show no movement. No distribution is visible in the liquidation funds of Tera, Pusula and Atlas. No statement by the company, the liquidator bank or the SPK on these funds has been found.	Primary source
27.10.2026	Law No. 7596 on Certain Investment Funds Whose Liquidation Has Been Ordered was published in the Official Gazette (27 October 2026, No. 33413, resmigazete.gov.tr). Date of adoption 22 October 2026; the date beneath the text is 26 October 2026. The Law entered into force on the date of its publication, with effect from 17 September 2026 (art. 8). The Official Gazette text is identical to the text adopted by the TBMM. The Law leaves implementation to the SPK: the interim payment may be made “in the funds determined by the Board” (art. 4(2)); for voluntary returns the Board sets the calculation period and method (art. 4(4)); the procedures and principles for implementing the Law are set by the Board, after obtaining the TMSF’s opinion on matters within the TMSF’s remit (art. 7(2)). By decision 76/1903 of 27 October 2026 (SPK Bulletin 2026/76) the SPK set the procedures and principles for the liquidation and the payments: the interim payment will be made in the funds under liquidation founded by Tera, Pusula and Atlas Portföy (details). The decision gives no start date for payment. As at 5 November 2026 the calculation period, the method and the “accounts announced by the Board” for voluntary returns (art. 4(4)) had not been set.	Primary source
27.10.2026	SPK Bulletin 2026/76: Board decision 76/1903 of 27 October 2026: “Procedures and Principles for the Liquidation and Payments to be Made under Law No. 7596 on Certain Investment Funds Whose Liquidation Has Been Ordered” (11 articles). The liquidation of the funds founded by Tera, Pusula and Atlas Portföy that were placed in liquidation by the decisions of 17.09.2026 begins (art. 1); the liquidation is carried out by T.C. Ziraat Bankası AŞ for the Pusula and Atlas funds and by Türkiye İş Bankası AŞ for the Tera funds (art. 2); interim payments are made to the unitholders of those funds (art. 3); interim payments begin with funds whose names include the words “para piyasası” (money market) (art. 4). The interim payment is made fund by fund and may not exceed the net investment amount or TRY 1 million (art. 6); it is made without units being redeemed and is set off against the final payment (art. 10). The decision gives no start date, no application procedure and no fund codes.	Primary source
27.10.2026	SPK press release “Procedures and principles for the liquidation and payments have been set” and the guide “10 Questions on the Procedures and Principles for Liquidation and Payments” (spk.gov.tr, PDF): a question-and-answer summary of decision 76/1903; it contains no date, application or payment-account information.	Primary source
27.10.2026	SPK Bulletin 2026/77: all activity permits and the authorisation certificate of Tera Yatırım Menkul Değerler AŞ (a brokerage firm) cancelled; compensation of its investors and its gradual liquidation ordered (SPKn art. 97(1)). The firm’s activities had been temporarily suspended since 30 September 2026. The decision concerns a brokerage firm, not the portfolio management company that founded the funds.	Primary source
27.10.2026	Vice President Cevdet Yılmaz, TBMM Planning and Budget Committee (2027 budget debate; ANKA report, Karar, Diken): “Payments of up to TRY 1 million in the extraordinary liquidation will begin as of Friday through İş Bankası and Ziraat Bankası. We will go from the lowest to the highest.” The process is expected to be completed “by mid-November” (target). He said TRY 68 billion had been paid to 71,899 accounts in 93 funds as at 23 October 2026.	Press report
27.10.2026	In the TEFAS record of 27 October 2026 HPH’s unit price fell from 0.675299 to 0.617690 (≈ −8.5%) while its number of investors (6,593) did not change; HDH’s unit price fell by ≈ 9.4%. No significant movement in KSA or HKJ. No reasons have been given.	Primary source
28.10.2026	YTM notice (ytm.gov.tr, PDF): from 27 October 2026 the duties and powers of the statutory bodies of Tera Yatırım Menkul Değerler AŞ are performed by the YTM; the application form and rules for compensation claims will be published separately on ytm.gov.tr; objections to the schedule of creditors may be made within thirty days of its announcement; payments will be made within three months of the announcement of the schedule (extendable by up to three months with the Board’s approval).	Primary source
28.10.2026	8th Fund Coordination Board, written statement of the Directorate of Communications (@iletisim post; CNN Türk, AA report, memurlar.net): for the funds in the extraordinary liquidation, “the first interim payments are expected to begin on Friday 30 October 2026”. The liquidation work in 27 of Hedef’s 31 funds had been “largely” completed as at 23 October 2026 (TRY 27.2 billion to 26,152 accounts); work on the remaining 4 funds continues. Since the start the number of funds in liquidation has fallen from 131 to 38, and liquidation payments in kind and in cash totalling TRY 68 billion have been made to 71,899 accounts. “Returns to the accounts opened with the TMSF are continuing.” Technical preparations for a draft bill with structural measures will be accelerated. The statement does not appear in the iletisim.gov.tr news list.	Press report
28.10.2026	In the TEFAS record of 28 October 2026 a unit price was published for DFI (Atlas Portföy Serbest Fon; 47,645 investors) for the first time after 24 September 2026: TRY 0.280642 (portfolio ≈ TRY 1.40 billion). The fall in HDH continued (≈ −9.1%); no significant movement in KSA, HKJ or HPH. No new fund is marked “Paid” in the list.	Primary source
28.10.2026	Official Gazette (No. 33414, resmigazete.gov.tr): no provision on the funds.	Primary source
30.10.2026	The first interim payments began: according to Anadolu Agency (Memurlar.net), TRY 29.3 billion in total to 235,705 investors in 7 funds. The split by fund has not been disclosed; the SPK decision gives no date.	Press report
03.11.2026	9th Fund Coordination Board (Anadolu Agency report): as at 30 October 2026, TRY 97.3 billion to 247,839 investors in 100 funds; interim payments to continue “this week”.	Press report
04.11.2026	Total reported in the press (Anadolu Agency and DHA reports): TRY 117.6 billion to 446,040 investors. No fund list or cut-off date was given.	Press report
13.11.2026	SPK Bulletin 2026/78 (76/1918): end of the relaxation of the equity ratio for margin transactions (2026/68); not a time limit for applications by fund investors.	Primary source
16.11.2026	Last day of the 60-day period, running from publication, for an action for annulment against the regulatory act 57/1708. Preclusive time limit. (İYUK art. 7) The provision of Law No. 7596 giving it effect from 17 September 2026 does not by itself change this calendar calculation.	Calculation
27.11.2026 / 30.11.2026	Calendar calculation: 60 days from the SPK’s announcement of 28.09.2026 and from decisions 64/1770 and 64/1775 of 30.09.2026. Whether these texts can be challenged in court needs to be assessed separately.	Calculation
≈ 17.03.2027	End of the maximum liquidation period (the SPK may extend it).	Primary source

13 · Documents

Documents that may be gathered

Ticks are stored only in this browser and are not sent anywhere. Sample texts for applications to the institutions follow below.

MKK e-Yatırımcı account movements (via e-Devlet or MKK e-Yatırımcı): in particular the entries “Fon satış blokaja alma (TEFASP)” (sale block placed) and “Fon satış blokaj çözme (TEFASP)” (sale block released), and PBLK / RHVN / TEKA sub-account movements
Date- and time-stamped screenshots of the bank or brokerage screens (order, status, cancellation message, “bekliyor” (pending) notice)
Mobile app notifications (SMS / push), such as “emre dönüşmüştür” (converted into an order)
Account statements and transaction receipts
Investment services agreement, risk disclosure form, suitability / appropriateness assessment
Fund prospectus and key investor information document (instruction cut-off time, settlement)
Written replies received from the institutions
KEP proofs of dispatch and delivery
Transaction and log records requested through a data subject access request under art. 11 KVKK (worth considering)

14 · Sample texts

Sample application texts

The full texts of the five general samples are on a separate page: sample application texts. Applications to Turkish banks, MKK, Takasbank and the SPK are made in Turkish, so the samples are reproduced there in their original Turkish, each with an English description. Which sample relates to which situation is set out in the situations and avenues sections.

WarningThe texts below are samples for general information only. They are not legal advice and should not be used without being adapted to the facts of the particular case. No liability is accepted for any consequences of their use. Professional legal assistance should be obtained before any application is made.

Sample 1

A/6 application to the liquidator bank

Addressed to: T.C. Ziraat Bankası A.Ş. (funds of founders other than Tera Portföy) or Türkiye İş Bankası A.Ş. (Tera Portföy funds)

Asks for an unexecuted TEFAS sell order to be recorded as a liability of the fund and paid with priority.

Open the text: A/6 application to the liquidator bank

Sample 2

Complaint and application to the SPK under art. 10 İYUK

Addressed to: Sermaye Piyasası Kurulu Başkanlığı (the SPK; unit concerned: Yatırım Fonları Dairesi Başkanlığı, the Investment Funds Department)

Asks the SPK to determine the scope of A/6, instruct the liquidators and reserve the amount; the step before court proceedings.

Open the text: Complaint and application to the SPK under art. 10 İYUK

Sample 3

Request to Takasbank for TEFAS records

Addressed to: İstanbul Takas ve Saklama Bankası A.Ş. — Piyasalar ve Operasyon GMY / Fon Platformları Ekibi (Markets and Operations; Fund Platforms Team)

Requests the TEFAS transmission, matching and cancellation records and the source and time of the cancellation.

Open the text: Request to Takasbank for TEFAS records

Sample 4

Request to MKK for reconciliation and registry information

Addressed to: Merkezi Kayıt Kuruluşu A.Ş. — Piyasa Operasyonları GMY (Market Operations)

Asks whether the order was included in the A/2 reconciliation and, if not, for a correction or an annotation of dispute.

Open the text: Request to MKK for reconciliation and registry information

Sample 5

Records request and A/6 notification to the bank or brokerage firm

Addressed to: The bank or brokerage firm through which the order was placed (the distributor)

Requests the order record, transmission time and TEFAS status, and notification of the order to the liquidator under A/6.

Open the text: Records request and A/6 notification to the bank or brokerage firm

All five sample texts · with the warnings and the copy and print tools

15 · Questions

Frequently asked questions

01When will the Tera funds and the other funds in liquidation be paid?

As at 5 November 2026 the position differs by founder. According to the 8th Fund Coordination Board (28 October 2026, as reported in the press), the number of funds in liquidation has fallen from 131 to 38, and since the start of the process liquidation payments in kind and in cash totalling TRY 68 billion have been made to 71,899 accounts. Tera, Pusula and Atlas: by decision 76/1903 of 27 October 2026 the SPK determined that interim payments will be made to the unitholders of the funds under liquidation founded by these three companies; payments begin with funds whose names include the words “para piyasası”; payment is made by Türkiye İş Bankası AŞ in the Tera funds and by T.C. Ziraat Bankası AŞ in the Pusula and Atlas funds. The decision gives no date. The first interim payments began on 30 October 2026. According to the Directorate of Communications’ statement on the 9th Fund Coordination Board (3 November 2026, as reported in the press), TRY 29.3 billion had been paid in the extraordinary liquidation as at 30 October 2026, and interim payments will continue “this week”. According to press reports of 4 November 2026 (Anadolu Agency and DHA), TRY 62.2 billion in total has been paid to 390,219 investors in the extraordinary liquidation, and the principal of 133,839 of them has been covered in full. No official text of these figures was found; neither fund names nor a cut-off date were given. The SPK decision gives no date. Vice President Cevdet Yılmaz told the TBMM Planning and Budget Committee on 27 October 2026 that they expect the process to be completed “by mid-November” (as reported in the press); this is a target, not a fixed date. There is no official statement that all unitholders were paid on the same day or up to the cap. A1 Capital, Bulls and Pardus: according to the Government’s statement of 18 October 2026, the liquidation of these companies’ 66 funds has been completed (as reported in the press); in 17 funds the proceeds were transferred on 8 October 2026; according to TEFAS data, the portfolios of 20 funds fell to residual amounts on 16 October 2026 and those of 23 funds on 19 October 2026. Hedef Portföy: under SPK decision 70/1821 of 15 October 2026 the funds are being liquidated under the rules of 64/1770. According to the company (as reported in the press), payments began on 20 October 2026 with the HYV, HDK, HAT and HGH funds and are being made on the basis of the current portfolio values arising in the liquidation, not at the prices of 16 September 2026. A distribution is also visible in the HBV, HDA, HPI, HFI, HKP, HPF, FNT, HVC, DUH and HPZ funds in the TEFAS record of 22 October 2026 and in the HKM, HMK and HEH funds in the record of 23 October 2026; no company statement on these funds has been found. According to the 8th Fund Coordination Board (28 October 2026), the liquidation work in 27 of the 31 funds had been “largely” completed as at 23 October 2026 and TRY 27.2 billion had been paid to 26,152 accounts in total; work on the remaining 4 funds continues (as reported in the press). Which funds are meant has not been disclosed. On what TEFAS shows, the list in this note marks 19 Hedef funds as “Paid” (the latest, HPL, on the record of 26 October 2026); the two counts rest on different bases, and it has not been confirmed that the funds are the same. In the TEFAS record of 26 October 2026 the unit price of KSA, HPH and HKJ fell by 55–73% while the number of investors did not change: part of the portfolio appears to have been distributed, but no payment has been announced. No date has been announced for the remaining Hedef funds.

Payments are made to reconciled accounts pro rata to unitholdings (57/1708 A/5). The maximum liquidation period is six months (≈ 17 March 2027) and the SPK may extend it; the Government’s target for final liquidation is “five to six months”. These are targets, not fixed dates.

02When will the interim payment be made, to whom, and how much?

SPK decision 76/1903 (27 October 2026). By this decision the SPK set the procedures and principles for the liquidation and payments under Law No. 7596 (SPK Bulletin 2026/76). To whom: interim payments are made to the unitholders of the investment funds under liquidation founded by Tera Portföy Yönetimi AŞ, Pusula Portföy Yönetimi AŞ and Atlas Portföy Yönetimi AŞ (art. 3). The Hedef Portföy funds had been removed from the interim payment by decision 70/1821 of 15 October 2026 and are not listed in the decision. The decision names no funds and gives no fund codes. Order: interim payments begin with funds whose names include the words “para piyasası” (art. 4); in the other funds, payment begins with the fund with the highest ratio of distributable cash to total interim payment obligations, and the order is set by the liquidator banks (art. 7). Who pays: T.C. Ziraat Bankası AŞ in the Pusula and Atlas funds, Türkiye İş Bankası AŞ in the Tera funds (art. 2, art. 6). How much: the interim payment is made fund by fund and “may not exceed the net investment amount calculated by MKK without indexation, or TRY 1 million” (art. 6). If distributable cash is insufficient, the payment may not exceed the lowest of (i) the net investment amount, (ii) for funds whose names include “para piyasası”, the amount calculated as at the end of the day before 17.09.2026 and, for other funds, the amount calculated as at the end of the day before the date on which the interim payment amount is calculated, and (iii) TRY 1 million (art. 6). If cash is still insufficient, an order from the smallest to the largest interim payment amount may be set and/or the Board may approve a minimum interim payment amount for all (art. 8). Units: interim payments are made without the units being redeemed; units are redeemed on the final payment and the interim payment is set off against it (art. 10). No payment is made to persons and entities that the Board has determined committed the acts under SPKn art. 104, 106 or 107 and that MKK has notified to the banks (art. 9).

When? The decision gives no date. The first interim payments began on 30 October 2026. According to the Directorate of Communications’ statement on the 9th Fund Coordination Board (3 November 2026, as reported in the press), TRY 29.3 billion had been paid in the extraordinary liquidation as at 30 October 2026, and interim payments will continue “this week”. According to press reports of 4 November 2026 (Anadolu Agency and DHA), TRY 62.2 billion in total has been paid to 390,219 investors in the extraordinary liquidation, and the principal of 133,839 of them has been covered in full. No official text of these figures was found; neither fund names nor a cut-off date were given. The SPK decision gives no date. Vice President Cevdet Yılmaz told the TBMM Planning and Budget Committee on 27 October 2026 that they expect the process to be completed “by mid-November” (as reported in the press); this is a target, not a fixed date. There is no official statement that all unitholders were paid on the same day or up to the cap. Neither the decision nor the SPK’s press release of 27 October 2026 says whether an application is needed or into which account the payment will be made.

Statements in the committee report. According to the statements of the public authorities set out in the Planning and Budget Committee’s report (Report No. 294), TRY 1 million is not a ceiling on total payments but only on the interim payment; the interim payment does not end unitholding, and the indexation not applied to the interim payment will be applied to the final payment. The amount of the final payment depends on the assets that can be converted into cash in the fund; these statements are not an undertaking to pay.

The formula in the Law. Under art. 4 of Law No. 7596, MKK calculates the net investment amount by updating each cash inflow into and each cash outflow from the fund to the liquidation date by the arithmetic average of the changes in TÜFE and Yİ-ÜFE and deducting the outflows first-in, first-out. The interim payment is made only in funds the SPK designates, and it may not exceed three limits: (i) TRY 1,000,000 per investor for each fund; (ii) the net investment amount calculated without indexation; (iii) except in funds of a money market nature, the value of the units in the account at the end of the previous day, at a Takasbank price. Under SPK decision 76/1903, if distributable cash is insufficient, “the amount calculated as at the end of the day before 17.09.2026” also applies as a cap in funds whose names include “para piyasası” (art. 6). To try scenarios with your own figures against these three limits: interim payment estimate tool. The bill was adopted in committee on 14 October 2026; Article 4, which governs the interim payment, was adopted by the General Assembly on 21 October 2026 as in Report No. 294, and the bill as a whole on 22 October 2026. The Law was published in Official Gazette No. 33413 of 27 October 2026 and entered into force with effect from 17 September 2026 (art. 8).

03Has the fund liquidation law passed, and what does it change?

Yes. On 22 October 2026 the TBMM General Assembly adopted Articles 6–9 and the bill as a whole; the bill became Law No. 7596 on Certain Investment Funds Whose Liquidation Has Been Ordered (Tasfiyesine Karar Verilen Bazı Yatırım Fonları Hakkında Kanun) and was sent to the Presidency the same day. The Law was published in Official Gazette No. 33413 of 27 October 2026 and entered into force the same day, with effect from 17 September 2026 (art. 8). The Official Gazette text is identical to the text adopted by the TBMM. The Law leaves the implementing rules to the SPK (art. 4(2), 4(4), 7(2)); the SPK set the procedures and principles for the liquidation and payments by decision 76/1903 of 27 October 2026; the calculation period, method and accounts for voluntary returns (art. 4(4)) had not been set as at 5 November 2026. The process: Bill No. 2/3939 was submitted to the TBMM on 9 October 2026 and adopted by the Planning and Budget Committee on 14 October 2026; the committee report was distributed as Report No. 294 on 20 October 2026. On 21 October 2026 the General Assembly adopted Articles 1–5; a sentence was added to Article 3 by amendment stating that those whose units have been blocked are subject to the liquidation provisions “in their capacity as fund unitholders”. On 22 October 2026 Articles 6–9 were adopted in the wording of Report No. 294, all amendments being rejected, and the bill as a whole was adopted by electronic vote. The text of the Law published by the TBMM differs from Report No. 294 only in paragraph 5 of Article 3 (the added sentence and one punctuation change). In the adopted text, unitholding is to be determined on the basis of reconciliation of the records of MKK and of the institution charged with the liquidation (arts. 2(c) and 3(5)), and the benchmark for voluntary returns became the average of TÜFE and Yİ-ÜFE (art. 4(4)).

Under the Law, in funds whose cash does not cover the total value at the unit price at the end of the day before the liquidation decision, payments will follow the net investment amount calculated by MKK rather than the value of the units. The interim payment will gain a statutory basis and be capped at TRY 1,000,000 per investor for each fund; according to the committee report, that cap applies only to the interim payment, not to total payments. If cash falls short, the SPK may order payment starting from the lowest net investment amount. No payment will be made to persons whom the SPK determines to have committed, in connection with the funds, the acts in SPKn arts. 104, 106 or 107, or to have acted together with them. The TMSF will collect value unlawfully extracted from the funds, and seized and confiscated assets will go to the fund or to a recovery account that cannot be attached. The Law covers funds whose liquidation is not completed on the date of its publication (27 October 2026). It makes no reference to A/6; under the sentence added to Article 3 in the General Assembly, those whose units were blocked under instructions that could not be executed because of a default or the non-publication of the price are subject to the liquidation provisions “in their capacity as fund unitholders”, and an amendment giving them priority payment was rejected. See the section on Law No. 7596.

04Where was the payment from my A1 Capital, Bulls or Pardus fund made?

According to the Directorate of Communications statement of 8 October 2026, T.C. Ziraat Bankası A.Ş. transfers the liquidation proceeds to the banks and brokerage firms holding investors’ accounts; those institutions credit the amounts to investors’ accounts. Transfers were made on 8 October 2026 in the A1 Capital (AJ1, CAH, P1A, PAB), Bulls (BMU, BOS, BPZ) and Pardus (AC4, AC5, BRT, BST, IAU, KHA, PAO, PMP, POS, PYR) funds; according to TEFAS data, the portfolios of the A1 Capital (BHN, BYZ, CBD, CHY, SEH), Bulls (BI5, BUC, YLZ) and Pardus (AC8, BSE, KRH, PHY, PO7, PO8, PO9, POI, PSR, SHI, PYD, PYI) funds fell to residual amounts on 16 October 2026 and those of the Bulls (BLA, BP5, BOH, BBN, BDO, IHY, BIK, BSN) and Pardus (AP6, BHH, AC7, PCH, PDH, DHI, DRH, PKU, POF, POB, PPO, OHI, POU, PST, CSH) funds on 19 October 2026. According to the Government’s statement of 18 October 2026 (as reported in the press), liquidation “in kind and in cash” has been completed in all 66 funds of these three companies; “in kind” indicates that some investors may have received capital market instruments instead of cash. No statement has said that a separate application is needed to receive the payment; investors can check their own account with the bank or brokerage firm holding the units. The very low unit price shown on TEFAS after payment reflects the residual amount left in the fund and does not show the amount paid to investors. Status fund by fund: full list.

05Can a lawyer guarantee the outcome?

No. The amount distributed in the liquidation is limited to what the fund’s assets realise when converted into cash; losses caused by market price movements are not compensated; damages claims depend on proof of fault and causation; and even a favourable judgment leaves open whether it can actually be enforced. The separation of the fund’s assets (art. 53 SPKn) protects unitholders, but there is no public mechanism that makes good any shortfall. On 7 October 2026 the Vice President told parliament that “no Treasury resources will be used”, and the explanatory memorandum to Bill No. 2/3939 also states that no public resources will be used for payments. Procedural errors, such as skipping mandatory mediation or suing directly in a dispute below the consumer arbitration committee threshold, can also end a claim before the merits are considered.

06Does the Investor Compensation Centre (YTM) cover losses in this process?

The YTM steps in only where the SPK determines that an investment firm (a brokerage firm or bank) is unable to return cash or capital market instruments held in its custody and a compensation decision is made. A portfolio management company is not an “investment firm” within the YTM scheme, and losses arising from the liquidation of funds and from market price movements are outside its scope (SPKn art. 84(2)). Where a compensation decision is made, claims must be brought within one year of its announcement (art. 85); the maximum for 2026 is TRY 2,065,145 per investor.

Tera Yatırım Menkul Değerler AŞ. By SPK Bulletin 2026/77 (27 October 2026) it was decided “to cancel all activity permits and the authorisation certificate” of Tera Yatırım Menkul Değerler AŞ (a brokerage firm), “to compensate its investors and to liquidate the Brokerage Firm gradually” (PDF). According to the YTM’s notice of 28 October 2026, from 27 October 2026 the duties and powers of the firm’s statutory bodies are performed by the YTM until the liquidation is concluded; the application form and the rules for compensation claims will be published separately on ytm.gov.tr; objections to the schedule of creditors prepared by the YTM may be made within thirty days of its announcement; compensation payments will be made within three months of the announcement of the schedule, a period that may be extended by up to three months with the Board’s approval in compelling cases (ytm.gov.tr). The YTM’s compensation covers claims arising from the failure to meet obligations to pay cash or deliver capital market instruments held or managed by the investment firm on the investor’s behalf. The decision concerns a brokerage firm; it does not concern the fund founder Tera Portföy Yönetimi AŞ. No statement has been made on fund units held at this firm or on liquidation payments to be made to such accounts.

07What is the position of a cancelled sell order?

In its announcement of 28 September 2026 the SPK stated that all instructions given on 17 September 2026 were cancelled by TEFAS because the funds had been closed to trading on TEFAS, and that the holders of those instructions will be paid out of the liquidation balance pro rata to their unitholdings in the fund. According to the same announcement, instructions transmitted to TEFAS on or before 16 September 2026 but not executed because the fund defaulted or did not publish a price fall within the liquidation for the purposes of A/6 (Scenario 4). As regards orders of 17 September 2026, the view that the second sentence of A/6 contains no requirement that the order must not have been cancelled now takes the form of an objection to the interpretation the SPK has published (Scenario 1); how the administrative authorities and the courts will respond to that objection is uncertain. Law No. 7596 (bill 2/3939) makes no reference to A/6. However, on 21 October 2026 the General Assembly added a provision to paragraph 5 of Article 3 by amendment: where instructions transmitted to TEFAS on or before 17 September 2026 could not be executed because the fund defaulted and/or its unit price was not published, those whose units have been blocked are subject to the liquidation provisions of the law “in their capacity as fund unitholders”. An amendment that would have given these investors priority payment was rejected. Law No. 7596, adopted by the General Assembly on 22 October 2026, was published in Official Gazette No. 33413 of 27 October 2026 and entered into force the same day, with effect from 17 September 2026 (art. 8); the Official Gazette text is identical to the text adopted by the TBMM. The SPK’s announcement of 28 September 2026 is unchanged.

08What happens if no redemption instruction was given?

Under A/5, cash obtained from the sale of assets is transferred to the reconciled individual custody accounts pro rata to unitholdings; no priority arises. The relevant steps are to confirm that the units are correctly recorded at MKK at registry level (with matching by ISIN for funds whose name differs between systems) and to follow the distribution (Scenario 10).

09What if the fund is not on the SPK Bulletin 2026/61 list?

Funds that are not on the list but are subject to trading restrictions or in default (for example TMV) fall outside the liquidation rules of decision 57/1708; the SPK may be asked to lay down a procedure under art. 96 SPKn (Scenario 8). By Bulletin 2026/75 of 26 October 2026 the SPK temporarily suspended the activities of Tera Portföy and Pusula Portföy and appointed Türkiye İş Bankası AŞ (Tera) and T.C. Ziraat Bankası AŞ (Pusula) to liquidate these companies’ investment funds, real estate investment funds and venture capital investment funds other than those covered by the decisions of 17 September 2026; the bulletin names no funds or codes. These funds are outside the scope of Law No. 7596 (art. 1). For funds not covered by the decisions of 17 September 2026 (for example BSM — Global MD Portföy Berrak Serbest Fon), a written enquiry may be made to the distributing bank about what has become of the orders (Scenario 9).

Related: TMV · BSM

10Is 1 October 2026 a deadline for investors to apply?

No. A/3 governs the reconciliation, between the previous custodian, the liquidator bank and Takasbank, of the debts and receivables arising from the funds’ own transactions (repos, deposits, borrowings and the like), and allows 10 business days after the Board’s decision for it (1 October 2026). That period was not set for applications by investors; the statement in an earlier version of this note describing it as the last date in practice for having a claim recorded has therefore been removed. The period for the MKK–bank reconciliation under A/2 expired on 21 September 2026; requests made after that date are in the nature of a correction. Because interim payments and distributions will be made on the basis of reconciled records, it is important that applications are made before any distribution.

Related: Calendar · A/2 and A/3

11What does a fund price of 0 on TEFAS mean?

Since 25 September 2026 the price of the Tera Portföy funds under liquidation has been shown as 0 on TEFAS (for TLV, the price of 24 September 2026 reappeared on 1 October 2026, and from 6 October 2026 the price is again shown as 0). No official reason has been given. According to press reports, a note was added to the MKK e-Yatırımcı screen stating that the “0” price is not determinative and that payment will be made out of the balance remaining after liquidation, according to the number of units held. The amount due to an investor in the liquidation is determined by the balance obtained from converting the assets into cash under A/5. In the A1 Capital, Bulls and Pardus funds that have been paid out, by contrast, a very low unit price is shown (for example, since 9 October 2026 in the 17 funds paid on 8 October 2026); in Hedef’s HYV fund, too, the unit price fell from 6.697765 to 0.198244 in the TEFAS record of 21 October 2026. This reflects the residual amount left in the fund after the cash was distributed and does not show the amount paid to investors. A day’s TEFAS record may be incomplete in its first hours (for example, on the morning of 23 October 2026, 357 funds were shown at a price of 0); a price of 0 on a single day does not show that a payment has been made.

12What are the voluntary return accounts? Will investors be asked to pay a fee to receive payment?

By its announcement of 1 October 2026, the SPK stated that separate accounts had been opened in the name of each fund (with Birleşik Fon Bankası, in the name of the TMSF) so that persons who made excessive gains from redemptions of units in the period before the liquidation decision may voluntarily return those gains to the fund concerned. These accounts are not for payments to investors; amounts paid into them are simply added to the liquidation estate of the fund concerned. Liquidation payments are made under A/5 to the reconciled individual custody accounts. On 29 September 2026 the Centre for Combating Disinformation (Dezenformasyonla Mücadele Merkezi) denied claims that investors would be charged a fee for payments (as reported in the press). Messages asking for a fee, a password, or card or account details in return for payment should be disregarded.

13Can unitholders apply to the institutions without a lawyer?

Yes. Unitholders may apply directly to the liquidator banks, MKK, Takasbank, the SPK and the distributors. When sending by KEP, the message type “Kep” should be selected (not “E-Yazışma”), and the proof of delivery should be downloaded and kept after sending. Procedural rules such as mandatory mediation, the monetary threshold for consumer arbitration committees and preclusive time limits apply separately in each case.

14What does fund liquidation mean?

Fund liquidation means bringing an investment fund’s activity to an end: the assets in its portfolio are sold (converted into cash), the fund’s debts are paid, and the remaining amount is distributed to unitholders pro rata to their units. At the end of the liquidation the fund is struck off the trade register. The liquidation of the 131 funds was started by SPK decision 57/1708 of 17 September 2026; Türkiye İş Bankası (Tera funds) and T.C. Ziraat Bankası (the other funds) are converting the assets into cash as liquidators. A fund’s assets are separate from those of its founder (SPKn art. 53); the founder company’s creditors cannot seize the fund’s assets.

15How long does a fund liquidation take?

Under SPK decision 59/1710, the maximum liquidation period is six months from the announcement (≈ 17 March 2027), and the Board may extend it; the SPK has stated that the period does not mean the liquidation will necessarily take that long. In practice the duration varies by fund: in the A1 Capital, Bulls and Pardus funds the liquidation was completed in about a month (Government statement, 18 October 2026); it may take longer in funds whose assets are hard to convert into cash. Payments need not be made in a single instalment; interim payments and partial distributions are possible.

Related: Payment calendar · Payments

16Which funds are being liquidated? Is my fund on the list?

The 131 funds whose liquidation was ordered are listed by name in SPK Bulletin 2026/61: the funds of A1 Capital (9), Atlas (16), Bulls (15), Hedef (31), Pardus (42), Pusula (12) and Tera Portföy (6). The bulletin gives no fund codes; in this note’s full list the 131 funds can be searched together with their TEFAS code, founder, liquidator bank and payment status. A fund that is not on the list (e.g. TMV) is not covered by the liquidation decisions of 17 September 2026.

17Why were 131 funds liquidated?

By its decisions of 17 September 2026 the SPK closed the funds of seven portfolio management companies to trading on TEFAS and ordered their liquidation. The press reported that, before the decisions, redemption payments of participation units had gone into default in some funds (Tera Portföy’s THF and TP2 funds, 16 September 2026). The Board has not set out the reasons for its decisions in detail. A criminal investigation and an inquiry by the State Supervisory Council are under way; this note does not cover the persons or allegations that are the subject of the investigation.

Related: Latest developments · Sources

18Which shares did the liquidated funds hold?

The assets in a fund’s portfolio can be seen in the monthly portfolio breakdown reports published on KAP and in the asset allocation section of the fund analysis page on TEFAS. This note does not list individual shares; the order and price at which assets are sold in the liquidation is a matter for the liquidator bank, and the amount due to investors is determined by the cash realised from those sales.

19Into which account is the payment made, and is an application needed?

The liquidator bank sends the amount to the account at the bank or brokerage firm where the units are held; that institution credits it to the investor’s account (Directorate of Communications, 8 October 2026; the practice in the ordinary liquidations). There is no official statement that a separate application is needed to receive the payment. Under SPK decision 76/1903 the interim payment in the Tera, Pusula and Atlas funds is made by “the banks charged with the liquidation” (Tera: Türkiye İş Bankası AŞ; Pusula and Atlas: T.C. Ziraat Bankası AŞ); neither the decision nor the SPK’s press release of 27 October 2026 says whether an application is needed or into which account the payment will be made; as at 5 November 2026 no announcement on this by the SPK, MKK or those banks had been found. As payments are made to accounts reconciled with the MKK records, a unitholder who believes there is a problem with their record may ask MKK and their institution to confirm it (sample application texts). The SPK temporarily suspended the activities of Alnus, Bulls and Pusula Yatırım Menkul Değerler AŞ from 21 October 2026 (Bulletin 2026/72); these are brokerage firms, not the portfolio management companies that founded the funds. As at 5 November 2026 it has not been announced how liquidation payments will reach those who hold accounts with them; information can be requested in writing from the firm itself and from the SPK. The activity permits of Tera Yatırım Menkul Değerler AŞ were cancelled on 27 October 2026 and compensation of its investors by the YTM was ordered (YTM row); no statement has been made on liquidation payments for fund units held at that firm. Messages asking for a fee, a password or card details in return for payment should be disregarded.

Related: Payments · Sample MKK application

20What is a voluntary (isteğe bağlı) refund, and how does Law No. 7596 regulate it?

Under Article 4(4) of Law No. 7596, persons who received payment by redeeming their units to the fund before the liquidation date may return the return they made in excess of their inflows updated, pro rata temporis (kıstelyevm), by the arithmetic average of the changes in TÜFE and Yİ-ÜFE “to the accounts announced by the Board on a voluntary basis” (Kurulca ilan edilen hesaplara isteğe bağlı olarak). Persons who made gains on shares the SPK has made the subject of arts. 104, 106 and 107 of Law No. 6362 may return the gain in excess of the purchase cost updated by the same average “to the general share return account announced by the Board” (genel hisse iade hesabı), also on a voluntary basis. The calculation period, the method for determining the amount to be returned and the other procedures and principles are to be set by the SPK. The Law was published in Official Gazette No. 33413 of 27 October 2026 and entered into force with effect from 17 September 2026; this provision is in force too. As at 5 November 2026 the SPK had not set the calculation period or the method, or announced the “accounts announced by the Board”. SPK decision 76/1903 of 27 October 2026 does not deal with these matters; its Article 11 only sets the order in which “amounts transferred to the general share return account” are distributed to the funds under liquidation: first the money market funds with the lowest coverage of interim payments and the largest number of investors whose net investment amount is below TRY 1 million, then, if any amount remains, the other funds on the same principles.

Before the Law, by its announcement of 1 October 2026, the SPK said that voluntary return accounts had been opened in the name of the TMSF, one for each fund, together with a general share return account, so that those who made “excessive gains” (fahiş kazanç) from redemptions before the liquidation decision could return those gains of their own accord to the fund concerned. Whether those accounts will be used as the “accounts announced by the Board” under the Law has not yet been announced. The accounts are not for payments to investors.

Official statements (as reported in the press). According to the 8th Fund Coordination Board statement (28 October 2026), “returns to the accounts opened with the TMSF are continuing”; no amount was given. Vice President Cevdet Yılmaz told the TBMM Planning and Budget Committee on 27 October 2026: “As of yesterday there is a repayment of TRY 11 billion” (Dün itibarıyla 11 milyar lira bir geri ödeme söz konusu; ANKA report). How much of this amount comes from voluntary returns and how much from other sources has not been stated; no TMSF or SPK announcement on this amount has been found.

21Does making a voluntary refund remove liability?

In the text of the Law (art. 4(4)) the return is “voluntary” (isteğe bağlı); there is no provision on the consequences of not making a return, on criminal liability or on effective repentance. The public bodies’ statement in the Planning and Budget Committee report (Report No. 294) said that the voluntary return mechanism “in no way results in amnesty, release or impunity” (af, ibra veya cezasızlık), that “the criminal and legal liability” (cezai ve hukuki sorumluluk) under Law No. 6362 and the Turkish Criminal Code of those who make returns continues, and that whether the provisions on effective repentance apply lies “exclusively within the discretion of the judiciary”; this is a statement by public bodies, not the text of the Law (unofficial translations).

In a statement on his social media account on 25 October 2026, the Minister of Justice, Akın Gürlek, said: “Making a voluntary refund does not, on its own, remove the legal liability of any natural or legal person. These refunds, which contribute to redressing the losses suffered, do not stand in the way of the conduct of the investigations or the assessment of the evidence.” He also said that the priority is for “the refunded amounts to reach the true rightholders” and that the source, timing and amount of the refunds and the way they are passed on to the true rightholders will be examined “meticulously” (as reported in the press by Hürriyet/DHA and Anka; unofficial translation). On 6 October 2026 the Minister had also said: “The perception that no action will be taken against those who have made good the loss is wrong” (Zararı giderenler hakkında bir işlem yapılmayacak algısı yanlış.; as reported in the press).

Related: Voluntary refunds · Law No. 7596

16 · Sources

Sources

Data cut-off: 5 November 2026. The sources are in Turkish. 59 primary and 28 press sources.

Show the list of sourcesSPK bulletins and announcements, TBMM records, BDDK, TEFAS, KAP · press

Primary

Press (secondary)

Tera Portföy THF / TP2 default: ekonomim.com, foreks.com (16.09.2026)
Hedef Portföy KAP statement (21.09.2026)
Takasbank statement: ntv.com.tr
Report of measures concerning six brokerage firms: bloomberght.com (22.09.2026)
Note on the “0” price on the MKK e-Yatırımcı screen: paraanaliz.com (25.09.2026)
Fund Coordination Board and State Supervisory Council inquiry: hurriyet.com.tr, foreks.com (29–30.09.2026)
Statement of the Centre for Combating Disinformation: haberturk.com (29.09.2026)
Bulls Portföy statements (funds outside the liquidation; payments of 8 October): dunya.com, foreks.com (06–07.10.2026); cnbce.com (08.10.2026)
Directorate of Communications statement: payments begin in 17 funds: foreks.com, evrensel.net (08.10.2026)
List of the 17 funds paid out: bloomberght.com (08.10.2026)
Statement of the Minister of Treasury and Finance on the 17 funds: ntv.com.tr (08.10.2026)
Sixth Fund Coordination Board statement: liquidation completed in 66 funds: ankahaber.net, dunya.com (18.10.2026)
Economic Coordination Board statement on interim payments: foreks.com, sondakika.com (19.10.2026)
Hedef Portföy statement: ordinary liquidation of 31 funds: yenisafak.com, cumhuriyet.com.tr (19.10.2026)
Hedef Portföy statement: payments in four funds: cnbce.com (20.10.2026)
Seventh Fund Coordination Board statement: 47 funds in liquidation, 18 of Hedef’s 31 funds completed: aa.com.tr (22.10.2026)
Minister of Justice, AA Editors’ Desk interview: voluntary refund accounts: istiklal.com.tr (06.10.2026)
Minister of Justice statement: voluntary refunds and legal liability: hurriyet.com.tr (DHA), ankahaber.net (25.10.2026)
Vice President, TBMM Planning and Budget Committee: interim payments to begin on Friday, mid-November target: karar.com (ANKA report), diken.com.tr (27.10.2026)
Eighth Fund Coordination Board statement (@iletisim): first interim payments expected to begin on 30.10.2026, 38 funds in liquidation: finans.cnnturk.com, memurlar.net (AA report) (28.10.2026)
First interim payments: 7 funds, 235,705 investors, TRY 29.3 billion: memurlar.net (Anadolu Agency report, 30.10.2026), sabah.com.tr (31.10.2026); fund codes: takvim.com.tr (30.10.2026)
Observation of TRY 250,000 payments based on individual account movements: birgun.net (31.10.2026)
Ninth Fund Coordination Board statement (03.11.2026): TRY 97.3 billion, 247,839 investors, interim payments to continue: aa.com.tr, cumhuriyet.com.tr
Total of TRY 117.6 billion, 446,040 investors (04.11.2026): foreks.com (Anadolu Agency report), cnnturk.com (DHA report)
DFI receipts (04.11.2026): yatirimx.com.tr
TEFAS records, 02–05.11.2026: tefas.gov.tr
SPK Bulletin 2026/78 (30.10.2026): 76/1918, equity ratio relaxation until 13.11.2026; no decision on the fund liquidation: spk.gov.tr
TEFAS records of 28.10.2026 and 02.11.2026: tefas.gov.tr

Information reported in the press should be checked separately against the institution’s own statement.

At a glance

Where things stand · 05.11.2026

When will the funds in liquidation be paid?

How will the interim payment be made? SPK decision 76/1903

A1 Capital, Bulls and Pardus

Hedef Portföy

Tera Portföy (THF, TP2, TLY, DOH and others)

Pusula and Atlas Portföy

Calculators: interim payment, pro rata distribution and time limits

Interim payment estimate (Law No. 7596 art. 4(2); SPK 76/1903 art. 6)

Pro rata distribution scenario

Deadline calculator

Which situation applies? Avenues by instruction status

All cases: by date and result of the instruction

Avenues of application under the legislation

Avenues of application under the legislation

Avenues of application under the legislation

Avenues of application under the legislation

Avenues of application under the legislation

Avenues of application under the legislation

Avenues of application under the legislation

Avenues of application under the legislation

Avenues of application under the legislation

Avenues of application under the legislation

Avenues of application under the legislation

Avenues of application under the legislation

Latest position: developments in the liquidation and payments

TEFAS 5 November: sharp portfolio falls in BSH and HIM; all values 0 in HPH and HDH

Payments continued: TRY 117.6 billion in total to 446,040 investors

9th Fund Coordination Board: TRY 97.3 billion as at 30 October; interim payments to continue this week

TEFAS 2 November: investor and unit counts unchanged in the money market funds; PPT portfolio ≈ −38%

First interim payments began: TRY 29.3 billion to 235,705 investors in 7 funds

SPK Bulletin 2026/78: no decision on the liquidation; equity ratio relaxation extended to 13 November 2026

8th Fund Coordination Board: first interim payments expected to begin on 30 October 2026

Tera Yatırım Menkul Değerler AŞ: activity permits cancelled; the YTM runs the compensation process

TEFAS 27–28 Oct: falls in HPH and HDH; a price published again for DFI

SPK 76/1903: procedures for the interim payment set (Tera, Pusula, Atlas)

Law No. 7596 published in the Official Gazette and in force

SPK temporarily suspends the activities of Tera Portföy and Pusula Portföy

Hedef Portföy: HPL falls to a residual in the TEFAS record of 26 October; partial falls in KSA, HPH and HKJ

Minister of Justice: a voluntary refund does not on its own remove legal liability

Hedef Portföy: distribution visible in three more funds in the TEFAS record of 23 October

Bill adopted: Law No. 7596

7th Fund Coordination Board: 47 funds still in liquidation

SPK: blocked units on equal terms with other unitholders

Hedef Portföy: distribution visible in 10 more funds on TEFAS

General Assembly adopts Articles 1–5; PBLK sentence added

Activities of three brokerage firms suspended

Hedef Portföy: payments made in four funds

Bill in the General Assembly: no article voted on 20 Oct

Committee report published (Report No. 294)

Payments in 23 more Bulls and Pardus funds; target for the interim payment

A1 Capital, Bulls and Pardus: liquidation completed in 66 funds

SPK 70/1821: Hedef funds moved to ordinary liquidation

Bill adopted by the Planning and Budget Committee

TRY 6.4 billion paid to 43,643 investors in 17 funds

Bill No. 2/3939 submitted to parliament

A1 Capital, Bulls and Pardus: payments in 17 funds

Government statement in parliament: interim payment tied to the bill

SPK statement on Borsa İstanbul notifications

SPK: the YTM asset-protection provision is not new

SPK Bulletin 2026/68: margin relief extended

Voluntary return accounts opened

Interim payment decision (64/1775)

A1 Capital, Bulls and Pardus: order of liquidation (64/1770)

Measures concerning Tera Yatırım and three banks

Instructions of 17 September: paid pro rata

Three points corrected in this note

The fund liquidation law: Law No. 7596 in force (Official Gazette 27.10.2026, No. 33413)

Voluntary refunds (gönüllü / isteğe bağlı iade): the text of the Law, the SPK accounts and official statements

Text of the Law · Law 7596 art. 4(4) · in force (Official Gazette 27.10.2026)

SPK announcement · 1 October 2026

SPK 76/1903 · art. 11 · general share return account

Committee report · Report No. 294 · public bodies’ statement

How does fund liquidation work? The regulatory framework

Stages of the liquidation · as at 05.11.2026

A/6: unexecuted redemption instructions

Institutions and avenues of application

Who does what?

Liquidator bank