An interim payment is a payment made before the liquidation is completed and later deducted from the final amount you receive. The rule of the Capital Markets Board (SPK) in force today and the rule proposed in the Bill before the Turkish Grand National Assembly differ from each other.
In brief
- The SPK decision now covers the Tera, Pusula and Atlas funds. 1
- The Hedef funds were removed from the interim payment scheme on 15 October 2026. They are now liquidated in the same order as the A1 Capital, Bulls and Pardus funds. 2
- The amount is your net investment amount as calculated by the Central Securities Depository (MKK), and may be at most TRY 1 million.
- An interim payment is an advance: it is set off against the final payment. Your units are not redeemed at this stage.
- The Bill may change this rule, but it is not yet in force.
The rule in force today (SPK, 30 September 2026)
By decision No. 64/1775, the SPK introduced a payment method supplementary to the general liquidation procedure for the funds of the portfolio management companies Tera, Pusula, Atlas and Hedef. 1 3 By a decision dated 15 October 2026, the Board removed the Hedef funds from the scope of this decision; the rule now applies to the Tera, Pusula and Atlas funds. 2
| Subject | Rule |
|---|---|
| Who is eligible | All fund unit holders whose reconciliation has been completed |
| Basis amount | The net investment amount calculated by the MKK for each entitled holder |
| Upper limit | If the net investment amount is below TRY 1 million, the full amount; if it is TRY 1 million or more, at most TRY 1 million |
| Per fund? | According to the SPK release, the cap applies separately for each investor in each fund. 3 |
| Order | Money market funds first |
| Your units | No units are redeemed in return for the interim payment. The units are redeemed at the final liquidation payment. |
A simple example
Suppose an investor has invested a total of TRY 400,000 in a money market fund belonging to Pusula and has previously withdrawn TRY 100,000. The net investment amount is TRY 300,000. Because this person is below the TRY 1 million cap, they may receive an interim payment of up to TRY 300,000. Their remaining entitlement is determined in the final payment when the liquidation is completed.
This example is only to illustrate the logic. The actual amount is determined by the MKK’s records.
The situation for the A1 Capital, Bulls, Pardus and Hedef funds
For the funds of these three companies, the SPK set not an interim payment procedure but a separate liquidation order: money market funds first, then the other funds from the one with the most investors to the one with the fewest. 1 According to the official statement, the amounts payable in 17 funds of these companies were transferred to banks and brokerage firms on 8 October. 4 According to the official statement of 18 October 2026, in-kind and cash liquidation transactions totalling approximately TRY 40.8 billion have been completed by Ziraat Bank for more than 45,000 people in 66 funds of these three companies. 5
By decision No. 70/1821 dated 15 October 2026, the SPK removed the funds founded by Hedef Portföy from the scope of the interim payment decision. These funds will now be liquidated in the order above: first the funds whose name includes “money market”, then the others from the one with the most investors to the one with the fewest. 2 According to the official statement, payments to as many people as possible, starting with money market funds, are planned for the coming week. 5 No definite payment date has been announced for your fund. If an interim payment reached your account before this decision, keep the receipt and ask your distributor in writing how that amount will be deducted from the final payment.
What does the Bill propose?
The Bill was adopted by the Planning and Budget Committee of the Turkish Grand National Assembly on 14 October 2026; according to the official statement, it is expected to be debated in the General Assembly in the week starting 20 October. 5 It does not apply unless it is adopted by the General Assembly and published in the Official Gazette, and the text may change during this process. 6
The main provisions of the text adopted by the Committee concerning the interim payment and the net investment amount are as follows: 7
- Indexation: If the cash to be distributed does not cover the total amount calculated at the 16 September price, the net investment amount taken into account for payments changes. Each cash inflow to and outflow from the fund is adjusted on a daily basis by the average of the change in the consumer price index (TÜFE) and the domestic producer price index (Yİ-ÜFE). Outflows are deducted from inflows on a first-in, first-out basis. The calculation is made by the MKK.
- Interim payment cap: The interim payment may not exceed TRY 1 million or the non-indexed net investment amount. Except for money market funds, it may also not exceed the previous day’s value of the units in your account.
- If cash is insufficient: The SPK may decide that payments be made starting from the smallest net investment amount, or that a minimum amount applicable to everyone be set.
- Those who will not be paid: No payment is made to persons found by the SPK to have committed market fraud, insider trading or market-distorting acts in connection with these funds.
- Set-off: In the final payment, amounts previously received from the liquidation, from the recovery account or through other legal remedies are deducted.
Points not yet settled
- Is the cap per fund or per investor? The SPK release applies the cap separately for each fund. The Bill’s explanatory memorandum speaks of TRY 1 million “per person”, but the text of the article bases the payment on each fund’s own liquidation assets and on the net investment amount at fund level. 6 The text is open to both interpretations; the SPK’s implementing regulation should be awaited. This difference matters for those holding units in more than one fund.
- Retroactive effect: The initial text of the Bill submitted to the Turkish Grand National Assembly provides for the law to enter into force with effect from 17 September 2026. 6 Whether this provision was retained in the Committee text has not yet been officially published.
- Fund price, or inflation-adjusted principal? The method in the Bill, where cash is insufficient, takes as its basis not the fund value on 16 September but the inflation-adjusted investment amount. The relationship of this method to the right to property is being debated in legal circles.
An interim payment is an advance to be deducted from the final amount. Nevertheless, if you are asked to sign a document at the time of payment, do not sign it without reading its contents and, if necessary, consult a lawyer.
Sources
- SPK Bulletin 2026/6730 September 2026. Decision No. 64/1770 (order of liquidation for the A1 Capital, Bulls and Pardus funds) and Decision No. 64/1775 (interim payment for the Tera, Pusula, Atlas and Hedef funds).
- SPK Bulletin 2026/7016 October 2026. Decision No. 70/1821 of the Board’s decision-making body dated 15 October 2026: the funds founded by Hedef Portföy Yönetimi A.Ş. were removed from the scope of interim payment decision No. 64/1775; their liquidation will follow the principles set by decision No. 64/1770 for the A1 Capital, Bulls and Pardus funds. (Content checked against the official statement and press reports, 19 Oct 2026.)
- SPK Announcement, 1 October 2026Interim payment announcement for the funds in liquidation (Tera, Pusula, Atlas, Hedef).
- Lexpera Blog, 9 October 2026Prof. Dr. T. S. Küçük and Assoc. Prof. Dr. M. Duygun, “Fon Krizi Nedeniyle İdarenin Mali Sorumluluğu” (The Financial Liability of the Administration Arising from the Fund Crisis).
- Directorate of Communications statement, 18 October 2026: Sixth Fund Board MeetingIn-kind and cash liquidation transactions of approximately TRY 40.8 billion completed by Ziraat Bank for more than 45,000 people in 66 funds of A1, Bulls and Pardus Portföy; funds in liquidation down from 131 to 65; Hedef funds made subject to the same principles by the SPK decision of 15 October 2026; payments, starting with money market funds, planned for the coming week; the Bill expected to be debated in the General Assembly. (Reported by CNBC-e.)
- Bill No. 2/3939“Tasfiyesine Karar Verilen Bazı Yatırım Fonları Hakkında Kanun Teklifi” (Bill on Certain Investment Funds Placed in Liquidation). Submitted to the Turkish Grand National Assembly on 9 October 2026 and adopted by the Planning and Budget Committee on 14 October 2026. Not yet enacted.
- Ekonomim, 14 October 2026“Fon teklifi komisyondan geçti: Yatırımcıya ödeme nasıl yapılacak?” (Fund bill passes committee: how will investors be paid?). A summary of the text adopted by the committee.
Have a question?
These articles are general information. You can send questions about your own situation through the contact section or by e-mail.
Av. Dr. Mustafa Aykanat · Ankara Bar Association Reg. No 43042 · Yenimahalle, Ankara