A new law has come into force for investors who cannot withdraw the money they invested in funds. Law No. 7596, published in the Official Gazette on October 27, 2026, regulates the conversion of remaining fund assets into cash, the recovery of values unlawfully withdrawn, and the payment of collected amounts to investors. (Law No. 7596)
However, the enactment of the law does not mean that everyone will immediately receive their full amount. The amount an investor can receive will depend on which fund they are in, their past transactions, the assets the fund holds, and how much money can be recovered from those responsible.
For this reason, it is not enough for victims to simply wait for payment. They must first check their records, learn the calculation made for them, and contact the appropriate authority if there is a problem.
What happened first
By decisions dated September 17, 2026, the CMB decided to liquidate 131 funds belonging to seven portfolio management companies. In its September 23 announcement, the CMB stated that these funds had 455,758 investors. This number represents the investor count announced on that date; it does not mean everyone suffered the same loss. (CMB investor count announcement)
Liquidation is the process of closing a fund, selling its assets, determining its debts and receivables, and distributing remaining funds to entitled parties.
An important distinction exists here: placing a fund in liquidation does not necessarily mean the company managing it is completely shut down. Suspending the company's operations, appointing a receiver to the company, the company's bankruptcy, or the company's liquidation are separate proceedings.
How the problem known publicly as a fund heist emerged
CMB announcements point to price movements in shares of companies with low trading volumes that cannot be explained by economic data in certain funds. Unsecured borrowing between related parties and artificial calculation of fund values are also among the disclosed problems. (CMB examination announcement)
We can understand how the system could cause damage as follows: the price of shares held by a fund is inflated through related transactions. The fund value calculated based on these shares also increases. The investor sees a high amount in their account. However, when all shares are to be sold, buyers may not be found at the same price.
Another possibility is that fund money is transferred to other persons or companies through transactions that do not actually benefit the fund. The new law also aims to recover values withdrawn in this manner. (Law No. 7596, art. 5)
These explain how examined transactions could cause damage. Which specific person committed which crime will be determined based on evidence and trial outcome. Obtaining high returns or exiting the fund early does not by itself prove a crime was committed.
Did the new law repeal all previous decisions
No. The law does not collectively repeal all previous CMB decisions. It introduces new payment and collection rules to the liquidation process already underway.
If old decisions conflict with the new law, the new law prevails. Implementation details from previous decisions that are consistent with the law and have not been subsequently changed may be used. (Law No. 7596, art. 3 and 7)
For example, the interim payment application up to 1 million TL had been announced for certain funds even before the law. The new law regulates this application and sets its limits. Therefore, reading an old announcement alone to determine today's final payment amount or priority would be incorrect. (September 17 liquidation decision; September 30 interim payment decision)
The law specifically clarifies the following matters:
If funds are insufficient, by what method will the investor's receivable be calculated?
Which persons and companies will not receive payment?
From whom and how will values withdrawn outside the fund be recovered?
How will money found after liquidation is completed reach investors?
Which investors does the law cover
The law covers funds that were not yet liquidated as of October 27, 2026, among those whose liquidation was decided by the CMB's decisions dated September 17, 2026. It does not apply to all investment funds. (Law No. 7596, art. 1)
For this reason, the first step a victim should take is to learn the fund's name and code and check whether it is within the scope.
Persons who issued a sale instruction on or before September 17 but whose transaction did not occur because the fund could not make payment or did not disclose the share price, and whose shares were blocked, are also subject to the liquidation provisions in the law. Having issued a sale instruction does not by itself ensure payment is made first. The priority provisions in old decisions must now be evaluated together with the new law. (Law No. 7596, art. 3/5; September 17 liquidation decision; CMB PBLK announcement)
Can the full amount shown in the account be recovered
Not in every case. If the fund's money does not cover the final share value calculation specified in the law, the calculation based on the amounts the investor actually deposited and withdrew comes into play. (Law No. 7596, art. 4/1)
For example, consider someone who deposited 10 million TL into the same fund. After some time, they withdraw 12 million TL. They set aside the 2 million TL they earned and deposit 10 million TL again. The second time they also withdraw 12 million TL and deposit 10 million TL again. However, they cannot withdraw the last amount they deposited.
This person's total deposits are 30 million TL and total withdrawals are 24 million TL. Setting inflation aside for now, the difference is 6 million TL.
So even if 10 million TL appears in the account as their last deposit, the 4 million TL gain they withdrew in earlier periods is not disregarded. Calling withdrawn money "profit" does not exclude that amount from the calculation.
However, this example does not necessarily mean 6 million TL will be paid. In the actual calculation, the date of each deposit and withdrawal will be considered; amounts will be updated to the liquidation date using the average of CPI and domestic PPI changes. MKK will perform the calculation. (Law No. 7596, art. 4/1)
Will everyone receive 1 million TL
No. This amount is the interim payment ceiling for investors meeting the conditions. It is not an amount everyone will necessarily receive.
Interim payment is payment made before the process is completed and deducted from final payment. The unindexed net investment amount limit in the law and the rules on applicable share value and cash sufficiency are evaluated together. The fund-specific limits and calculation dates in the CMB's October 27 announcement are shown separately in the section below. (Law No. 7596, art. 4/2–3)
On the other hand, 1 million TL is not the upper limit of total collection rights. Additional payments may be made as assets are sold or money is recovered later.
How liquidation and payments will be made according to the CMB announcement
As stated in the CMB's October 27, 2026 announcement titled "Procedures and Principles Regarding Liquidation and Payments in 10 Questions," the application under decision 76/1903 will be as follows. CMB's 10-question announcement
Scope and authorized banks: The announcement addresses the relevant funds of Tera, Pusula, and Atlas. Tera's liquidation is being conducted by İş Bankası, and Pusula and Atlas's by Ziraat Bankası. Priority is given to money market funds.
Interim payment: The unindexed net investment amount limit and 1 million TL limit are applied on a fund basis.
If cash is insufficient: The net investment amount does not exceed the lower of the relevant share value and 1 million TL. For share value, the close of business before September 17 is used for money market funds, and the close of business before calculation for others. The payment order or minimum payment method is subject to CMB approval.
Final payment: If cash at the close of business before liquidation multiplied by the unit price and the number of shares subject to payment covers the total, final payment is made directly. Shares are not taken in interim payment; they are returned in final payment.
Payment exclusions: No payment is made to those identified by the CMB as having committed or acted jointly in the related acts specified in the law and reported by MKK.
General share returns: Priority is given to money market funds with low coverage ratios and investors with net investment below 1 million TL. The same principles apply to other funds with remaining amounts.
This application announcement is not the same as the law's general scope. An investor with multiple funds must check each fund separately; a fund-specific ceiling does not mean exactly 1 million TL will be received from each fund. Base payment on the amount specific to your account, cash sufficiency, and announcements from the authorized entity.
Can a company that used inside information or participated in manipulation also receive payment
A different rule applies here.
A person or institution identified by the CMB as having committed or acted jointly in manipulation, misuse of information, or the specified market-distorting acts within the fund connection will not receive payment from the liquidation and recovery account. (Law No. 7596, art. 3/6)
Therefore, in our example, if the investor is a company and falls within the payment exclusion, the presence of principal in the account does not entitle it to payment.
However, mere rumor or investigation is not sufficient. The identification and connection required by the law must exist. The provision does not require a final criminal conviction. A company executive's own transaction does not automatically place the company in the same situation; the company's connection must be separately determined. (Law No. 7596, art. 3/6; Capital Markets Law)
If company owners are detained, from whom will money be collected
Detention does not eliminate responsibility or debt. Additionally, the new law establishes a collection system that does not require each victim to individually pursue those responsible.
First, the fund's existing assets will be converted to cash. For values unlawfully withdrawn, those responsible will be identified under the law's conditions and TMSF will conduct collection proceedings. Assets seized in criminal files may also be used in this process if conditions are met. (Law No. 7596, art. 5–6)
A payment method is also established for money found after liquidation is completed. However, TMSF and the Investor Compensation Center taking on duties does not mean the loss will be covered from these institutions' own budgets.
The legal path a victim should follow step by step
It is not necessary for each investor to separately file a lawsuit or file a criminal complaint to qualify for liquidation payment. Entitlement is determined based on records. The following written applications serve to identify record and calculation errors and document claims; they should not be evaluated as a single mandatory application form prescribed in the law for everyone.
1 Determine the fund's scope and responsible entity
Obtain the fund's full name and code from your bank or broker. The law's scope is not the same as the scope of a specific interim payment decision. The September 17 decisions, the fund's liquidation status, and current CMB decisions must be checked together. It should not be assumed that a fund placed in liquidation later is automatically included in the special law.
2 Gather all records from initial investment to today
Keeping only the current portfolio screen is not sufficient. Obtain all cash deposits and withdrawals, purchases and sales, fund share transfers, and unexecuted orders in chronological order. Create a separate transaction file for each fund. If you use multiple banks, evaluate records together; do not count the same money's movement between accounts twice as if it were a new investment.
3 Check your entitlement and MKK reconciliation
Ask the entity where the fund was purchased and the entity conducting liquidation whether your share count matches MKK records. If there is a difference in account holder, fund code, or share count, request written correction with supporting documents. If there is inheritance, representation, joint account, attachment, or account blocking, clarify its effect on the payment process separately.
4 Separately document any unexecuted sale order
Obtain the date of the TEFAS instruction on or before September 17, 2026, the order number, the reason for non-execution, and share blocking information. An investor meeting the conditions in art. 3/5 of the law is subject to the liquidation regime. The existence of a sale order does not by itself create a payment right ahead of everyone else.
5 Submit your written information and payment request
Learn from the liquidating entity your entitlement, the amount calculated for you, your interim payment scope, whether any documents are missing, and the payment method. Base your IBAN or new account opening only on the authorized entity's official instructions. Make your application through a channel that provides proof of delivery and keep the reference number.
6 Request the calculation statement and object to errors specifically
Point out missing deposits, duplicate withdrawals, incorrect dates, wrong share counts, or double deduction of previous payments separately. Distinguish between indexed net investment amount and unindexed amount used in interim payment. First request correction from the liquidating entity; also report matters requiring regulatory review to the CMB. The fact that the law does not establish a single general objection period for investors does not mean there is no period for reported transactions or notifications.
7 Track your interim payment scope and remaining receivable
Check your interim payment entitlement, the fund's cash position, and payment order. Do not evaluate the 1 million TL interim payment ceiling as the ceiling of final receivable or a government guarantee. Record which fund and which account each payment you receive is for; verify that the remaining receivable is adjusted accordingly.
8 Report any irregularity to the CMB with evidence
In your complaint, clearly identify the fund, transaction, date, relevant person or entity, and your claim with supporting documents. Request investigation of fund loss and those responsible. In the law's special collection mechanism, the CMB identifies those responsible and amounts and reports them to TMSF; the investor does not initiate public debt collection under Law No. 6183 in their own name.
9 If there is criminal suspicion, contact the prosecutor's office
If there is concrete criminal suspicion and evidence, contact the Chief Public Prosecutor's Office. If the number of an ongoing investigation is known, submit your victimization and documents to the relevant file. Mention any previous applications describing the same event. The special rule regarding written application to the CMB under Capital Markets Law crimes must also be considered. Filing a criminal complaint is not a transaction that directly and definitively provides money repayment.
10 Request protection of assets and return to the fund
By showing concrete evidence in the criminal file, you may request evaluation of asset seizure if legal conditions are met; assets determined to belong to the fund may be requested to be transferred to the relevant fund or recovery account. The competent judicial authority makes the decision. Not all seized assets are distributed one by one to the first applicant investor. If criminal proceedings are filed, your status as a person harmed by the crime and your request to join the proceedings should also be evaluated.
11 Determine whether a separate compensation lawsuit is necessary
If there is misleading sales, breach of contract, unauthorized transaction, or other personal injury claim, separately identify the counterparty and legal basis. Banks, custodians, managers, and partners have different responsibilities; obligation, breach, damage, and causation must be examined for each. The fund's collective loss recovery must be separated from the investor's personal damage claim. The competent court, if necessary, evaluates mandatory mediation as a condition of suit and statute of limitations according to the specific relationship.
12 Examine rejection decisions and documents to be signed
If payment is not made, request the written reason: record error, cash insufficiency, calculation dispute, or payment exclusion require different legal remedies. The place to apply may differ between public proceedings and private law disputes. The Istanbul administrative courts jurisdiction in art. 5/4 of the law is not a general rule for all investor lawsuits. Before signing documents containing release, settlement, assignment of receivable, or waiver, examine them. Also track post-liquidation recovery efforts.
The legal basis for these steps is primarily articles 3 through 7 of Law No. 7596 and general provisions applied according to the nature of the claim. Law text
Which legal remedy applies to which situation
Problem encountered | Possible remedy |
|---|---|
If a person or entity's unlawful conduct causes damage | Compensation lawsuit against those responsible. Mediation first if necessary. |
If there is suspicion of fraud, manipulation, or another crime | Contact prosecutor, submit evidence to existing investigation, and join criminal proceedings if conditions are met. |
If payment is excluded due to an unlawful decision by a public authority | Administrative lawsuit against the decision; separate damage claim if conditions are met. |
These remedies are determined by examining the nature of the claim and conditions of suit. The special rule requiring the CMB's written referral to the prosecutor in capital markets crimes is also considered. (Capital Markets Law, art. 115; Turkish Commercial Code; Administrative Procedure Law)
If a lawsuit must be filed against a company, the detention of its owners does not prevent this. The company retains legal existence while liquidation continues; representation is determined by the liquidator's or receiver's authority if one exists. If individuals have separate responsibility, they may also be sued. However, merely being a company owner does not automatically create personal liability for every loss. (Turkish Commercial Code, art. 533 and 553)
Complaining to the CMB does not replace a compensation lawsuit. In complaint review, the CMB evaluates compliance with regulations; this application alone does not provide a decision regarding payment of your loss. (CMB application guide)
Do not miss lawsuit deadlines while waiting for payment
The continuation of liquidation or criminal investigation does not suspend all lawsuit deadlines. Applying to CİMER or another entity does not always protect the deadline.
Therefore, while tracking liquidation payments on one hand, the investor should verify lawsuit deadlines on the other. Receiving interim payment does not mean waiving remaining claims. However, any settlement or "I have no other claims" document presented separately should be examined before signing. (Law No. 7596, art. 4/5; Administrative Procedure Law)
Questions you must answer before legal action
Coming to your first meeting with an attorney with the following information will allow faster and more accurate file evaluation. Do not guess at answers you do not know; specify which record must be obtained from which entity. If you have multiple funds, prepare investment and payment information separately for each fund.
Identity and account ownership
1 What are your name, surname, and contact information where you can be reached?
2 Are you applying in your own name, on behalf of your company, or on behalf of another person?
3 In whose name is the investment account registered; is there a joint account, inheritance, or representation situation?
4 Are you working with another attorney on the same matter; is there an existing power of attorney or lawsuit?
Investment and money movements
5 What are the full names and codes of the funds?
6 Through which banks or brokers did you purchase the funds?
7 On what dates and in what amounts were your initial and subsequent additional investments made?
8 How much total money did you invest in each fund?
9 How much total money have you withdrawn or received as payment from each fund to date?
10 How many shares currently appear in your account and what amount?
11 Is the loss you reported the money you invested and could not withdraw, the current portfolio value, or does it include expected returns?
12 Did you acquire shares through transfer, gift, or inheritance other than purchase; were there inter-account transfers?
Sale instruction and access to funds
13 Did you issue a sale instruction; what is its date, time, amount, and order number?
14 Did the order execute, wait, or get cancelled; were shares blocked?
15 When did you first learn you could not access the money and what reason was given to you?
16 Who directed you to delay the sale, cancel the order, or keep the investment; is there a record?
Liquidation and payment records
17 What notifications did you receive about liquidation?
18 Did the liquidating entity provide information about your entitlement or net investment amount?
19 Is there a difference in amount or share count between MKK and bank records?
20 For which fund, when, and how much interim payment or return did you receive?
21 Did you object to the calculation; is there written justification for underpayment or rejection?
22 Were you asked for approval, release, settlement, or waiver; did you sign any document?
Recommendation and fund sale
23 Who recommended the fund; a bank employee, advisor, manager, social media account, or another person?
24 Were you promised principal protection, specific returns, or the ability to sell whenever you wanted?
25 What contract and risk disclosures were provided; how were your investor profile and qualified investor status, if any, determined?
26 Did you make the decision yourself; was your account managed by an advisor or portfolio manager?
27 Do you have messages, emails, advertisements, presentations, or existing call recordings showing promises or recommendations?
Applications and existing files
28 On what dates did you contact the bank, liquidating entity, CMB, or CİMER; do you have responses?
29 Is there a criminal complaint, investigation, statement, or notification?
30 Is there a lawsuit, enforcement, or mediation file; what is its number and stage?
31 Did you receive a discounted payment, settlement, or assignment of receivable offer; did you accept?
32 Is there a recently notified decision or notification containing a deadline?
Relationship and expectations specific to your file
33 Do you have a working, partnership, or consulting relationship with the fund founder, managers, or related companies beyond investing?
34 Did you receive non-public information or trading recommendations before public disclosure; what is the source and content?
35 Did you recommend other investors; did you receive commission, bonus, or other benefit?
36 Were you asked to explain your transactions; was an investigation or payment restriction notified?
37 Which of the following are your priorities: payment tracking, calculation objection, compensation, or criminal file follow-up?
38 Do you have credit interest or other additional damage; are there documents showing this?
Questions about relationships and transaction information do not contain a presumption of guilt. The purpose is complete legal evaluation. Investigation or inquiry information should not be withheld from your attorney; merely having obtained gains does not by itself prove irregularity.
Which documents should be in your application file
Identity and representation documents: Identity information, representation authority for company applications, relevant documents if inheritance is involved, and existing power of attorney information if any.
Complete transaction history: Fund and cash account statements from initial investment to today, all deposit and withdrawal receipts, purchase and sale records, and transfer records.
Share and order records: MKK records, current share count, unexecuted sale instructions, order numbers, and blocking information.
Sale and disclosure documents: Contracts, investor profile and suitability or appropriateness documents, risk disclosures, and documents regarding qualified investor status.
Evidence: Messages, emails, advertisements, presentations, and other lawfully obtained existing records. Preserve original files and date information.
Applications and notifications: Entity complaints, reference numbers, responses, rejection decisions, investigation and lawsuit documents.
Collections and agreements: Interim payment receipts, settlement and release texts, waiver or assignment of receivable documents, and offer correspondence.
How to organize your file
Prepare a single chronological list for each fund: transaction date, transaction type, money in, money out, share count, and name of supporting document. Also record gains withdrawn in earlier periods. Do not offset losses or gains from different funds on your own. Mark missing records separately; compare your account's official result with MKK and liquidation records.
What to request in your first written application
In your application, identify your name or company name, account and fund information, the share count shown in existing documents, and any dispute. You can substantiate your request with the following content:
"Regarding the specified fund and account, I request that the status of my entitlement reconciliation with MKK records, my net investment amount, and the basis of my interim payment calculation be disclosed in writing; that the record differences I have shown in attached documents be examined and corrected; and that any missing documents, payment method, and the reason for non-payment, if any, be explained in writing."
This text is an example of an information and correction request. It does not replace an annulment lawsuit, compensation lawsuit, or criminal complaint petition. If there is a specific decision or notification, claims and deadlines must be separately determined based on that.
Common false expectations
The first applicant does not necessarily receive payment first. The distribution order depends on applicable regulations, CMB decisions, and the fund's cash position.
Having a loss below 1 million TL is not a guarantee that the amount will be paid immediately and in full. Loss exceeding 1 million TL does not mean the remainder is automatically waived.
Making only a CMB or CİMER application does not protect all lawsuit deadlines. The deadline calculation varies depending on the type and recipient of the application.
Being a complainant in a criminal file does not by itself provide a compensation judgment or priority collection right. Liquidation, criminal, and personal compensation processes must be coordinated.
TMSF taking on duties does not mean the loss will be paid from its own budget. Collection depends on fund assets and recoverable values.
Credit interest, expected returns, and other additional damages are not automatically added to the liquidation receivable. If there is a separate claim, its basis, proof, and responsible party are examined.
Do not share bank passwords, e-Government passwords, or one-time authentication codes with an attorney or entity. Information and documents are transmitted through secure channels.
The new law opens a path for investors to receive payment. To benefit from this path, priority should be correct records, correct calculation, and timely application.
Updated on October 27, 2026, taking into account the CMB application principles published the same day. This guide is for general information purposes; current decisions, notifications, and personal claims regarding your fund must be examined separately.