Türkiye's regulator sets interim payout rules for funds in liquidation

Türkiye's Capital Markets Board set the rules on 27 October for paying investors in some of the funds it ordered into liquidation in September, starting with money market funds and capping each interim payment at TRY 1 million, its bulletin 2026/76 said.

The board acted under Law 7596 on certain investment funds ordered into liquidation, adopted on 22 October and published in the Official Gazette on 27 October. Article 3 of the law gives the board the power to set the stages of liquidation, the valuation rules, interim and final payments and the order of distribution. Its decision, 76/1903, came the same day, with a ten-question guide in a press release. This explainer sets out the rules from those three documents.

Whose funds, and who runs the process

The decision covers the funds founded by Tera Portföy Yönetimi, Pusula Portföy Yönetimi and Atlas Portföy Yönetimi among those the board ordered into liquidation on 17 September. Ziraat Bankası will liquidate the Pusula and Atlas funds and İş Bankası the Tera funds. The board coordinates the work with the Savings Deposit Insurance Fund, Borsa İstanbul, the Central Registry Agency (MKK), Takasbank and the banking regulator, the bulletin said.

How much is paid, and in what order

Interim payments start with funds whose names include "money market". An investor's interim payment from each fund may not exceed the net investment amount, which MKK calculates without indexation, or TRY 1 million. For funds other than money market funds, Law 7596 also caps it at the total value of the investor's units at the end of the day before the payment is calculated. Where a fund's distributable cash cannot cover every interim payment, each investor receives no more than the lowest of three figures: the net investment amount; the amount calculated as of the end of the day before 17 September for money market funds, or before the calculation date for other funds; and the TRY 1 million ceiling.

Among the other funds, payments begin with the fund whose distributable cash covers the largest share of its total interim obligation. Where funds have the same or similar coverage, the banks put first the fund in which the available cash pays the most investors. Where a fund's cash cannot cover the total of its interim amounts, the board may approve ordering payments from the smallest interim amount to the largest, and/or a minimum amount for every holder, so that payments reach as many investors as possible.

If a fund's cash covers the full value of its units at the price of the day before the liquidation decision, investors receive a final payment instead of an interim one. Where cash does not cover that value, the law has MKK calculate each investor's net investment amount for payments from the liquidation balance by indexing each cash flow into and out of the fund to the average change in the consumer and domestic producer price indices.

What an interim payment does not settle

Interim payments are made without redeeming investors' units. Units are returned only at the final payment, and interim amounts are deducted from what an investor is finally owed. Money moved to the general share refund account goes first to the money market funds with the lowest coverage and the most investors with a net investment under TRY 1 million, the bulletin said.

No payment is made from the liquidation and recovery account to persons or institutions that the board determines committed, or acted together with the funds in, acts covered by Articles 104, 106 or 107 of Capital Markets Law 6362, the law says. Under the decision, the bar applies once MKK has notified the liquidating institutions.

The board's other recent rule change raised the professional client asset test to TRY 50 million. The parliamentary route to the new law is set out in the October governance briefing on Türkiye.