Investor Compensation Center Application: Investors' Rights When an Investment Firm Cannot Pay

Under what conditions does YTM step in when a brokerage firm cannot pay?

Being unable to withdraw the money in an investment account, or the failure to deliver securities that are to be transferred to another institution, can create an urgent liquidity problem for an investor. For a person who planned to pay rent, a loan or education expenses with this money, the balance shown on the account screen is not enough on its own. The legal assessment begins with which institution the balance represents a claim against, and under which transaction that claim arose.

Under Article 82 of Capital Markets Law No. 6362, if SPK determines that an investment firm has failed, or will shortly be unable, to perform its cash payment or capital market instrument delivery obligations, it takes a decision to compensate investors. The three-month period provided for the decision runs from this determination. It cannot be treated as the same as the date of the first customer complaint. For banks, the opinion of BDDK is obtained; the same compensation provisions do not apply to debts that count as deposits and participation funds. K10

Are a compensation decision, a suspension of operations and a seizure the same action?

The suspension of operations, the liquidation of a fund, a change of management, a criminal investigation and the seizure of assets are actions with their own legal bases and consequences. For YTM compensation, the operative part of the decision should be checked for a provision on the compensation of investors. The bankruptcy of the firm or the conclusion of criminal proceedings is not a general precondition of the compensation decision under the Law. K1 K10

Stating only a trade name in the application may also be insufficient. A bank, a brokerage firm and a portfolio management company may be separate legal entities even if they belong to the same group. The account agreement, the custody record and the counterparty to the payment obligation must be identified together. It cannot be assumed that every institution and product subject to SPK regulation has the same YTM protection. The official announcement on the YTM membership of authorized investment firms must also be read together with the institution's authorization and the scope of the claim. K1 K7

How should the October 2026 fund liquidations be related to a YTM application?

SPK's announcement of October 1, 2026 set out the rules for an interim payment of up to 1 million TL per investor and per fund in the funds specified. The payment in the announcement depends on conditions such as net invested amount, reconciliation of records and set-off against the final liquidation payment. The 1 million TL here and the 2,065,145 TL compensation limit that YTM has announced for 2026 are amounts under different regulations. K27 K3

Currency also matters. SPK's Decision No. 70/1821 of October 15, 2026 was published in Bulletin No. 2026/70 of October 16. By this decision, the funds founded by Hedef Portföy whose liquidation was decided by the decisions of September 17, 2026 were removed from the scope of the interim payment decision No. 64/1775 of September 30. It was decided that the liquidation proceedings would begin on the terms set in Decision No. 64/1770 for the A1 Capital, Bulls and Pardus funds. Accordingly, the initial list in the October 1 announcement should not be reported as the current scope of payment without reading the later decisions. K28

The Bill on Certain Investment Funds Whose Liquidation Has Been Decided was also adopted by the Planning and Budget Committee on October 14, 2026. The status seen in the TBMM bill record in the October 18, 2026 research is the committee stage. That the bill provides for tasks to be given to YTM or TMSF does not mean that the provisions of the bill are in force, or that every fund investor can receive payment under the current YTM compensation regime. K29 K30

This distinction does not prevent more than one application arising from the same event. For example, while a fund liquidation continues, a delivery obligation that the brokerage firm has separately failed to perform may also be asserted. However, the debtor, amount and basis of each claim must be shown separately; the calculation must not be set up so as to lead to the same claim being collected twice. K1 K2

Which claims does YTM compensate, and which losses fall outside its scope?

Cash and securities delivery claims

The subject of compensation is the payment or delivery obligation relating to cash and capital market instruments that are held or managed in the investor's name in connection with an investment service or ancillary service. Giving a single total of "all my investment losses" in the application causes the undelivered asset to be confused with the loss arising from investment performance. Cash, the number of securities and, separately, any other loss items asserted should be broken down. K4

For example, a fall in the price of a share is different from the investor's shares not being found in the account. In the former, the market value has changed; in the latter, the question is whether the custody and delivery obligation has been performed. A loss in the value of a fund unit, a claim of liability that may be directed at the fund manager, and a brokerage firm's failure to pay a final sale price are likewise not the same type of claim. K4 K5

Price losses, crypto assets and unauthorized Forex transactions

Losses arising from investment advice or from market price movements fall outside the scope of YTM compensation. Money delivered to a person or company in a way unrelated to an investment service is also not protected merely because an investment purpose is stated. For crypto assets, Article 35/C of the Law contains an express exception. That an institution appears on the SPK list cannot be interpreted as meaning that every one of its products is insured by the state. K1 K5

Money sent to an unauthorized Forex platform should not be treated as the same as a customer claim at an authorized investment firm. For accounts that investment firms resident in Türkiye hold with foreign organizations, and for instruments issued abroad, the MKK/Takasbank custody or collateral condition in Article 16 of the Regulation is examined separately. For over-the-counter derivatives, the special condition on payment of the relevant YTM contribution is also taken into account. A general promise of payment cannot be given on the basis of a product name. K2

How is the 2026 YTM compensation limit applied?

YTM's official table states the maximum amount for 2026 as 2,065,145 TL. The same table shows 1,645,665 TL for 2025. The initial amounts in the Law or in the old regulation text should not be used as the current payment limit. Even if a file that began in earlier years is paid in 2026, this alone does not show that the 2026 ceiling will apply; the relevant decision, announcement and calculation must be examined separately. K3

The limit is assessed with respect to the total in-scope claims of the same investor against the same investment firm. The existence of different account numbers, currencies or products at the same institution does not give rise to a separate full ceiling for each. The Law also contains a restriction on attempts to obtain additional compensation by assigning the claim above the limit to another person. K13

Is the entire existing portfolio subject to this ceiling?

Under Article 15 of the Regulation, existing cash and capital market instruments that are distributed to the investor in kind are not counted toward the compensation limit. For this reason, the in-kind return of a portfolio whose existence and entitlement are established, and the compensation for the part that cannot be delivered, are calculated separately. K2

Hypothetical calculation: Suppose shares worth 5 million TL exist in the investor's name, and in addition a net cash claim of 3 million TL that is accepted as in scope cannot be paid. On the assumption that there is no debt, pledge or dispute and that the 2026 limit applies, the shares are returned in kind; for the 3 million TL, a compensation of 2,065,145 TL and a residual claim of 934,855 TL result. This example explains why the same person's total of returns and compensation may be higher than the annual ceiling. The stated example value of the shares is not a sale price or a guarantee of actual payment. K2 K3

Is double payment made on a joint account?

The Regulation treats a joint account as a single account; payment is made according to the ratio of entitlement, or equally if the ratio cannot be determined. The actual shares of entitlement, the holders' other claims at the same institution, and the limit based on person and institution must be assessed together. The mere presence of two names on the account does not show that double the maximum payment will be made. K2 K13

How do the account record, set-off and valuation affect the claim?

If the MKK record and the institution's statement do not match

MKK's e-YATIRIMCI service can be used to examine investment account and transaction information. The application screen, periodic statements and the investment firm's transaction records should be compared. An MKK query does not by itself replace a YTM compensation application. Especially for incomplete settlements, transfers and cash movements, the transaction date and the value date should be recorded separately. K14

That an asset does not appear in the institution's account does not mean that the right definitely does not exist. The Regulation allows for the evaluation of off-record cash and securities whose entitlement is determined by a final court judgment or which YTM accepts as belonging to the investor. For this reason, it cannot be said that every investor must win a lawsuit before applying. If a conflict between documents cannot be resolved, a need for a judicial determination may arise separately. K2

Is a debt asserted by the institution deducted directly?

As a rule, the cash and securities belonging to the investor are tracked separately from the institution's assets. The inability to resort to customer assets for the institution's debts is not the same matter as an attachment, pledge or valid set-off arising from the investor's own debt. K1

In the compensation calculation, valid debt and set-off items are assessed and the net claim is determined. If a debt is demanded from the investor on account of credit use, commission or an incomplete transaction, the contract, the amount and the transaction record should be examined. Objecting to an erroneous debt entry is as important as objecting to a missing claim entry, because an accepted debt may reduce the net amount payable. K11

For the compensation value of a capital market instrument that cannot be delivered, the date of the compensation decision and the relevant valuation rules are used. The purchase price, a later market peak or the price on the day of application is not applied automatically. For securities to be returned in kind, bonus issues, coupons and similar rights between the decision and the distribution are also taken into account. K2 K16

Where, how and within what period is a YTM application made?

The application is made in writing to YTM, following the compensation announcement relating to the institution concerned, with documents showing entitlement. The annexes to the announcement, the version of the form, the method of delivery and the documents requested should be examined specifically for the file. A phone call, a social media notification or a general complaint should not be used on the assumption that it replaces the compensation application set out in the announcement. K8

From which date does the one-year period run?

The period in Article 85 of the Law is a one-year statute of limitations from the announcement of the compensation decision. The legal nature of the period should not be changed into a "forfeiture period." The day the investor learned of the event, the date on which the investor needed the money, or the last account transaction is not the general starting point of this special period. K9 K11

The initial application schedule in the announcement also matters. The first announcement for Toros in 2016 stated a two-month application schedule for preparing the list, and for claims outside the list the one-year period was tied to the announcement in the Turkish Trade Registry Gazette (Türkiye Ticaret Sicili Gazetesi). The two months in this old announcement are not a general period that applies to all new files. An investor should not postpone following the first announcement's schedule in reliance on the one-year outer limit. K15

Is an application via e-Devlet or e-mail sufficient?

The amendment of July 16, 2026 regulated the e-Devlet procedure for the refund from YTM of time-barred deposits and claims. This amendment did not move all compensation applications concerning an investment firm's payment difficulties to the same digital channel. K24

The method accepted by the file-specific announcement should be followed. For example, in Toros's 2024 liquidation balance announcement, the signed form was requested to be delivered by hand or by mail, and it was stated that electronic and fax applications would not be considered. This rule is the procedure of that announcement; for any other current file, the form and method must be read afresh. The proof of delivery of the application should be kept together with a copy of the text sent and its annexes. K20

Which documents should the application file contain?

The application must be suitable for examining the source and calculation of the claim. The list below is a framework for preparing the file; the specific document requests in the official announcement are fulfilled separately. K8 K15

1. The full name of the investment firm, the account number and the relevant contract.
2. The SPK compensation decision, the announcement and the current application form.
3. Account statements, MKK records, money transfer receipts and transaction listings.
4. The sale, payment or transfer instruction; transmission, execution and value date information.
5. An explanation of the calculation showing cash, securities and asserted debts separately.
6. Documents on previous payments and refunds, pledges, attachments, injunctions or pending disputes.
7. Identity, entitlement, representation or heirship documents, and suitable recipient account details.
8. Proof of delivery of the application and subsequent correspondence.

The statement of the claim should show, for example, on which date the amount sent was not credited to which account, or how many units of which security were not delivered. The difference between the total given by the institution and the investor's own calculation should be explained separately. Instead of settling for a screenshot, requesting all the movements of the relevant period can prevent the same amount from being written twice, as both cash and securities.

Heirs and applicants through an attorney

An heirs' application to protect the estate's right and payment of the entire claim to a single heir are different actions. Entitlement, shares and authority of representation must be determined under the provisions of the Turkish Civil Code on the acquisition of an inheritance and on joint ownership of the estate. An heir's late discovery of the account does not by itself cause the period that runs from the compensation announcement to start again. K26 K9

The announcement concerned may request a certificate of heirship, a tax document, or the original or a certified copy of a power of attorney. Toros's 2024 announcement contains special annexes to this effect. No generalization should be made that the same document is required in the same form in all compensation applications. K20

Why is the creditors' list decisive?

YTM prepares the list showing investors' claims and debts on the basis of the institution's records and applications. That an application has been sent does not mean that the amount requested has been accepted as it stands. The investor should check, in their own row, the amount of the claim, the number of securities, the debt set-off, the currency and any dispute entry. K2 K16

How is an objection to the list made within thirty days?

The Regulation provides for an objection to YTM within thirty days from the announcement of the list. For an objection made by mail, the date of posting is decisive. This express rule should not be extended to mean that the first compensation application is also completed on the date of posting in every case. K2 K16

The objection should state the item considered wrong, the amount asserted to be correct and the supporting record. If a missing transfer, an erroneous debt, a wrong price or a cash inflow that does not appear are each explained separately, the review is made easier. For a claim that does not appear in the list at all, an application within one year and, if accepted, the preparation of a supplementary list are possible; the charging of the costs arising from a late application to the applicant is regulated separately. K2 K17

Is the end of the fourth month a deadline for all lawsuits?

The special provision in Article 12 of the Regulation concerns the preservation of the blockage on securities in custody that are the subject of an objection. If the objection has been rejected, YTM must be notified by the end of the fourth month following the announcement of the list that judicial proceedings have been brought; otherwise the securities may become part of the institution's assets. If notification has been made, the blockage continues until a final court judgment. K2 K16

This provision is not a general four-month limitation period for lawsuits on every cash claim. The judicial route, the limitation period for a lawsuit and the notification needed to preserve the blockage must be assessed separately. The existence of a disputed portion does not necessarily require a claim that has been accepted and is not in dispute to await the end of the same proceedings. K2

How are the application, list and payment periods tracked?

The periods in the table cannot be tied to the same starting point. The Law sets the payment period from the determination of the persons entitled and of the amounts; the Regulation is based on the announcement of the list. For this reason, the result "all the money is paid three months after the application" cannot be drawn. K10 K11 K2

The extension relating to preparation of the list and the extension of up to three months relating to the payment period are also different. Indeed, YTM's 2016 Toros announcement stated that the period for preparing the list was extended by a total of five months, first three and then two. Keeping the announcements in chronological order makes it possible to understand which stage was extended. K31

Whose claims may fall outside compensation?

The Law and the Regulation provide exceptions for certain managers and shareholders of the institution, for persons and companies with group relationships, and for persons who have responsibility for or an interest in the financial deterioration. The spouses of managers and certain shareholders, their blood and in-law relatives up to the second degree, and those acting in their names are also evaluated under the relevant provisions. Because there are special cases relating to certain shareholding ratios and omnibus custody accounts, the examination as to the person is not complete merely on the statement "I am a customer." K6

On the other hand, the status of qualified or professional investor is not listed in the exception list as a general ground of exclusion on its own. This is a legal assessment arising from reading the relevant provisions together. The fact that a large portfolio or a risk notice has been signed does not on its own eliminate all delivery claims; the specific exception and the nature of the claim are investigated. K6 K13

Is the payment to a victim who has filed a criminal complaint suspended?

There are special provisions for claims relating to the misuse of information, market fraud, or the laundering of assets derived from crime. The claim of a person convicted of these offenses, arising from the acts concerned, falls outside compensation; an investigation of the investor personally for these offenses may cause payment to be suspended until a final decision. K5 K13

The investor's filing of a criminal complaint against the institution or its managers as a victim is not the same situation as this exception. In the application, the capacity in the criminal file, the act under examination and its connection with the claim should be explained. A general note such as "there is a criminal file" may not show whether the person is a suspect or an injured party.

Can interest and delay damages be requested on the compensation payment?

Article 14 of the Regulation provides that no interest is applied to cash claims for the period between the compensation decision and payment to the investor. The addition of commercial default interest for this period to the YTM payment account on its own should not be expected. The same special rule is expressly stated in Toros's creditors' list announcement. K2 K16

This provision does not settle, in a single rule, claims for interest or damages against all debtors for all periods. Article 86 of the Law separately regulates the determination by SPK of default interest for the process between compensation and liquidation. For additional damage asserted on account of a fund sale instruction that was not carried out, the breach of a specific payment undertaking, or an unlawful transaction, the relevant liability relationship must be established separately. K12

Accordingly, the assertion "I waited a long time" does not provide an automatic additional payment in the YTM compensation calculation. The waiting periods, the person alleged to be liable, the basis of the claim and the documented loss should be shown separately. If loan interest or another necessary expense is asserted, the incurrence of that expense and its connection with the uncollected claim are examined. If the same loss has been paid before, that payment must also appear in the calculation.

What happens to the claim above the compensation limit and to seized assets?

YTM is subrogated to the investor's right up to the amount it has paid. This does not mean that the unpaid residual claim ceases to exist. In the gradual liquidation of an investment firm other than a bank, the aim is for the remaining investor claims and YTM's claim to be paid out of the firm's assets. This liquidation of the investment firm is a process separate from the liquidation of an investment fund. K11 K12

The liquidation balance is allocated to investors' remaining claims; if it is insufficient, proportional distribution comes into play. For any surplus, the ranking applicable to the public authorities, YTM and other creditors is applied. The residual amount not paid to the investor should be tracked with regard to the relevant distribution list and later collections. K2

Can enforcement proceedings be started immediately for the residual amount?

During gradual liquidation there are special prohibitions and stays on proceedings under the Enforcement and Bankruptcy Law and Law No. 6183. For this reason, the suggestion that "enforcement proceedings can be brought immediately for the amount above the limit" is not correct without determining the stage. The liquidation decision, the status of any existing proceedings, the claim record and the open routes of application should be examined together. K12

SPK's granting YTM the power of disposition over assets, the liquidation actions, protective measures requested from the court, and the seizure in a criminal investigation also have different bases. That assets have been identified or protected does not mean the investor is paid the same day. Which asset belongs to whom, to which claim it can be allocated, and which distribution procedure applies are determined separately. K1 K2

What does the Toros example show an investor awaiting payment?

The official file on Toros Menkul Kıymetler Ticaret AŞ shows that the compensation stage and the later payments from the liquidation balance should be tracked separately. The chronology below is not a summary of a court decision but a comparison of the actions and announcements published by YTM. K18 K19

The 2024 announcement provides for an additional payment to those who had previously received a partial payment and, for those applying for the first time, payment of the whole of the claim in the liquidation balance distribution list of 2018. This announcement does not mean that everyone on the list actually received the money, that all investment losses were paid, or that a new compensation application period was opened. K19 K20

The submission of the current form and annexes was requested for payment. The announcement provides for payment or transfer of securities within one month at the latest after a complete application, while separate waiting conditions are stated for attachments, injunctions and pledges on the account. This one-month schedule specific to this file should not be written in place of the general YTM compensation period. K20

How should a payment form containing a release and a waiver be assessed?

Toros's 2024 application form contains broad statements to the effect that principal and ancillary claims have been collected, that no other rights remain, and that pending lawsuits or proceedings are waived. For this reason, the form should not be treated as a document that merely updates an IBAN or contact details. K21

The amount in the form should be compared with the claim in the list, previous payments, and pending lawsuits or proceedings. Which claim and which parties the statement covers, the applicant's authority of representation, and the items asserted to be still unpaid should be clear. It cannot be said that all release clauses are invalid or that adding a unilateral note to the form will definitely secure payment. The review should be made on the specific form and account.

What route is followed if the application is rejected or the claim is accepted in part?

The first step is to obtain in writing the reasoning for the rejection or partial acceptance and the underlying calculation. The dispute may rest on entitlement, being outside the scope, set-off, valuation, time limits or a measure. Each requires different documents and a different legal assessment.

The administrative judicial route against SPK decisions is regulated in Article 134 of the Law. A YTM action, a dispute over the list and a private-law claim against the investment firm must be determined separately according to the subject of the claim, the legal nature of the action and the defendant. A categorical recommendation that sends all disputes to a single court ignores these distinctions. K1

In administrative courts, the general period for filing an action is sixty days unless there is a special provision; its start is calculated according to the relevant notification and the type of action. An application complying with Article 11 of the Administrative Procedure Law (İYUK), if made in time, suspends the running of the filing period; after rejection, or after thirty days of silence, the remaining period resumes. It cannot be assumed that every YTM objection suspends the filing period of every lawsuit. K25

The thirty-day objection period for the list and the fourth-month notice that preserves the blockage of a disputed security should also be calendared separately. Waiting for the outcome of a criminal investigation or of an application to another authority is not a general method that automatically preserves the compensation and litigation periods. K2

How should an investor act so that the harm does not grow?

The priority of a person awaiting payment is to build a single file that makes their right and time limits visible. The relevant decisions and announcements should be kept in chronological order; the claim calculation should be prepared with a separation of cash, securities, debt and previous payment. Missing records should be requested in good time, the list announcement should be followed separately, and whichever item is in dispute should be explained with documents.

YTM's announcement of July 24, 2025 reported notifications about persons saying that they would compensate Forex, crypto and equity market losses in return for a commission or service fee. The announcement of July 29, 2025 reported that YTM's websites were being imitated and that personal information, credit card information and fees were being requested. These official statements show the concrete risk of making a second payment in the hope of recovery. K22 K23

YTM's statement that it does not charge a fee for its own services should not be extended to mean that no application can ever involve any expense. The cost of a late application, and postage or document expenses, are separate matters. A promise of "send a commission first, and all your loss will be paid under state guarantee" is incompatible with the scope of official compensation. The application address and the payment announcement should be verified from the official source, independently of the link sent by the person who calls. K23 K2

Conclusion

A sound YTM application depends first on whether there is a compensation decision on the investment firm concerned, on whether the claim is in the nature of a payment or delivery claim, and on actual entitlement. When the in-kind return of existing assets, compensation subject to the limit, and the residual claimed from the liquidation are shown separately, the investor can set out clearly what is being requested at which stage.

As much as the announced limit of 2,065,145 TL for 2026, the one-year limitation period for applications, the thirty-day objection period for the list and the special blockage notice are important. Following the current fund decisions and the later announcements in past liquidation files prevents the application from being built on an old or different payment regime. When payment and release documents are examined together with the claim calculation, the scope of the remaining rights can also be determined more soundly. K2 K3 K9 K19

Frequently Asked Questions

My fund has been liquidated; will YTM pay me automatically?

A fund liquidation alone does not create a right to YTM compensation. The compensation decision on the relevant investment firm, the nature of the claim and the scope conditions are examined. A fund interim payment is also a separate regulation. K1 K27

What is the most YTM compensates in 2026?

In the official table, the 2026 maximum is 2,065,145 TL. The in-scope claims of the same investor at the same institution are assessed together. The annual amount applicable to an old file must be determined separately. K3 K13

Must the value of all the shares in my account stay below this limit?

Cash and securities that exist and are distributed in kind are not counted toward the compensation limit. The limit is assessed for the in-scope compensation claim remaining outside this return. K2

How long is the YTM application period?

There is a one-year statute of limitations from the announcement of the compensation decision. The application schedule and annexes of the first announcement should be followed separately. K8 K9

What should I do if my amount in the creditors' list is incomplete?

A reasoned objection is made to YTM within thirty days from the announcement of the list. The wrong amount or number of securities is shown with the correct calculation and supporting documents. K2 K16

Must I file a lawsuit first for money that does not appear in my account?

A prior court judgment is not required in every application. Off-record assets that YTM accepts as belonging to the investor may also be evaluated. If a dispute over entitlement cannot be resolved, a court decision may be needed. K2

Does filing a criminal complaint against the institution prevent compensation?

Filing a criminal complaint as a victim is not the same as the payment-suspension provision relating to the investigation of the investor for certain offenses. The capacity in the criminal file and the connection with the claim are important. K5 K13

Can I receive automatic interest from YTM for the period I waited?

There is a special rule that no interest is applied to a cash claim for the period between the compensation decision and payment. Interest and damages claims for other periods or against other debtors are examined separately. K2 K12

Is my claim above the compensation ceiling extinguished?

Payment does not extinguish the remaining claim automatically. For the residual, the liquidation and other suitable routes are examined, with regard to the prohibitions on proceedings in gradual liquidation. K11 K12

Must I sign every release form sent to me in order to be paid?

The effect of the text to be signed on the payment amount, the remaining claim, and pending lawsuits and proceedings should be examined. Toros's 2024 form contains broad release and waiver statements; forms in other files are assessed on their own content. K21

Sources

The sources were checked on October 18, 2026. Legislation, official practice announcements and the bill have been kept separate from one another. The sample calculation is hypothetical; the Toros chronology is based on official actions and announcements.

K1 Capital Markets Law No. 6362, in particular Arts. 3, 35/C, 46, 82–86 and 134. Current text from SPK: mevzuat.spk.gov.tr

K2 Regulation on Compensation of Investors and the Gradual Liquidation Procedures and Principles (Yatırımcıların Tazmini ile Tedrici Tasfiye Usul ve Esasları Hakkında Yönetmelik), in particular Arts. 5–17, 20, 22 and 28–30; current consolidated text: ytm.gov.tr

K3 YTM, maximum compensation amounts by year; 2026: 2,065,145 TL. ytm.gov.tr

K4 YTM, cash payment and capital market instrument delivery claims within the scope of compensation. ytm.gov.tr

K5 YTM, losses outside the scope of compensation. ytm.gov.tr

K6 YTM, persons and institutions not compensated. ytm.gov.tr

K7 YTM, membership of investment firms. ytm.gov.tr

K8 YTM, procedure for investor compensation claims. ytm.gov.tr

K9 YTM, application period for compensation claims. ytm.gov.tr

K10 YTM, Capital Markets Law Art. 82: decision to compensate investors. ytm.gov.tr

K11 YTM, Capital Markets Law Art. 85: compensation process and subrogation. ytm.gov.tr

K12 YTM, Capital Markets Law Art. 86: gradual liquidation. ytm.gov.tr

K13 YTM, Capital Markets Law Art. 84: scope, exceptions and total claims at the same institution. For the initial amount, the annual table at K3 and, for the current wording of the Law, K1 have been taken as authoritative. ytm.gov.tr

K14 Central Registry Agency (Merkezi Kayıt Kuruluşu, MKK), e-YATIRIMCI service. mkk.com.tr

K15 YTM, first announcement on the compensation and gradual liquidation of Toros investors, Turkish Trade Registry Gazette (Türkiye Ticaret Sicili Gazetesi), 13.01.2016. ytm.gov.tr

K16 YTM, Toros creditors' list announcement, 2016. ytm.gov.tr

K17 YTM, Toros supplementary creditors' list announcement, 2017. ytm.gov.tr

K18 YTM, Toros investor compensation actions and closing information of 24.05.2018. ytm.gov.tr

K19 YTM, announcement of the increase of the Toros liquidation balance distribution rate to 100 percent, 26.04.2024. ytm.gov.tr

K20 YTM, distribution of the Toros liquidation balance and application conditions, April 2024. ytm.gov.tr

K21 YTM, Toros liquidation balance application form, April 2024; release and waiver statements. ytm.gov.tr

K22 YTM, Announcement on Fraud Committed Through Communication, 24.07.2025. ytm.gov.tr

K23 YTM, announcement on imitation websites and fee demands, 29.07.2025. ytm.gov.tr

K24 Amendment to the Investor Compensation Center Regulation (Yatırımcı Tazmin Merkezi Yönetmeliği), Official Gazette 16.07.2026/33311; refund procedure for time-barred deposits. ytm.gov.tr

K25 Administrative Procedure Law No. 2577 (2577 sayılı İdari Yargılama Usulü Kanunu), in particular Arts. 7, 8 and 11. Ministry of Justice Legislation and Case Law Program: mevzuat.adalet.gov.tr

K26 Turkish Civil Code No. 4721, in particular Arts. 599 and 640. Ministry of Justice Legislation and Case Law Program: mevzuat.adalet.gov.tr

K27 SPK, Announcement on Interim Payments for Funds in Liquidation, 01.10.2026. spk.gov.tr

K28 SPK, Bulletin No. 2026/70 of 16.10.2026, p. 7; Decision No. 70/1821 of 15.10.2026. spk.gov.tr

K29 TBMM, Bill No. 2/3939 on Certain Investment Funds Whose Liquidation Has Been Decided; legislative status seen on 18.10.2026. tbmm.gov.tr

K30 TBMM, news item on the adoption of the bill in the Planning and Budget Committee, 14.10.2026. tbmm.gov.tr

K31 YTM, extension of the period for preparing the Toros creditors' list, 28.08.2016. ytm.gov.tr