THE CAPITAL MARKETS BOARD’S DECISIONS REGARDING FUNDS SUBJECT TO LIQUIDATION PROCESS SUMMARY AND CURRENT STATUS OF IMPLEMENTATION

THE CAPITAL MARKETS BOARD’S DECISIONS REGARDING FUNDS SUBJECT TO LIQUIDATION

PROCESS SUMMARY AND CURRENT STATUS OF IMPLEMENTATION

In its announcement dated September 28, 2026, the Capital Markets Board (SPK) clarified the status of instructions transmitted via TEFAS regarding investment funds in the liquidation process and the basis for payments to be made to the holders of these instructions. Thus, the special liquidation regime, which has been taking shape gradually since September 17, has become largely clear for investors and market participants.

▪ September 17, 2026 – TEFAS closure and liquidation decision: Pursuant to Decision No. 57/1707 published in Bulletin No. 2026/60, the funds covered by the decision were closed to TEFAS transactions. Pursuant to Decision No. 57/1708 published in Bulletin No. 2026/61, the liquidation list was updated, and the procedures and principles for liquidation were established; purchase and redemption transactions outside of TEFAS were also suspended.

▪ Banks authorized to conduct the liquidation: Türkiye İş Bankası for Tera Portföy funds; T.C. Ziraat Bankası for funds under the scope of the portfolio management companies A1 Capital, Atlas, Bulls, Hedef, Pardus, and Pusula.

▪ September 21, 2026 – Extension of the deadline: Under Decision No. 59/1710, the three-month period specified in Article A/8 of the liquidation principles was extended to six months, while other provisions remained unchanged. The six-month period is not a mandatory waiting period but a maximum duration; liquidation may be completed earlier, and the Board reserves the right to extend the deadline.

▪ September 23, 2026 – Clarification of Scope: It was announced to the public that the process covers 131 funds belonging to seven portfolio management companies and 455,758 individual investors, according to MKK records.

▪ Instructions on or before September 16, 2026: Instructions submitted to TEFAS by this date were executed in accordance with normal procedures on their respective settlement dates.

▪ Unfulfilled legacy instructions: Those that could not be executed due to fund default or an inability to determine the price will also be considered under the liquidation process.

▪ September 17, 2026, instructions: All instructions submitted to TEFAS on this date were canceled, regardless of the time of submission. The reference to “1:30 p.m.” in Bulletin No. 2026/61 pertains to the price value date (instructions submitted after 1:30 p.m. on September 16 and before 1:30 p.m. on September 17 are subject to the same price value date); it does not imply that instructions submitted before this time on September 17 will be executed.

▪ Payment Basis: Payments will be made to the holders of canceled orders from the liquidation balance in proportion to their ownership of participation shares in the fund.

This process establishes a model—implemented for the first time on this scale in the Turkish fund market—that could serve as a precedent for similar situations in the future:

▪ Centralized and collective liquidation model: The liquidation of 131 funds belonging to seven founders under a single decision-making framework and uniform principles.

▪ Liquidation conducted by banks: The authority to liquidate is delegated to banks designated by the Board rather than to the founding portfolio management companies.

▪ A consensus-driven, phased process: The reconciliation of investor records and pending instructions, along with the determination of the funds’ assets and liabilities, is completed prior to the sale of assets.

▪ Controlled conversion to cash: The sale of portfolio assets, taking into account market depth and liquidity conditions to limit value loss.

▪ Phased distribution: Distribution of the proceeds to investors in specified periods; not waiting for the liquidation to be fully completed before making payments.

▪ Distinction between order date and price value date: Establishing a clear criterion for classifying pending orders at the close of the trading platform.

▪ Flexible timeframe: A timeframe structure that combines a maximum duration, the possibility of early completion, and the Board’s authority to extend the period.

The most significant contribution of the latest announcement to implementation is that it clarifies the distinction between the order date and the price value date and resolves the uncertainty regarding the 17 September orders in terms of timing. For portfolio management companies, custodians, and distributor institutions, the accurate classification of order records, the provision of consistent information to investors, and the complete retention of records to address potential claims are of critical importance. Investors, for their part, would be well advised to confirm with their brokerage or distribution firms which category their orders fall into.

It should be noted that this framework applies specifically to the funds listed in the decisions and does not constitute a change in general fund regulations. However, the model presented is expected to guide secondary regulations in the future.