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About a month has passed since the decision, taken by the Capital Markets Board (SPK) in its decisions dated 17 September 2026, to liquidate 131 investment funds belonging to 7 portfolio management companies (Tera, Pusula, Hedef, Atlas, A1 Capital, Pardus and Bulls). In this process, which directly concerns 455,758 investors, there have been three significant developments: the first payments have been made, the criminal investigation has widened, and on the night of 14 October 2026 the Bill on Certain Investment Funds Resolved to Be Liquidated was adopted by the Plan and Budget Committee of the Grand National Assembly of Türkiye (TBMM). In this article, we summarise what investors holding money in the funds need to know as of today.
About a month has passed since the decision, taken by the Capital Markets Board (SPK) in its decisions dated 17 September 2026, to liquidate 131 investment funds belonging to 7 portfolio management companies (Tera, Pusula, Hedef, Atlas, A1 Capital, Pardus and Bulls). In this process, which directly concerns 455,758 investors, there have been three significant developments: the first payments have been made, the criminal investigation has widened, and on the night of 14 October 2026 the Bill on Certain Investment Funds Resolved to Be Liquidated was adopted by the Plan and Budget Committee of the Grand National Assembly of Türkiye (TBMM). In this article, we summarise what investors holding money in the funds need to know as of today.
The First Payments Have Been Made, but Not for Everyone
In its announcement dated 1 October 2026, the SPK declared that an interim payment would be made to investors whose reconciliation has been completed, without waiting for the liquidation to be completed. Accordingly, the interim payment will be made on the basis of the net investment amount that the Central Securities Depository of Türkiye (MKK) will calculate for each investor, and a maximum of TRY 1 million will be paid to each investor, separately for each fund. Investors whose net investment amount is below TRY 1 million will receive the whole of that amount. It must be emphasised that no redemption of participation shares is made against the interim payment; the shares will be redeemed only at the time of the final liquidation payment.
In this context, on 8 October 2026, the payments of 43,643 investors in 17 funds belonging to A1 Capital, Bulls and Pardus were transferred by Ziraat Bank to the relevant bank and brokerage accounts. By contrast, no definite payment date has yet been announced for the Tera, Pusula, Hedef and Atlas funds. The Government has stated that it aims to make payments to the vast majority of investors within October.
What Does the Bill Bring?
The bill adopted by the Committee will apply only to the funds resolved to be liquidated by the SPK's decisions dated 17 September 2026; it does not create a general liquidation or liability regime for other investment funds. The provisions that stand out from the investors' perspective are as follows:
The net investment amount will be adjusted for inflation. If the cash obtained from the sale of the fund assets is insufficient to satisfy investors' claims, the amount on which payment is based will be found not on the basis of the fund price, but by adjusting each amount that the investor actually paid into and withdrew from the fund by the average of the rates of change of the Consumer Price Index (CPI) and the Domestic Producer Price Index (D-PPI) and offsetting them on a first-in, first-out basis. In other words, in the event of insufficient cash, the protection will relate not to the fund's return, but to the principal adjusted for inflation.
The interim payment gains a statutory basis. The interim payment, capped at TRY 1 million, is being elevated to the level of statute. If the cash is insufficient to cover all payments, the SPK will be able to decide that payments are made starting with the investor with the lowest net investment amount, or that a minimum amount applicable to everyone is set.
No payment will be made to those involved in manipulation. To persons and institutions determined by the SPK to have taken part, together with these funds, in market fraud, abuse of information or market-disrupting acts, no payment will be made from the liquidation and recovery account.
Managers will be personally liable. For loss arising from assets transferred from the fund's assets to related persons unlawfully or without a genuine economic purpose, the portfolio management company will be liable first; if the amount cannot be collected, the natural and legal persons determined by the SPK will be held personally liable. Leaving office will not remove the liability. Upon notification by the SPK, the Savings Deposit Insurance Fund (TMSF) will pursue these receivables by the procedure for public receivables.
Seized assets will return to investors. Assets that are seized or confiscated within the scope of the criminal investigation and that are determined to be connected with the fund will not be recorded as revenue of the Treasury; they will be transferred to the relevant fund or to the recovery account held at the TMSF. The TMSF will be able to sell assets such as real estate without waiting for the outcome of the case. The amounts in the recovery account cannot be attached and may be used only for payments to investors.
Voluntary refund for those who obtained excessive gains. Persons who obtained returns above inflation by selling their shares before the liquidation will be able to return this surplus voluntarily to the accounts announced by the SPK.
The Criminal Investigation Is Widening
In the investigation conducted by the Istanbul Chief Public Prosecutor's Office, the Chairman of the Board of Tera Portföy and the CEO of Tera Yatırım were arrested on 1 October 2026. According to information reported in the press, as of 14 October 2026 the number of persons in detention has reached 86, and the assets of a large number of persons have been seized. Taking into account the seizure provisions of the bill, the assets seized in the investigation may become an important source of the payments to be made to investors in the coming period.
What Should Investors Do Now?
First of all, since payments are calculated on the basis of the net investment amount, it is of great importance that you keep the receipts and account statements for all your deposits into and withdrawals from the fund. We recommend that you check the accuracy of the calculation by comparing the payment made to your account with the MKK records.
Secondly, it should be remembered that the bill has not yet become law, that it will enter into force once it has been debated in the General Assembly of the TBMM and published in the Official Gazette, and that during this process the provisions may change. The remedies available in cases such as a shortfall in payment, an erroneous calculation or non-payment, as well as claims based on the duty to inform of the bank or brokerage firm that sold the fund, should be assessed separately according to the particulars of the specific case.
Finally, investors should rely only on statements by the SPK and official institutions and be wary of persons who make contact with promises such as "we will get your money back quickly". To protect your rights, following the process together with a law firm that is your point of contact and takes on responsibility will prevent losses of rights that would be difficult to remedy later.
