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Investment Fund Liquidation: Guide for Affected Investors, Remedies and Sample Petitions

Attorney Berk İşcan · 26 October 2026 · 4 min read

Investment Fund Liquidation: Guide for Affected Investors, Remedies and Sample Petitions

In its press announcement of 23 September 2026, the Capital Markets Board (CMB/SPK) stated that, under its decisions of 17 September 2026, the liquidation of 131 investment funds belonging to 7 portfolio management companies had been decided, and that according to Central Securities Depository records these funds had 455,758 unique investors. This article summarises the remedies and time limits for affected investors. Sample petitions are available in the Turkish version of this article, since they are submitted to Turkish institutions in Turkish. This article is general information only and does not replace an assessment of your specific situation. For the current liquidation timetable and payments, always check CMB and Central Securities Depository (MKK) announcements.

1. First step: collect documents

  • Fund buy and sell orders, receipts and account statements (number of units and transaction dates).
  • The institution through which you bought the fund: bank, brokerage or portfolio company application.
  • The prospectus, investor information form, fund rules, risk disclosure form and investor profile form.
  • Correspondence about the guidance and information you received: emails, messages, call-centre records, screenshots.
  • Any payments made after liquidation and their receipts.

2. Follow official announcements

The liquidation process and the timing and method of payments are announced in CMB bulletins and by the institutions concerned. Be careful of unofficial persons and websites that promise refunds or ask you for fees, commissions or personal information.

3. Written information request

You may send a written request to the institution through which you bought the fund, the portfolio management company and the custodian to learn your unit balance, the account for liquidation payments, the timetable and the fund's portfolio. Use a method that can prove the date of sending, such as a signed petition, notary or registered electronic mail (KEP).

4. Complaint to the CMB

You can report to the CMB in writing any transaction or practice you believe violates the legislation. A complaint is an administrative application: it may contribute to the exercise of the CMB's supervisory and sanctioning powers but does not by itself secure compensation for your individual loss, and it does not interrupt limitation periods.

5. Criminal complaint

  • For offences defined in or referred to by the Capital Markets Law, an investigation depends on a written application by the CMB to the public prosecutor's office; this is a procedural condition (Art. 115/1). If a public case is filed, the CMB becomes an intervening party (Art. 115/2).
  • For offences under the Turkish Penal Code (for example fraud or breach of trust), as a victim you may file a complaint with the public prosecutor directly. The basic form of breach of trust depends on a complaint, with a six-month complaint period running from the day the person learns of the act and the offender (TPC Art. 73). Heavier penalties apply where the offence concerns property entrusted through a professional, commercial or service relationship or the authority to manage another's property (TPC Art. 155/2).
  • A prosecutor's complaint and a CMB complaint are separate routes; one does not replace the other.

6. Compensation

If a breach of legislation or contract caused your loss, the following relationships may be assessed: the portfolio management company (duty to manage the fund in the interest of unit holders), the custodian (liable to unit holders for losses caused by failing its obligations, and unit holders' right to sue is reserved; Capital Markets Law Art. 56/2-3), and the institution that marketed or sold the fund (whether adequate information was given and suitability to the investor profile). The competent court, whether mediation is mandatory before suing (Consumer Law Art. 73/A for cases before consumer courts; Commercial Code Art. 5/A for monetary commercial claims) and the limitation period depend on the nature of the relationship. In tort, the general limitation period is two years from learning of the loss and the liable party, and ten years from the act in any case (Code of Obligations Art. 72); different periods may apply to contractual claims.

7. Administrative courts

CMB decisions are administrative acts. Those whose personal, legitimate and current interest is affected may bring an annulment action before the administrative court; the period is generally sixty days (Law No. 2577, Art. 7). Whether an individual investor has standing must be examined separately.

8. Summary of time limits

  • Administrative action: generally 60 days.
  • Complaint for offences requiring a complaint: 6 months from learning.
  • Tort compensation: 2 years / 10 years.
  • Where mediation is a precondition, apply to a mediator before suing.

If you would like your file assessed with its documents, you can create an appointment or reach us via the contact page.

This article is for general information only, contains no promise of results and is not legal advice.

This article is for general information only, it does not constitute legal advice.

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