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Payment Regime, Agreement and Ways of Objection in Liquidated Investment Funds by the CMB's Decisions dated 17 September 2026
This guide was updated as of 1 November 2026, based on Law No. 7596 and Resolution 76/1903 of the SEC, published in the Official Gazette dated 27 October 2026.
By decisions dated 17 September 2026, the Capital Markets Board (SPK) suspended TEFAS trading in and ordered the liquidation of more than 130 investment funds established by seven portfolio management companies. According to publicly reported figures, these funds' total value exceeds 800 billion Turkish lira and the number of unitholders exceeds 500 thousand.
Law No. 7596, which came into force on 27 October 2026, re-determined what value and in what order the payment would be made in these funds. If the liquidation cash is not sufficient, the investor will be paid not on the fund price but on the net investment amount updated according to inflation. A maximum of TL 1 million per fund has been stipulated. In this guide, the scope of the law, method of calculation, order of payment and ways of objection are explained step by step.
19 August 2026 The Istanbul Public Prosecutor's Office requested a review and document from the SEC due to unusual price movements in some shares.
28 August 2026 The SEC has limited the concentration of free funds in shares outside BIST 30: 5 per cent in one share, 20 per cent in total.
Early September Exits from the funds accelerated; sales pressure on low-liquidity stocks became a payment problem.
17 September 2026 The SEC closed the funds of A1 Capital, Atlas, Bulls, Target, Pardus, Compass and Tera portfolio management companies and decided to liquidate them.
30 September 2026 The SPK has decided to pay the agreed shareholders up to TL 1 million in breaks (64/1775).
1 October 2026 The SPK announced that the TL 1 million interpayment ceiling would be implemented separately for each fund.
22 October 2026 Law No. 7596 was adopted at the General Assembly of Parliament.
27 October 2026 The law was published in the Official Gazette; the CMB determined the procedures and principles of liquidation and payment on the same day by resolution 76/1903.
2. What Funds Does Law No. 7596 Cover?
The law applies to uncompleted investment funds (m.1/1, m.2/1-b) which have been decided to be liquidated by the resolutions of the CMB dated 17/9/2026 and on the date of publication of the law. The legislator has explicitly written that this is an exceptional regime: no general or continuous liquidation and liability scheme has been established for other investment funds (m.1/2).
This is one of the first points to be discussed in objections to his method.
Fund share ownership, which is entitled to receive payment, is determined on the basis of funds and accounts as a result of the agreement between the records of the institution in charge of liquidation and the Central Register (MKK) records (m.3/5).
In practice, the most questions are related to investors who can't get their money by ordering sales. According to the law, persons who have been forwarded to TEFAS before and after September 17, 2026 but whose shares are blocked in unfulfilled instructions due to the default of the fund or the lack of disclosure of the share price shall be considered shareholders of the funds and subject to liquidation provisions. Prior to the Act, some of these instructions had been given priority in the form of the CMB; and the law explicitly held these persons as shareholders. Therefore, the investor's first job is to document in which category his or her instruction is evaluated.
4. On What Value is Payment Made?
1. If the liquidation cash is sufficient: the payment shall be made by multiplying the principal share amount to the payment by the current unit share price as of the end of the day before the liquidation decision (16 September 2026).
2. If the liquidation cash is insufficient: it is based on the net investment amount of each investor, not the share price in payments (m.4/1).
There is a strong possibility that the second possibility will occur in funds whose portfolio is concentrated in low-liquidity stocks. In this case, there may be a difference between the last fund value that the investor sees on the screen and the amount it will receive. It is a separate matter of who and in what way this difference may be requested; the compensation routes have been discussed in the "Fon Victims Compensation Case" guide at the Information Pool.
5. How is Net Investment Amount Calculated?
The MKK calculates the net investment amount. The method is described in the law as follows:
• Every cash entry made by the investor into the fund and every cash outflow received from the fund is updated from date of transaction to date of liquidation.
• In the update, the arithmetic average of the change rates in the domestic producer price index (YI-ÜFE) with the consumer price index (TÜFE) announced by TÜIK is applied on a day basis (Küstelyevm).
• If the total of updated entries is greater than the outputs, the outputs are deducted from the inputs on the basis of the first entry.
• The net investment amount of an investor who has previously attracted more than his principal can be zero.
An investor invested TL 400,000 in January 2026, TL 200,000 in May 2026, and withdrew TL 150,000 in July 2026. Index rates are for narration only; actual rates apply MKK.
Net investment amount: 480,000 + 220,000 TL 159,000 = 541,000 TL Non-indicated to intermediate payment: 400,000 + 200,000 TL 150,000 = TL 450,000
This investor may receive a maximum of TL 450,000 in interim payments if the following other conditions are met; his remaining right is assessed at the final payment.
4 of the Act. When the second and third paragraphs of the article are read together with the resolution 76/1903 of the SEC, the table reads as follows:
Ceiling If the net investment amount is less than TL 1 million, that amount is as much as TL 1 million and if it's over, it's a maximum of TL 1 million. 7596 s.K. m.4/2
Basic without index The upper limit of the intermediate payment is the unindexed part of the net investment amount. m.4/2
Application per fund The ceiling works separately for each fund; the investor who has a share in more than one fund is evaluated separately for each fund. SPK announcement, 1.10.2026
Account value limit Intermediary payment, except for money market funds, cannot exceed the end-of-the-day value of shares in the account. m.4/2
If cash is not enough The SEC may decide to pay or pay everyone the same minimum amount, starting with the lowest net investment amount. m.4/3
Priority The title starts with funds with the phrase "money market"; funds with a low welcome rate and a large number of investors under TL 1 million are put forward. SPK 76/1903
Payback and deduction The share is not returned in exchange for the intermediate payment; the shares are returned in the final payment, and the intermediate payment is deducted from the final amount. m.4/3, m.4/5
The first intermediate payments were predicted to start on October 30, 2026. The payments are planned to be transferred to the retention accounts of the agreed-upon investors.
7. Who Can't Be Paid?
There is no payment from the liquidation and retrieval account to persons and institutions that the CMB has identified as operating the acts of market disruptor action (SPKn m.104), information abuse (m.106) or market fraud (m.107) through these funds, in conjunction with funds or with a subsidiary of funds (7596 s.K.). m.3/6).
In terms of the presumption of innocence and property rights, this provision is expected to come before the judiciary in a later period.
Those who return their shares before the liquidation and receive returns on inflation may optionally return the excess to accounts declared by the SEC. A separate general share return account is also stipulated (m.4/4) for those who profit from the shares subject to manipulation. This extradition is not mandatory; however, if it is found that there has been unlawfully devalued from the fund assets, it is about those responsible 5. It operates a separate and compulsory collection regime in the article.
9. Recovery Account: To Whom Do the Later Collected Coins Go?
• The portfolio management company is primarily responsible for damages arising from values that are unlawfully deducted from the fund, and if they cannot be collected, the persons designated by the CMB are personally liable (m.5/2).
• The Collection Savings Deposit Insurance Fund (TMSF) makes the collection in its manner (m.5/4).
• The values confiscated in the criminal investigation can be returned to the fund; for those who cannot be transferred to the fund, the TMSF may be a trustee (m. 6/1-2).
• The values that are agreed to allow and correspond to the loss of funds are not transferred to the Treasury but to the fund or to the recovery account (m.6/3).
• The retrieval account is held separately for each fund, cannot be foreclosed and paid only by the Investor Compensation Centre (YTM) to the shareholders of that fund (m.6/4-6).
This structure indicates that the final payment may not be a one-off. Records showing entitlements must be stored for a long time, as recoverys can spread over years.
CMB decisions are administrative action. A lawsuit may be filed in the administrative court against these decisions, and these cases are considered to be of hasty business (SPKn Art. 134). The time to file a lawsuit is, as a rule, 60 days from the notification or announcement of the decision (Art. 7).
If there is a record error in the net investment amount calculated by the MKK, a documented written application must be made to the liquidation authority and the CMB first. A more fundamental discussion relates to the method itself: based on the amount of investment indexed instead of the published fund price, 35 of the Constitution. It is open to debate in terms of the right to property and Protocol No. 1 to the European Convention on Human Rights. This claim is qualified to be carried through appeal to the Constitutional Court in a concrete case.
Retired teacher Ayşe Hanım has a share of TL 1,300,000 in a money market fund that was liquidated. On September 15, 2026, he gave a sales order of TL 300,000, the instruction was forwarded to TEFAS but it did not happen due to default of the fund and his shares were blocked. Over the years, he has invested a total of TL 1,100,000 in the same fund and attracted TL 200,000.
Due to the unfulfilled instruction, Ms. Ayşe is not a separate creditor but is considered a shareholder of funds under Art.3/5 of Law No. 7596. Since the net investment amount without index is TL 900,000, the interpayment ceiling is TL 900,000 for itself; since there is a money market fund, the account value limit is not applied. The indexed net investment amount is based on the final payment. A comparison of their registration with the MKK account, a written application must be made with the receipt if there is an incomplete entry, and a 60-day trial period should be monitored against CMB decisions.
My fund has been liquidated, is my money gone completely?
Oh, no. In liquidation, fund assets are converted into cash and distributed at the share rate. If cash is not enough, the payment will be made over the net investment amount updated according to inflation. The values collected afterwards are also transferred to the shareholders through the recovery account.
Do I also need to apply for a break payment?
The law and the CMB procedure stipulate that payments will be transferred to deposit accounts of completed investors. Nevertheless, the consensus result and the calculated amount must be checked.
I have a share in multiple funds, is the TL 1 million limit total?
Oh, no. The SPK announced that the ceiling would be applied separately for each fund.
I ordered a sale before September 17, but my money didn't show up. What's my status?
If the instruction has been forwarded to TEFAS and the shares have been blocked, by law, the fund is considered a shareholder and payment is taken in accordance with the liquidation provisions (m.3/5).
I got a break payment, and can I file for compensation?
Yeah. The law has not closed other legal ways; payments received by other means are deducted in the final payment (m.4/5).
Why is my net investment amount zero?
The net investment amount could be zero if the investor withdrew more than its inflation-updated principal before liquidation.
• Failure to collect transaction records: The net investment amount is based on the date of each entry and exit; account error cannot be contested without receipts and extracts.
• Failure to document the value of September 16: Payment in funds where liquidation cash is sufficient depends on the share value at this date.
• Missing 60 days of litigation: The administrative trial period against non-payment or procedural decisions is short.
• Considering the intermediate payment to be the final result: the intermediate payment is a advance subject to set-off; the remaining claims for rights and compensation must also be monitored.
• Relying on paid "money-saving" promises: The Attorney General's Office has announced that untruthful sharing will be assessed under TCK Art.217/A; it also sets the stage for fraud attempts targeting victims for a second time during crisis periods.
Law No. 7596 established an exceptional scheme that drew the investor's take in liquidation funds from the value of the on-screen fund to the actual amount of investment updated by inflation. In this scheme, the most powerful tool in the investor's hands is his or her transaction records; every error in the calculation and any decision to opt out of payment can only be corrected by objecting with these records and within their duration.
Küheylan Law Firm; consensus and net investment amount control in the funds under liquidation, administrative application against CMB decisions and litigation processes, and legal to investors in planning the path to compensation for the damage left after liquidation
Important Legal Notice: The statements, tables and fictional script contained in this guide were prepared by Küheylan Law Office for general information based on the current legislation and public official statements as of November 1, 2026. The text is not a legal advisory nature; the circumstances of each concrete event, the type of fund and the phase of liquidation may change the path to follow. The current situation must also be confirmed, as the legislation and CMB decisions change rapidly. © 2026 Küheylan Law Office.
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