1. Amendment to the Communiqué on Early Repayment Fees

The amendment to the Communiqué on the Procedures and Principles Regarding Fees That May Be Charged to Commercial Clients by Banks numbered 2020/4 (the “Communiqué”) was published in the Official Gazette on June 28, 2024, and came into effect on July 1, 2024. With this amendment, banks are now obliged to accept requests from commercial clients who wish to repay their loans in full before maturity. In cases of early repayment, banks may charge an early repayment fee, which will be calculated based on the amount repaid early, taking into account loan interest rates and other cost elements. Factors such as the loan’s maturity and type (Turkish Lira, foreign currency, or foreign currency-indexed) will influence the calculation of this fee.

2. New Regulations on Early Repayment Fees

The amendment introduces a distinction between fixed-rate and variable-rate loans in the calculation of early repayment fees:

• Fixed-Rate Loans

For Turkish Lira loans, the early repayment fee will be calculated using the formula determined by the Central Bank of the Republic of Türkiye, based on the loan interest rate and remaining maturity, provided that the calculated rate is not exceeded. For loans in foreign currency or foreign currency-indexed loans, the fee will be calculated based on a fixed rate and the remaining maturity.

• Variable-Rate Loans

For variable-rate loans, the early repayment fee may be up to 2% of the amount repaid early.

Additionally, different methods for calculating early repayment fees will apply to loans extended before March 1, 2021, and those granted between March 1, 2021, and June 30, 2024.

3. Loans Granted Before March 1, 2021

For loans issued before March 1, 2021:

• For Turkish Lira loans with a remaining maturity of 24 months or less, the early repayment fee cannot exceed 1% of the amount repaid.
• For loans with a remaining maturity exceeding 24 months, the fee cannot exceed 2%.
• For loans in foreign currency, the applicable fee will be increased by one percentage point.

4. Loans Granted Between March 1, 2021, and June 30, 2024

For loans granted during this period:

• For Turkish Lira loans with a remaining maturity of 24 months or less, the early repayment fee will be calculated at 2%.
• For loans with a remaining maturity exceeding 24 months, an additional fee of 1% will be applied for each year exceeding 24 months. Remaining durations will be calculated annually, and any excess over 24 months will be rounded up to the nearest year.
• For loans in foreign currency, an additional one percentage point will be added to the fees applicable to Turkish Lira loans.