First question: Have Tera fund investors lost all their money?

Not necessarily. A regulatory decision to liquidate an investment fund does not mean that its assets have disappeared, that the investor has irreversibly lost the entire investment, or that full reimbursement is guaranteed. Recoverable amounts depend on the particular fund, Central Securities Depository (MKK) records, realizable assets, applicable liquidation calculations, legally recoverable transfers and any payments already received.

For the relevant Tera Portföy funds, Türkiye İş Bankası A.Ş. has been appointed to conduct liquidation. Under Law No. 7596 and the Capital Markets Board (SPK/CMB) implementing decision, a qualifying investor may be eligible for an interim payment capped at TRY 1 million per investor per fund, subject to several additional restrictions. The ceiling is neither a payment promise nor a ceiling on all possible civil damages.

Crucial distinction: fund unit holders and clients whose cash or securities are held by Tera Yatırım Menkul Değerler A.Ş. fall under different legal frameworks. Brokerage investor compensation through the Investor Compensation Center (YTM) must not be confused with liquidation distributions under Law No. 7596. Source: CMB, 27 October 2026.

1. What is the Tera Holding fund scandal, and what happened in 2026?

Public references to the “Tera Holding fund scandal,” “Tera fund crisis” or “Turkish investment fund investigation” describe a series of regulatory measures affecting funds established by several portfolio management companies, alongside separate criminal investigations into certain capital-market transactions. Tera Yatırım Menkul Değerler A.Ş., Tera Portföy Yönetimi A.Ş. and Tera-related holding companies are distinct legal entities. No legally sound assessment can treat all their liabilities, assets and customers as interchangeable.

According to the CMB’s announcement of 23 September 2026, decisions taken on 17 September concerned the liquidation of 131 investment funds established by seven portfolio management companies. MKK records indicated 455,758 distinct investors across those funds. This was a sector-wide figure: it did not mean 455,758 Tera Portföy investors, and neither the total net asset value of those funds nor an amount quoted in a news report equals legally established investor losses. CMB announcement, 23 September 2026.

The initial decisions affected funds associated with Tera Portföy, Pusula Portföy, Atlas Portföy, Hedef Portföy, A1 Capital Portföy, Pardus Portföy and Bulls Portföy. Nevertheless, the September liquidation decisions, the special statute enacted in October, subsequent payment decisions and the separate regulatory treatment of each company do not have identical scopes. An inability to trade a fund through TEFAS is not, without more, proof of inclusion in the same statutory payment mechanism.

Legal timeline: key dates and their effect on investors

Payment update as of 30 October 2026. The Anadolu Agency, TRT Haber and Bloomberg HT reported that interim distributions totaling TRY 29.3 billion had commenced for 235,705 investors in seven funds under extraordinary liquidation involving Atlas, Pusula and Tera portfolio managers. The same reporting referred to previous ordinary-liquidation distributions of approximately TRY 68 billion to 63,759 investors across 93 funds involving A1 Capital, Bulls, Pardus and Hedef. Aggregated media figures cited 100 funds, 299,464 investors and TRY 97.3 billion. These are reported aggregate figures, not evidence that all six Tera funds were paid on that date or that a particular investor has been credited. Anadolu Agency, 30 October 2026.

Media outlets have also reported detention, arrest and asset-preservation measures in criminal investigations concerning capital-market activity. Investigation, arrest, a regulator’s allegation and a final criminal conviction are different things. Individual criminal liability requires proof under the relevant substantive and procedural law; no public narrative substitutes for a court judgment. Anadolu Agency investigation coverage.

2. Which Tera investment funds are subject to liquidation? TP2, TLV, TLY, THF, DOH and T3B

Early company communications referred to five Tera Portföy funds, while the subsequent CMB Bulletin 2026/61 list covered six fund codes. Anyone assessing eligibility should rely on the current binding decision and the fund’s formal identification, rather than on an early news article.

These translated English names are descriptive; the fund codes and Turkish regulatory documents are controlling. Check the CMB 2026 bulletin archive and CNBC-e, 18 September 2026. Possession of a different Tera-branded fund does not automatically bring that holding within Law No. 7596. Article 1 defines the statute’s specific scope.

Does accepting investment risk eliminate a manager’s legal responsibility?

No general principle absolves a manager of potential liability for misleading information, unlawful diversion of fund assets, breach of safeguarding obligations or proven market manipulation merely because the investor accepted market risk. Conversely, a falling price or a disappointing return is not by itself evidence of fraud or compensable wrongdoing. Review the fund’s internal rules, issue document, risk disclosures, investment mandate, transaction rationale, applicable duties and causal link to the alleged loss.

3. Which category of investor are you? Three different legal routes

Category A – holders of liquidating Tera Portföy fund units. Legal entitlement derives from the holding and transaction records maintained by MKK and the appointed liquidation institution. Law No. 7596 and relevant CMB decisions govern distribution calculations. For the applicable Tera funds, the role of Türkiye İş Bankası is central.

Category B – clients of Tera Yatırım Menkul Değerler A.Ş. with cash or securities held at the brokerage. The CMB’s 27 October decision on investor compensation and gradual liquidation, reported in Bulletin 2026/77, brings the Yatırımcı Tazmin Merkezi (YTM, Investor Compensation Center) into focus. Eligibility depends on whether the investment institution failed to meet a covered cash payment or securities delivery obligation, and the statutory compensation requirements.

Category C – investors who bought TERA, TRHOL or other listed shares. Owning publicly traded company shares is legally different from holding units in one of the relevant funds. A loss on a listed share does not, by itself, entitle the shareholder to interim distributions under Law No. 7596. An independent claim requires evidence of the unlawful act, investor-specific loss and causation.

The same person may fall into more than one category. Someone may hold TP2 units while maintaining an unrelated cash balance at Tera Yatırım. That situation requires two separately calculated claims and two separate sets of documentary evidence.

4. My redemption order was not executed: why do 16 and 17 September 2026 matter?

The CMB’s 28 September 2026 statement addresses the status of investors’ purchase and redemption instructions. According to the clarification, instructions submitted to TEFAS on 17 September were canceled in connection with the suspension. Some instructions submitted on 16 September or earlier, which had not been settled due to default or nonpublication of a fund price, required particular attention in the liquidation procedure.

Article 3(5) of Law No. 7596 specifically addresses persons whose fund units remained blocked because orders received by 17 September had not been completed due to default or the absence of a published unit price. Determining whether a particular investor retains the relevant fund unit-holder rights requires a precise review of the instruction, system receipt time, settlement period, blocking status and recorded reason for rejection or cancellation.

Example. An investor submitted a TP2 redemption on 16 September. The transaction failed at settlement because a required price had not been published, and fund units remained blocked. The lawyer should assess Article 3(5), the applicable CMB decision and the actual MKK records. A 17 September instruction raises a separate cancellation issue. A phone screenshot is useful, but server-side order logs, timestamps, transaction identifiers and custody records are often essential.

5. The TRY 1 million Tera fund interim payment: who qualifies and how is it calculated?

The CMB’s 1 October announcement, Article 4 of Law No. 7596 and Resolution 76/1903 established a special interim-payment framework for the funds within scope. TRY 1 million is a ceiling per qualifying investor per relevant fund. It is not an unconditional entitlement to TRY 1 million, a state guarantee or a limit on a properly established separate damages claim.

Under the statutory framework, interim distributions cannot exceed the applicable unindexed net invested amount. Depending on fund category, the current calculated value of the investor’s units can impose an additional limit. The amount actually payable is also affected by each fund’s distributable cash and any CMB-approved payment sequence. Money market funds were given priority. The CMB’s explanatory guide of 27 October emphasizes the separate limits and permits additional allocation methods where available liquidity cannot meet all interim entitlements. Official ten-question guide, 27 October.

An interim distribution does not automatically involve surrender of the underlying fund units. Prior distributions are credited against subsequent amounts under the statutory system, while unit redemption takes place in connection with the final liquidation distribution. Investors should inspect any release, waiver or settlement document before signing.

Have interim payments started, and when will each fund pay?

As of 30 October 2026, the commencement of interim payments had been reported for seven funds across the Atlas, Pusula and Tera extraordinary-liquidation processes. However, there was no verified single payment date for all affected funds or all investors as of 31 October. Payment depends on fund-specific liquidation cash, MKK reconciliation and applicable CMB decisions. The earlier adjustment of the general liquidation period from three months to six months did not guarantee that each investor would be paid precisely at the six-month mark. Consult current CMB announcements and the appointed liquidation institution.

6. How is an investor’s loss calculated? Net invested amount is not the same as recoverable damages

It is essential to distinguish at least four amounts: (1) total historical cash paid into the fund; (2) the net amount remaining after contributions, withdrawals and the applicable statutory adjustment; (3) the last quoted or recorded value of fund units; and (4) legally recoverable damage caused by a proven breach or unlawful act. These figures can diverge sharply where fund valuation is disputed or redemptions remained unsettled.

Article 4 of Law No. 7596 prescribes a specialized net-investment calculation in circumstances where distributable cash is insufficient. The calculation can involve adjusting historical inflows and outflows on a daily pro-rata basis using the arithmetic mean of changes in the consumer and domestic producer price indices, with a first-in, first-out (FIFO) method for matching withdrawals to contributions. The statutory use and limits of that calculation must be checked against the fund’s position and the specific payment category. The unindexed amount used as an interim-payment ceiling must not be confused with the indexed amount potentially relevant elsewhere in the liquidation regime.

A civil compensation claim is separately assessed under the Turkish Code of Obligations and any applicable special rule. It may involve a contractual breach, tort, culpable misconduct or another statutory ground, plus legally recognized loss and adequate causation. Allegations of artificially inflated fund prices, inadequate disclosures or wrongful obstruction of redemptions may require different valuation methods. Accordingly, the statutory liquidation figure does not automatically equal the total amount recoverable in a civil action.

Three calculations that an investor’s lawyer should prepare

1. Liquidation schedule: fund code, units, MKK reconciliation, legal calculation under Article 4, distributable assets, interim payments, final distributions and offsets.
2. Transaction-specific economic loss: execution and settlement dates, unit prices, rejected instructions, a defensible counterfactual transaction and evidence connecting the loss to the alleged wrongdoing.
3. Supplementary recoverable heads of loss: legally applicable interest, documented consequential losses and litigation-related sums recoverable under the relevant cause of action.

Double recovery is not permitted. Article 4(5) requires amounts previously received through liquidation, asset recovery or other legal routes to be taken into account for the final distribution. Maintain an investor-specific chronological receipts and set-off register.

7. Law No. 7596: what new rights and recovery mechanisms does it provide?

Law No. 7596 on Certain Investment Funds Ordered to Be Liquidated (Tasfiyesine Karar Verilen Bazı Yatırım Fonları Hakkında Kanun) was adopted on 22 October 2026 and published in the Turkish Official Gazette, issue No. 33413, on 27 October 2026. Under Article 8, it came into effect on publication with application from 17 September 2026. Its special provisions apply only to the funds defined in its scope. Official Gazette, 27 October 2026 (Turkish text).

7.1. Identification, valuation and realization of fund property

Article 3 provides for determining assets and eligible investors, valuation, disposal of fund assets and distribution under the supervision of the CMB through the appointed institutions. Where the quoted market price of an exchange-traded asset does not reflect its economic value, particular sale or realization methods may arise. For any potential claim concerning the conduct of the liquidation, the time of sale, chosen buyer, valuation evidence, competing offers and the duty to protect unit holders’ common interests are important.

7.2. Recovery of assets allegedly diverted from a fund

Article 5 addresses assets extracted from fund property through transactions lacking genuine economic purpose, sham transactions or transfers without proper consideration, including arrangements structured as loans, advances, guarantees, assignments and purchases or sales. A contract’s formal existence does not establish that its economic substance or its benefit to the fund was legitimate.

The law establishes specific recovery responsibilities and a sequence of recourse. The fund’s founder and/or manager, namely the relevant portfolio management company, is a principal point of responsibility. For amounts not collected, or evidently uncollectible, personal recovery measures may concern other natural or legal persons whose responsibility is established under the statutory procedure, including persons acting in concert. Civil recovery responsibility under this statute and personal criminal liability are not identical concepts. Criminal guilt cannot follow from a corporate title alone.

7.3. What is the SDIF/TMSF recovery account?

Articles 5 and 6 provide a role for Türkiye’s Savings Deposit Insurance Fund (Tasarruf Mevduatı Sigorta Fonu, TMSF/SDIF), including specially prescribed collection powers and possible management measures concerning certain assets. Collected sums are to be maintained through special, fund-specific recovery accounts and distributed under the legal mechanism. In specified cases concerning funds whose liquidation is complete, the YTM may also participate in distribution.

This does not mean investment fund units have become insured bank deposits. The SDIF’s statutory collection function differs from the ordinary banking deposit-insurance regime. Likewise, the YTM’s occasional administrative role in a payment route does not mean it insures an investment fund against ordinary market movements.

7.4. Fund property is legally separate from the manager’s property

Article 53 of Capital Markets Law No. 6362 recognizes the separation of a fund’s assets from the property of its founder and portfolio custodian. The separation is fundamental to identifying which assets belong to the unit holders’ investment fund rather than the portfolio management company or another group entity. It does not guarantee that securities held inside the fund will preserve their economic value.

7.5. Constitutional and administrative-law questions

The retroactive effects of the special law, CMB determinations of responsibility and amounts, SDIF collection tools associated with Law No. 6183, restrictions on dealings with property and decisions excluding particular persons from payment may raise questions concerning property rights, legal certainty, proportionality, the presumption of innocence, effective remedies and judicial review. The relevant forum and time limit depend on the precise act, service or notification date and the special jurisdictional rules. The fact that an act is reviewable does not establish that it is unlawful; conclusions require a case-specific assessment.

8. Tera Yatırım brokerage license revoked: who may claim compensation from the YTM?

Through its decisions announced in CMB Bulletin 2026/77 of 27 October 2026, the regulator revoked the activities and authorization of Tera Yatırım Menkul Değerler A.Ş. and adopted measures for investor compensation and the company’s gradual liquidation (tedrici tasfiye). Tera Yatırım’s company announcement of 30 October directs investors to official YTM publications. See the YTM compensation notice dated 28 October and the company’s 30 October notice.

Under Articles 83-85 of Capital Markets Law No. 6362, YTM investor compensation concerns certain failures of investment institutions to discharge cash payment or capital-market instrument delivery obligations connected with investment services. Mere deterioration in a security’s value, disappointment with a fund’s return or an ordinary stock-market loss does not, by itself, give rise to a compensable YTM claim.

Time limit: Article 85(1) provides that the right to submit a compensation claim becomes time-barred one year after the compensation decision is announced. Investors should establish the legally operative publication date, the personal application method, and any objection periods in the relevant claims schedule. The deadline must not simply be assumed to begin on the date this article is read. The YTM notice archive should be monitored for updated forms, entitlement lists and objections.

Two ceilings must never be conflated: the TRY 1 million per-fund interim-distribution ceiling in the fund liquidation regime is separate from the annual statutory YTM compensation limit applicable to eligible brokerage claims. Check the current YTM-specific limit on its official website before preparing a monetary application.

9. What legal remedies are available to Tera fund investors in Türkiye?

9.1. Verify holdings and the liquidation account with MKK, the liquidator and the CMB

The first task is to identify the claimant’s legal position precisely: the fund code; number of units; record and entitlement date; unexecuted subscriptions or redemptions; net invested amount; statutory liquidation status; amounts calculated for interim payment; actual bank credits; and offsets. Compare the records supplied by the portfolio manager or the selling bank with independent MKK and liquidator records.

Where the figures disagree, submit a written, dated objection identifying the disputed transaction number, timestamp, settlement date, calculation and specific correction requested. An investor should not rely exclusively on telephone assurances or a single app screenshot when institutional audit trails can be obtained.

9.2. Criminal complaint to the Public Prosecutor: what must be proven?

Depending on evidence, potential capital-market offences under Article 106 (insider dealing) and Article 107 (market manipulation) of Law No. 6362 may require examination. Trade-based market manipulation can involve orders or transactions intended to create a misleading or false impression concerning the price, price movements, supply or demand of capital-market instruments. A fall in price or a large investor loss does not establish the offence by itself. The required mental elements, relevant transactions, persons and evidentiary chain must be demonstrated. CMB’s explanation of trade-based manipulation.

Article 115 of Law No. 6362 contains a special prosecution procedure involving the regulator’s written application in respect of relevant capital-market offences. A victim may submit evidence and ask prosecutors to investigate, but a private complaint does not displace the statutory procedural requirement for the CMB’s application where applicable. Depending on the actual conduct and elements proved, Turkish Criminal Code Article 155 (breach of trust), Articles 157-158 (fraud and qualified fraud) or Article 282 (laundering of criminal proceeds) may also be assessed. It would be improper to allege all such offences categorically against a person merely because the person is associated with a company mentioned in the media.

A properly targeted request for investigative measures may cover:

• Borsa İstanbul order books, original electronic order logs, cancellations and matching records;
• common control of brokerage accounts, beneficial ownership, related-party networks and coordinated transactions;
• reconciliations among MKK, Takasbank, the fund manager and the custodian;
• concentration of fund assets in thinly traded shares and the basis for fair-value assessments;
• investment committee minutes, valuation files, compliance warnings and portfolio-custodian notices;
• internal correspondence, client communications, alleged misrepresentations and risk disclosures;
• MASAK financial-flow reports, transfers, alleged sham arrangements and their economic rationale;
• grounds and proportionality of protective measures under Criminal Procedure Code Article 128 and relevant special legislation.

An investor may participate in a criminal investigation as a complainant and, where directly harmed and legally eligible, seek intervenor status if a public prosecution is brought. Access to investigation materials is subject to the Turkish Code of Criminal Procedure (CMK), the claimant’s procedural standing and any lawful confidentiality restrictions. A police report, prosecutor’s press release or pretrial arrest order is not a final finding of criminal guilt.

9.3. Damages claims against portfolio managers, responsible individuals or other institutions

Where legally actionable misconduct can be proved – such as breach of a portfolio manager’s duties of care and loyalty, misleading investor documentation, transactions contrary to the fund’s mandate or unlawful diversion of assets – compensation may be examined under Article 49 (tort) and Article 112 (contractual nonperformance) of the Turkish Code of Obligations No. 6098 and relevant sector-specific rules. Depending on the legal relationship and actual damage, the Turkish Commercial Code No. 6102 provisions concerning management responsibility may also require consideration.

The claimant must identify the correct defendant legal entity, the nature of its responsibility, its duty toward the particular investor, the impugned act or omission, quantifiable loss and adequate causal link. A portfolio management company, investment brokerage, portfolio custodian and distribution bank perform different functions. Naming every organization as a defendant without establishing a legally relevant duty can undermine the case and add costs.

Jurisdiction, court competence and mandatory mediation depend on the substantive claim, relevant investment agreement and whether the dispute qualifies as commercial, consumer or another type of litigation. In general, Article 72 of the Code of Obligations provides a two-year period from discovery of loss and the liable person and an ultimate ten-year period for tort claims, with possible application of longer criminal limitation periods under specified conditions. Contractual claims require separate review of Article 146 and any special periods. Do not assume that the YTM claim, an administrative judicial-review action and a civil damages suit share one deadline.

9.4. Interim attachment, interim injunction and preservation of evidence

If there is evidence of an imminent risk of dissipation of assets, consider precautionary attachment (ihtiyati haciz) under Articles 257 et seq. of the Enforcement and Bankruptcy Law, subject to its legal requirements. Where it is necessary to protect a disputed right, a provisional injunction (ihtiyati tedbir) under Articles 389 et seq. of the Code of Civil Procedure may be considered. Their requirements are not interchangeable. The statutory protections and restrictions applicable to special liquidation and recovery accounts must be considered before seeking enforcement against those accounts.

For at-risk records, a request for judicial preservation of evidence (delil tespiti) under Articles 400 et seq. of the Code of Civil Procedure may address electronic instructions, relevant price calculations, correspondence or other information which might later be impossible or materially harder to obtain. The application must explain precisely which evidence is requested, where it exists and why early preservation is justified. Evidence in criminal proceedings may separately need to be preserved or requested by the civil court.

9.5. Administrative litigation concerning CMB decisions

Judicial review of a regulatory measure requires identification of a final, executable administrative act, standing, the appropriate court, service or publication date and statutory time limit. Under Article 7 of Administrative Judicial Procedure Law No. 2577, the ordinary time for filing an administrative action is generally sixty days in the administrative courts, subject to special rules and the correct starting date. An administrative complaint or lawsuit does not automatically stay implementation; a stay of execution must be requested and justified where available.

Any damages claim premised on an alleged failure of regulatory supervision raises separate issues of public-law liability, demonstrable service fault, foreseeability, loss and causation. Article 5(4) of Law No. 7596 includes a special Istanbul administrative-court jurisdiction rule for specified lawsuits relating to SDIF collection measures. It must not be misrepresented as requiring every investor damages lawsuit to be filed in the Istanbul administrative courts.

9.6. Can affected investors file a collective action?

Turkish law does not provide a universal counterpart to the US-style investor class action. Where its conditions are met, optional joinder of parties under Articles 57 et seq. of the Code of Civil Procedure may permit multiple investors to litigate related claims together. But fund types, subscription dates, transaction histories, disclosure documents, alleged losses and limitation periods differ by person. Coordinated evidence strategy does not eliminate the need for investor-by-investor loss calculations.

10. What should Tera fund victims do now? A ten-step checklist

The most valuable early legal work is often to secure an accurate record of ownership and orders before memories fade and access to electronic systems changes. Preserve copies of dated official announcements, documents delivered by banks and written responses to requests.

1. Identify each fund code. Is it TP2, TLV, TLY, THF, DOH, T3B or an entirely different fund? Maintain a separate folder for each holding.
2. Obtain MKK statements. Secure the unit count, custody position and recorded entitlement as of relevant dates.
3. Download complete bank and brokerage account statements. Include all contributions, withdrawals, account charges and offsets.
4. Request original TEFAS order history. Keep the time of instruction, order ID, settlement date, accepted/rejected status, cancellation and any default notices.
5. Archive the fund documents. Obtain the internal rules, prospectus/issue documentation, risk disclosures and relevant promotional material.
6. Ask for a written liquidation account. Request the legal classification of your holding, MKK net-investment calculation and institution responsible for payment.
7. Record every interim distribution. Note the fund, credit date, amount, payment explanation and any disagreement with the calculation.
8. Check whether you have a distinct YTM claim. Brokerage clients must monitor the 28 and 30 October 2026 YTM notices and subsequent announcements.
9. Calendar each deadline independently. Compensation applications, objections, administrative actions, contractual and tort claims may have different triggers and limitation periods.
10. Coordinate liquidation, criminal complaints and civil litigation. Disclose receipts consistently and avoid duplicate recovery claims.

Minimum documentation to share securely with counsel: investor identification and contact information; intermediary/bank name; fund codes; MKK holdings; bank and brokerage statements; executed and canceled orders; settlement details; default or rejection messages; communications during acquisition of the investment; advertising and risk materials; payment evidence; relevant CMB/KAP announcements; and any existing applications or court documents. Financial and personal data should be transferred through secure, appropriately authorized channels.

11. Four practical investor scenarios – and the documents needed

Case 1: Savings held in a TP2 money market fund

An investor placed a significant portion of their savings into TP2 and then could not submit a redemption instruction or had one rejected. First confirm the precise units and order status. Next evaluate the Türkiye İş Bankası liquidation, the CMB’s priority for money market funds and Article 4 of Law No. 7596. Seek a written calculation before determining the appropriate claim for any unpaid balance.

Case 2: A large TLY or T3B investment and disputed fund valuation

Suppose an investor bought units at a published price and later learned of allegations that underlying assets had not been valued fairly. Relevant evidence may include daily net-asset-value worksheets, the trading volume and free float of portfolio shares, counterparties, related-party transactions, research material and the investor’s risk disclosures. A substantial loss is not proof of crime; the legal case requires identifying an unlawful act and explaining how it caused the particular loss.

Case 3: Cash or securities cannot be returned from a Tera Yatırım account

A client has a brokerage cash balance or securities which the institution has a duty to deliver, but delivery is not taking place. The lawyer should check the 28 October YTM notice, subsequent claims announcements and the applicable compensation requirements. A broker’s failure to meet a delivery obligation and a fall in the market price of a fund require materially different evidence and loss calculations.

Case 4: Loss on TERA or another listed share amid manipulation allegations

A person bought exchange-listed shares and incurred a loss after the price fell. This person is not automatically a unit holder of a fund covered by Law No. 7596. Any separate claim based on alleged market manipulation calls for a documented chronology of purchases and sales, identification of the transactions alleged to be unlawful, analysis of the effect on the market price and, where necessary, specialist economic evidence of causation.

What should a written investor information request include?

A targeted request to a liquidator, the CMB or the institution maintaining the account can ask for: (i) the fund and number of units recorded for the investor; (ii) the entitlement and reconciliation date; (iii) execution and cancellation grounds for orders issued on 16-17 September; (iv) underlying cash-flow data and any statutory indexation used to compute net investment; (v) amount and anticipated date of any interim payment; and (vi) deductions, offsets and the procedure for challenging a calculation. A request should be tailored to the investor’s own legal entitlements and access rights.

12. Frequently asked questions about Tera fund refunds and compensation

When will Tera funds reopen for trading?

A fund ordered into liquidation should not be assumed to reopen for normal TEFAS trading on a particular date. Investors should instead examine its specific liquidation decision and the statutory distribution procedure.

When will Tera fund investors receive their money?

Initial interim payments involving seven extraordinary-liquidation funds were reported as commencing on 30 October 2026. Payment for a particular holding depends on distributable cash, MKK reconciliation and regulator-approved distribution rules. As at 31 October, there was no verified universal payment date for all funds.

Is a TRY 1 million refund guaranteed?

No. It is a maximum interim payment, subject to the unindexed net-investment amount, applicable unit value restrictions, available liquidity and other conditions. Investors cannot infer a guaranteed government-backed refund of TRY 1 million.

Does the TRY 1 million ceiling apply per investor or per fund?

The special interim-payment limit is assessed separately for each investor in each fund falling within the relevant statutory arrangement.

I own TP2 units. What should I do first?

Obtain your MKK unit record, all account movements and any redemption instruction. Review the Türkiye İş Bankası liquidation procedure and the regulator’s priority for money market funds.

Will TLV, TLY, THF, DOH and T3B pay on the same date?

Not necessarily. Available assets, liquidity, liquidation sequencing and fund characteristics may differ. No common date can be inferred from a payment announcement concerning another fund.

Is THF on the liquidation list?

The later CMB Bulletin 2026/61 materials identified six Tera fund codes, including THF, although some early communications referred to five funds. Check the updated binding list for your exact holding.

My redemption order was canceled on 17 September. Have I lost my rights?

Cancellation of an order does not by itself extinguish ownership of the underlying fund units. The CMB explanation and the unit position in MKK records must be reviewed to identify the liquidation entitlement.

What if I ordered redemption on 16 September but settlement never occurred?

Article 3(5) of Law No. 7596 should be examined where the order failed because of default or nonpublication of a price and units remained blocked. Collect the original instruction, settlement records and the reason for nonexecution.

Do I need a lawyer to receive a liquidation distribution?

Routine, undisputed distributions do not necessarily require litigation or legal representation. Legal advice becomes especially relevant where entitlement is contested, an order was not executed, a payment is missing, fund valuation is disputed, or a formal objection or lawsuit has a time limit.

Can Tera Yatırım brokerage clients apply to the YTM?

They should assess eligibility under the CMB’s compensation decision and official YTM notices. The YTM scheme concerns covered delivery or cash obligations, not every fall in investment value.

What is the YTM claim deadline?

Article 85(1) of Law No. 6362 provides a one-year limitation period running from announcement of the compensation decision. The operative announcement and applicable claims procedure must be verified individually.

If I complain to the CMB, will it automatically refund my investment?

No. A regulatory complaint may trigger supervisory review or assist in correcting a record. It is not, by itself, a judicial damages order or proof that payment has become due.

Does a criminal investigation prove that Tera executives owe me compensation?

No. Investigation, individual wrongdoing, loss and causation are legally separate questions. Liability must be established with applicable evidence and law, not presumed from an arrest or media report.

Will the Savings Deposit Insurance Fund repay all investment fund losses?

No general promise of that kind arises from Law No. 7596. The SDIF/TMSF has a special role in recovering certain assets and distributing recovered sums under the statute. This is distinct from state-backed deposit insurance.

Can I sue for my entire loss?

A potential damages claim requires assessment of the correct defendant, legal cause of action, provable damage, causation, applicable court and limitations. Previous liquidation and recovery distributions must be credited as required to prevent double recovery. No lawyer can guarantee that a stated amount will be collected.

Are shareholders of TERA or TRHOL automatically Tera fund victims?

No. Direct share ownership is not the same as holding units in a fund. The Law No. 7596 interim-payment process does not automatically cover a shareholder merely because the company’s name or ticker is connected to the news.

I purchased the fund through another bank. Who must I contact?

The distribution bank, custodian, fund founder and appointed liquidation institution may be different entities. Review your MKK holding, the bank’s records and the fund’s specific CMB status to identify the responsible channel and request the necessary account information.

13. Legal assessment: the strongest investor-oriented strategy

The greatest procedural risk in a multi-layered capital-markets crisis is treating fund liquidation, statutory recovery, YTM compensation, civil damages and criminal complaints as though they were one claim. That confusion can produce incomplete evidence, missed objection periods and incorrect monetary demands. The 7596 recovery regime offers an important statutory pathway, but fund liquidation proceeds may not resolve a separate allegation that false valuations, unlawful management or a brokerage delivery failure caused additional recoverable harm.

A defensible legal sequence is: (1) verify ownership; (2) preserve original electronic records; (3) audit the official liquidation and net-investment figures; (4) challenge factual or computational discrepancies; (5) identify the legally responsible person and demonstrate causation; (6) pursue proportionate criminal, civil or administrative remedies; and (7) account for interim and final receipts at every stage. Proof that money was invested does not, without more, establish every element of a claim against a particular person. Conversely, where relevant data lie exclusively with a bank, broker, portfolio manager or custodian, targeted judicial requests for production can be pivotal.

Evidentiary limits as of 31 October 2026: The public sources reviewed for this article did not provide a complete, authenticated set of case-file evidence, all accepted indictments or final criminal judgments for the related investigations, nor final loss calculations for every investor. Therefore no blanket finding of guilt or promise of full reimbursement is justified. Individual legal assessment must rest on the investor’s own holdings and transaction trail.

14. Primary legal sources, official notices and news reporting

The following references distinguish binding Turkish law and regulator publications from media reporting. Official documents are relied on for legal rules; news articles are used principally to confirm the timeline and attribute publicly reported figures. All links are direct and free of tracking parameters. The Turkish-language text of legislation and regulatory decisions controls over the explanatory English translations used in this article.

1. Law No. 7596, Official Gazette of Türkiye, No. 33413, 27 October 2026, original text.
2. CMB, 27 October 2026, Resolution 76/1903, practical guide to liquidation and payment rules, official explanatory announcement.
3. CMB, 2026/60, 2026/61, 2026/76 and 2026/77 bulletins, 2026 bulletin archive.
4. CMB, 23 September 2026, 131 funds and 455,758 distinct investors, official notice.
5. CMB, 21 September 2026, change to the fund liquidation period, official notice.
6. CMB, 28 September 2026, status of TEFAS instructions and liquidation timetable, official clarification.
7. CMB, 1 October 2026, interim-payment announcement, official notice.
8. CMB, explanation of trade-based market manipulation under Law No. 6362, investor guidance.
9. CMB legal database, Capital Markets Law No. 6362, Communiqué III-52.1 on Investment Funds and related regulations, legislation database.
10. YTM, 28 October 2026, announcement regarding Tera Yatırım investor compensation, official notice; YTM, 30 October 2026, investor information requests, official notice.
11. Tera Yatırım, 30 October 2026, company notice about license revocation, investor compensation and gradual liquidation, company announcement.
12. Tera Portföy, September 2026, fund-liquidation company communications, notice archive; KAP, company disclosures for Tera Yatırım, public disclosure record.
13. Anadolu Agency, 27 October 2026, report on revocation of Tera Yatırım’s licenses, report.
14. Anadolu Agency, October 2026, reporting concerning capital-markets investigations, report.
15. Anadolu Agency, 30 October 2026, interim payments to 235,705 investors in seven funds, report; TRT Haber, 30 October 2026, payment report.
16. CNBC-e, 18 September 2026, Tera Portföy’s six funds and liquidation process, report.
17. YTM, current claim procedures and subsequent official notices, announcements.

Legal assessment and representation for affected fund investors

TD Law Firm advises on disputes arising from Turkish capital-markets transactions, including investor-specific review of custody and order records, fund liquidation calculations, submissions to the CMB and YTM, protection of victims’ procedural rights in criminal investigations, civil damages, and preservation of evidence.

The legal position of each investor depends on the fund code, invested amount, transaction history, payments already received, institutional records and evidence concerning alleged misconduct. Investors seeking advice are encouraged to prepare their MKK records, bank or brokerage statements and outstanding redemption instructions in advance.

Attorney Murat Can Dolğun
TD Law Firm
World Trade Center (Dünya Ticaret Merkezi), A2 Block, Floor 5, Office 206
Bakırköy, Istanbul, Türkiye
Telephone: +90 212 299 44 22