Status of Fund Investors Whose Redemption Orders Have Not Been Executed During the Liquidation Process
In anticipation of proposed legislation and further regulatory measures concerning investment funds subject to liquidation by decision of the Capital Markets Board (the “CMB”), please find below our information note on the position of investors whose redemption orders submitted before September 17 remain unfulfilled and the implications for their claims in the liquidation process.
Status of Unexecuted Fund Redemption Orders
All orders submitted to the Electronic Fund Trading Platform (the “EFTP”) on or before September 16, 2026, will be processed through the EFTP in accordance with the relevant funds' standard pricing and settlement periods. Redemption orders submitted to the EFTP on or before such date that could not be executed for any reason remain valid. However, while some of the orders submitted by investors during this period were successfully transmitted to the EFTP, others were rejected or canceled by the relevant banks or iintermediary institutions.
As the stage at which an order remained pending and whether it was transmitted to the EFTP may affect investors' claims during the liquidation process, it is important to determine the status of unexecuted orders. In this regard, records maintained in the EFTP Transaction Blocking Subaccount (the “PBLK”) and the Free Account within the Central Securities Depository of Türkiye (the “CSDT”) system, as well as indications such as “canceled”, “rejected”, or “not executed” displayed on the relevant bank or intermediary institutions's systems, may be taken into consideration.
Status of Investors Whose Orders Are Recorded Under PBLK Status
The recording of fund units under the PBLK code in the MKK records indicates that such units have been blocked in connection with a EFTP transaction.
Pursuant to the CMB’s decision, amounts arising from redemption orders submitted through the EFTP but not executed are accrued as liabilities of the fund. This provision also applies to orders submitted to the EFTP before September 17, 2026, that could not be executed due to the fund's default or failure to announce a price. Investors falling within this scope are considered priority creditors of the fund in respect of such amounts. Their claims are satisfied on a priority basis from the proceeds obtained through the liquidation of the fund’s assets.
Accordingly, the reconciliation of unexecuted orders between the CSDT and the banks conducting the liquidation process is important for confirming the stage at which each order remained pending.
Status of Investors Whose Orders Were Canceled or Rejected
The indication of an order submitted before September 17, 2026, as “not executed”, “canceled”, or “rejected” in a bank’s or intermediary institution’s system does not, in itself, determine the investor's legal status in the liquidation process. If an order was rejected before being transmitted to the EFTP, the investor may receive a payment from the remaining liquidation proceeds in proportion to their ownership of fund units. However, if the failure to transmit the order resulted from an operational error, system malfunction, or breach of obligations by the relevant institution, liability for damages may also arise, depending on the existence of fault, loss, and a causal link between them. Therefore, investors should retain records of the date and time of their orders, order reference numbers, and rejection or cancellation notices, and request written confirmation from the relevant institution of the the EFTP transmission and cancellation records, together with the reasons why the transaction could not be completed.
Is the Status of Investors Who Submitted Redemption Orders on September 17 Different?
Yes. Since the orders submitted to the EFTP on September 17, 2026, were canceled, no liabilities arising from such redemption orders will be accrued to the fund, nor will any such amounts be paid on a priority basis from the liquidation proceeds. These investors will continue to hold fund units and will be entitled to receive a proportionate share of the remaining liquidation proceeds based on their ownership of fund units.
