OJK Issues New Guidelines for Peer-to-Peer Lending Business

On November 8, 2023, the Financial Services Authority (Otoritas Jasa Keuangan or “OJK”) issued OJK Circular Letter No. 19/SEOJK.06/2023 on the Implementation of Information Technology Based Collective Financing Services (“Letter 19/2023”). Letter 19/2023 sets out a detailed guideline for the implementation of OJK Regulation No. 10/POJK.05/2022, dated June 29, 2022 on Information Technology Based Collective Financing Services (“OJK Reg. 10/2022”).

In Letter 19/2023, OJK lays out a more comprehensive list of requirements in performing the Peer-to-Peer Lending (the “P2P Lending”) business process to fill in the gaps where OJK Reg. 10/2022 is silent. The topics covered under this Newsflash relate to the operations of business activities, fund distribution, repayment mechanism, outsourced work, interest rates, and payment success rates. We set out the salient provisions of Letter 19/2023 below.

♦ Business Activities of P2P Lending Provider

OJK Reg. 10/2022 states the business activities of a P2P Lending Provider (a “Provider”) consist of (i) provision (penyediaan), (ii) management (pengelolaan), and (iii) operation (pengoperasian) of the P2P Lending. Further definitions of such elements of business activities that shall be performed by a P2P Lending Provider are not set out under OJK Reg. 10/2022.

Now, Letter 19/2023 specifically clarifies the details of each type of business activity, as follows:

  1. Provision Business Activity: providing an electronic system that brings together a borrower and a lender in a funding or lending transaction and providing other facilities such as customer services, virtual accounts, and escrow accounts;
  2. Management Business Activity: conducting activities including user identity verification, users’ private data processing, funding or lending disbursement from lender to borrower, fund repayment from borrower to lender, and debt collection; and
  3. Operation Business Activity: performing operational activities of the Electronic System it owns in full.

♦ Fund Disbursement and Repayment Mechanism

Letter 19/2023 provides a comprehensive procedure for a lender and a borrower in receiving and disbursing funds within a Provider’s platform. Prior to approving certain funds to be provided by a lender, a Provider shall conduct an analysis by way of (i) verification of a document’s authenticity submitted by a lender, (ii) confirmation and clarification to the lender on matters regarding anti-money laundering and counter-terrorist financing, and (iii) an analysis of the prospective lender.

From the borrower’s side, a Provider shall conduct a credit scoring on a prospective borrower before a borrower may borrow through the platform. Following a borrower’s request to borrow funds, a borrower’s credit scoring shall be conducted by way of (i) verification of the document’s authenticity submitted by the borrower, (ii) confirmation and clarification to the borrower on matters regarding anti-money laundering and counter-terrorist financing, (iii) process of data from other relevant third parties for the purpose of scoring (if necessary), and (iv) an analysis of the prospective lender. Based on such analysis, the Provider shall determine whether or not a borrower is eligible for the disbursement of funds in the Provider’s electronic system.

Letter 19/2023 explicitly states that the scoring conducted by a Provider shall take into account the character and repayment capacity of the prospective borrower. It is stipulated under Section IV.3.i of Letter 19/2023 that scoring on the repayment capacity for consumptive funding or lending shall be conducted by way of comparing the total amount of the principal payment amount and economic benefits that are paid by the borrower with the income of the borrower. The repayment capacity of the borrower is set to be at a maximum of:

  1. 50% (fifty percent) on the first year since the issuance of Letter 19/2023;
  2. 40% (forty percent) on the second year since the issuance of Letter 19/2023; and
  3. 30% (thirty percent) on the third year since the issuance of Letter 19/2023.

Once the analysis for both the prospective lender and the borrower is complete, the prospective lender may choose the prospective borrower on a Provider’s electronic system and proceed with the execution of the P2P Lending agreement using an electronic signature. Thereafter, the payment mechanism of the funding or lending shall be disbursed by the lender through a payment gateway or a virtual account to be placed in the Provider’s escrow account which will be further transferred to the borrower.

♦ Prohibition on the Utilization of an Outsourced Worker

OJK Reg. 10/2022 stipulates that a Provider is permitted to have an outsourcing agreement through (i) a job-chartering agreement; and/or (ii) an outsourcing agreement. However, Article 19(2) of OJK Reg. 10/2022 limits that the work function of assessment of funding or lending feasibility and/or information technology may not be outsourced to another third party.

Under Section V.5 of Letter 19/2023, such function is elaborated to cover that the prohibition on the outsourced work on the works that perform the function of assessment of funding or lending feasibility is only regarding the scoring of the funding or lending feasibility. In line with the foregoing, a Provider may still cooperate with a credit information processing agency to increase the data reference in conducting the funding or lending feasibility scoring.

Letter 19/2023 further stipulates that the prohibition of outsourcing in the information technology works which essentially relates to the development and operation of the information technology, which comprise of (i) user access management activities, (ii) database management activities, (iii) backup and restore activities, (iv) troubleshooting, and (v) disaster recovery.

♦ Interest Rates for P2P Lending

Previously, the interest rate for P2P Lending Activities was only regulated under the Indonesia Fintech Lending Association (Asosiasi Fintech Pendanaan Indonesia or “AFPI”) Code of Conduct which was amended periodically since its first issuance in 2018 and its latest amendment in 2021. Under such AFPI Code of Conduct, the applicable rate is a maximum of flat interest rate of 0.4% per day, calculated based on the principal lending amount.

While OJK Reg. 10/2022 does not stipulate any maximum interest rate, Articles 29(1) and (2) of OJK Reg. 10/2022 require Providers to fulfill provisions on the maximum limitation of funding or lending economic benefits (batas maksimum manfaat ekonomi), which will be determined by OJK.

OJK through its Letter 19/2023 now stipulates the maximum limit of funding or lending economic benefits. To clarify, economic benefits that are imposed by a Provider are the return rate which includes: (i) interest/margin/profit sharing, (ii) administration fees/commission fees/platform fees/ujrah (compensation fees in syariah) equivalent to the relevant fees, and (iii) other costs, other than late fines, stamp duty, and taxes.

The maximum limits of funding or lending economic benefits under Letter 19/2023 are as follows:

  • For productive funding or lending:
    1. 0.1% (zero point one percent) per calendar day of the value of the funding or lending balance, which is valid for 2 (two) years from January 1, 2024; and
    2. 0.067% (zero point zero six seven percent) per calendar day of the value of the funding or lending balance, which is valid from January 1, 2026.
  • For consumptive funding or lending:
    1. 0.3% (zero point three percent) per calendar day of the value of the funding or lending balance, which is valid for 1 (one) year from January 1, 2024;
    2. 0.2% (zero point two percent) per calendar day of the value of the funding or lending balance, which is valid for 1 (one) year from January 1, 2025; and 0.1% (zero point one percent) per calendar day of the value of the funding or lending balance, which is valid from January 1, 2026.

The above rates are also applicable for the maximum limit of late fines according to Sector VI.4 of Letter 19/2023.

Similar to the provision under AFPI Code of Conduct, Letter 19/2023 clarifies that all economic benefits and late fines that may be imposed on the borrowers may not exceed 100% (one hundred percent) of the funding or lending value that is stated in the funding or lending agreement.

♦ Introduction of a New Payment Succes Rate

Before the issuance of Letter 19/2023, there was only one criterion for a Payment Succes Rate (Tingkat Keberhasilan Bayar or “TKB”), as governed under OJK Reg.10/2022, namely TKB90. Letter 19/2023 introduces additional TKBs, which are TKB 0, TKB30, and TKB60. These TKBs are the rate for success payment by the Provider in facilitating the completion of funding or lending obligation within 0 calendar days for TKB0, 30 calendar days for TKB30, 60 calendar days for TKB60, and 90 calendar days for TKB90.

Similar to the previous requirement under OJK Reg.10/2022, the TKB shall be published in the electronic system of the Provider as part of the funding or lending performance of a Provider along with the value of distributed funding or lending, the number of lenders, and the number of borrowers.

 

AKSET

Please contact Johannes C. Sahetapy-Engel (jsahetaypyengel@aksetlaw.com), Clara Anastasia So (canastasia@aksetlaw.com), and Ammarsyarif G. Goenawan (agoenawan@aksetlaw.com) for further information.

Disclaimer:

The foregoing material is the property of AKSET and may not be used by any other party without prior written consent.  The information herein is of general nature and should not be treated as legal advice, nor shall it be relied upon by any party for any circumstance.  Specific legal advice should be sought by interested parties to address their particular circumstances.

Any links contained in this document are for informational purposes and are available and relevant at time this publication is made.  We provide no liability whatsoever in respect of any information or content in such links.

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OJK Issues New Guidelines for Peer-to-Peer Lending Business

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by Pilanita Silaen

Regulatory Overhaul for P2P Lending Business Finally Issued

The Financial Service Authority (“OJK”) recently issued OJK Regulation No. 10/POJK.05/2022 dated July 4, 2022 on Information Technology Based Collective Financing Services (“POJK 10/2022”). POJK 10/2022 revoked the previous regulation, namely OJK Regulation No. 77/POJK.01/2016 of 2016 dated December 29, 2016 on Information Technology-based Lending Services (“POJK 77/2016”), which was originally introduced to quickly response to the then-growing Peer-to-Peer Lending (“P2P Lending”) industry. Now, due to increasingly complex development of the P2P Lending industry, a highly comprehensive regulatory framework is needed to safeguard the industry.

Since its inception, the P2P Lending industry in Indonesia saw remarkable growth, with factors such as digital revolution, public interest in new financial technologies and a huge potential market, all contributing to the industry’s upward momentum. However, the expedited growth of the P2P Lending industry also gave rise to its fair shares of issues, such as poor industry practices (i.e., debt collection, data protection, exorbitant interest rates) and more notably, a pervasive growth in illegal P2P Lending activities.

Over the years, the OJK has been committed to improving the P2P Lending ecosystem, closely monitoring its players and cracking down on illegal P2P Lending companies. To this end, the OJK has even enacted a moratorium on the issuance of new P2P Lending licenses, to ensure that a more mature legal framework is in place before further growth of the industry.

POJK 10/2022 represents a culmination of the OJK’s efforts to improve the P2P Lending sector. Provisions under this new regulation prove to be far more extensive compared to the previous regime, governing aspects of the industry that POJK 77/2016 was previously silent on. Additionally, POJK 10/2022 also codifies some of the more essential provisions and policies previously scattered under the OJK’s derivative regulations under one legal product. All in all, the issuance of POJK 10/2022 imposes more stringent standards on the P2P Lending industry as a whole. Although POJK 10/2022 provides a much-needed governance to the P2P Lending industry, the comprehensive set of rules and requirements also invites more questions and issues in regard to the implementation of the newly introduced provisions.

Please see below for an overview of POJK 10/2022.

  • Revamping of the Licensing Regime

Under the previous regime of POJK 77/2016, the entry policy for P2P Lending business required a P2P Lending Provider (“Provider”) candidate to register first before applying for a business license (at the latest, 1 year after being registered).

Back in 2016, P2P lending was a completely new industry in Indonesia. Despite that, the business had already attracted many players. POJK 77/2016 (along with its registration-licensing regime), to some extent, was intended to provide an interim governance to nurture the development of the industry while at the same time safeguarding its operation in Indonesia.

Now, similar to other more mature financial services, the new POJK 10/2022 revamped the industry’s entry policy regime by enforcing a sole-licensing regime as a requirement to conduct its business in Indonesia.

Although the licensing process and requirements are quite similar with the licensing phase under POJK 77/2016, POJK 10/2022 adds as follows:

  1. an obligation for a Provider to immediately carry out Electronic System Operator (ESO) registration within 30 (thirty) calendar days as of the issuance of business license by OJK;
  2. submission of additional required documents, such as copies of tax return form of the last 2 (two) years for individual shareholder candidates, business feasibility studies for the first 3 (three) years, confirmation from relevant supervisory authority in the country of origin of the foreign shareholders.
  • Capitalization

Previously, POJK 77/2016 required a Provider to have a paid-up capital in the amount of at least Rp2,500,000,000 (two billion five hundred million Rupiah) at the time of licensing. Under POJK 10/2022, the amount is increased to at least Rp25,000,000,000 (twenty five billion Rupiah). POJK 10/2022 also requires the capital to be paid-up in full, cash, and stored in a form of time deposit.

Please note that this capitalization only applies for new Provider candidates, while existing licensed Providers, Providers which are in the licensing phase, and Providers which have returned their registration certificates and would like to resubmit its licensing application are exempted from this requirement.

  • Minimum Equity

POJK 10/2022 introduces a minimum equity to the P2P Lending business whereby a Provider must at all times have equity of at least Rp12,500,000,000 (twelve billion five hundred million Rupiah). The implementation of this requirement is done through stages within 3 (three) years’ time, as follows:

  1. having at least Rp2,500,000,000 (two billion five hundred million Rupiah) within 1(one) year after the issuance of POJK 10/2022;
  2. having at least Rp7,500,000,000 (seven billion five hundred million Rupiah) within 2 (two) years after the issuance of POJK 10/2022; and
  3. having at least Rp12,500,000,000 (twelve billion five hundred million Rupiah) within 3 (three) years after the issuance of POJK 10/2022.
  • Controlling Shareholder and Single Presence Policy

The P2P Lending industry now acknowledges the concept of a ‘controlling shareholder’ (Pemegang Saham Pengendali or “PSP”) which is defined as a legal entity, individual, or group company either: (i) owning at least 25% (twenty five percent) voting shares in a Provider; or (ii) owning less than 25% (twenty five percent) voting shares however can be proven to have any control, whether directly or indirectly, of the Provider.

A Provider is required to state at least 1 (one) PSP, whereby OJK may also decide a Provider’s PSP at its discretion. In the event that there are more than 1 (one) shareholders that fulfills the criteria as PSP, the Provider shall determine all of such shareholders as PSPs of the Provider.

Additionally, the regulation prohibits a party to be a PSP in more than 1 (one) conventional Provider or 1 (one) sharia-based Provider, whereby a party that has already been a PSP in more than 1 (one) conventional Provider and 1 (one) sharia-based Provider, is given 1 (one) year to adjust to the new provisions.

A licensed Provider must also report its determined PSP and any changes thereof to OJK within 6 (six) months since the enactment of the provisions. POJK 10/2022 further extends liability to the PSP of a Provider in certain conditions, such as in the event of a Provider being at loss due to PSP’s involvement in any tort conducted by the Provider.

  • Necessary OJK Approval on Corporate Actions

Previously, there was only 1 (one) general clause which stipulates the requirements of OJK approval for corporate actions. Now, POJK 10/2022 expands on this by stipulating comprehensive provisions relating to corporate matters requiring OJK’s approval, namely:

  1. change of ownership;
  2. increase of paid-up capital;
  3. change of members of Board of Directors (“BOD”), Board of Commissioners (“BOC”), and Sharia Supervisory Board (Dewan Pengawas Syariah or “DPS”); and
  4. merger and consolidation.

Specifically, for point (i) above, POJK 10/2022 further elaborates on what constitutes a change of ownership of a Provider, which consists of changes to the following:

  1. Shareholders of a Provider that is not a public company (direct change of shareholders);
  2. Shareholders of the shareholders of a Provider that is not a public company (indirect change of shareholders);
  3. PSP of a Provider that is a public company; and
  4. PSP of the shareholders of a Provider that is a public company.

There are also additional requirements for a Provider after obtaining OJK approval on corporate matters, such as convening a General Meeting of Shareholders no later than 60 (sixty) working days as of the date of the OJK approval and submitting a report to OJK at the latest 10 (ten) business days as of the date of the GMS. Failure of comply to such provisions will result in various sanctions, such as the void of the OJK approval, written warning, limitation of business activities, and license revocation.

  • Lock-Up Period for Change of Ownership

POJK 10/2022 introduces a lock-up period whereby a Provider is prohibited from conducting any of the abovementioned forms of change of ownership that results in any (i) new shareholder, and/or (ii) change of PSP, within 3 (three) years since the date of the Provider’s business license from OJK.

  • Limitation on the Funding Amount by Each Lender

POJK 10/2022 enforces a new limitation on the maximum amount of lending that each lender (and its affiliates) may provide, which is in the amount of 25% (twenty five percent) of the final lending position at the end of each month. Notwithstanding the aforementioned, please note that such maximum amount may be conducted in stages, as follows:

  1. 80% (eighty percent) of the final lending position at the end of the month, at the latest 6 (six) months after the enactment of POJK 10/2022;
  2. 50% (fifty percent) of the final lending position at the end of the month, at the latest 12 (twelve) months after the enactment of POJK 10/2022; and
  3. 25% (twenty five percent) of the final lending position at the end of the month, at the latest 18 (eighteen) months after the enactment of POJK 10/2022.

However, lenders in the financial services industry that is under OJK’s supervision may provide lending up to 75% (seventy five percent) of the final lending position at the end of each month.

  • Fit and Proper Test

POJK 10/2022 now expressly requires that (i) PSP, (ii) BOD members, (iii) BOC members, and (iv) DPS members (for Sharia-based Providers) shall obtain approval from the OJK prior to their appointment through a fit and proper test. The fit and proper test shall be conducted based on OJK Regulation No. 27/POJK.03/2016 of 2016 on Fit and Proper Test for Main Parties of Financial Services Institutions.

  • Introduction on the Necessity of Business Plan

The new POJK 10/2022 emphasizes the necessity of the Provider’s business plan. Business actions that are required to be included in the Business Plan under POJK 10/2022 are: (i) conversion plan into a sharia business model; (ii) entering into a cooperation; (iii) opening/closing a branch office, (iv) change of name and/or electronic system, (v) plan to change address, (vi) plan to change business model, (vii) plan to change ownership, (viii) increase of paid-up capital, (ix) plan to change members of BOD, BOC, and/or DPS, and (x) merger and consolidation plan.

  • Prohibitions for Provider

Other than the previously regulated prohibition under POJK 77/2016, POJK 10/2022 also introduces several new prohibitions for the Provider, notably:

  1. Prohibition to represent lenders to provide lending and/or provide an automatic lending feature;
  2. Prohibition to give access to the members of BOD, BOC, DPS, and employees as well as their affiliates to act as lenders;
  3. Prohibition to give access to the members of BOD, BOC, DPS, and shareholders as well as their affiliates to act as borrowers;
  4. Prohibition to have any loan (i.e., bank loan, shareholders’ loan, and loan from other sources); an
  5. Prohibition to conduct any action which causes or enforces other financial services institutions under the supervision of OJK to violate and/or circumvent the laws and regulations.
  • Other New Provisions Under POJK 10/2022

As a more comprehensive regulatory framework, POJK 10/2022 contains a myriad of new provisions, rules, and requirements relating to the P2P Lending business in Indonesia, such as:

  1. Corporate Governance. POJK 10/2022 now stipulates an extensive corporate governance requirements for a Provider, such as: (i) requirement to prepare good corporate governance guidelines; (ii) minimum numbers of BOD and BOC as well as DPS (iii) requirements for  competence and qualifications for BOD, BOC and DPS; and (iv) internal audit requirements. Providers are required to comply with the requirements on the minimum numbers of BOD and BOC along with their competence and qualification  within 1 (one) year since the enactment of POJK 10/2022.
  2. Relevant Requirements Relating to Human Resources. Under POJK 10/2022, a Provider must fulfill several requirements with regard to human resources, among others:
    • Requirement for all BOD, BOC, and officials 1 (one) level under the BOD to obtain work competence certificate from an OJK registered certification institution in the fintech industry. Such certification must be obtained within 1 (one) year since the enactment of POJK 10/2022;
    • Requirement for a Provider to have special workforce to develop, change, and erase the Provider’s electronic system;
    • Criteria for the utilization of foreign workers by a Provider; and
    • Restriction on the types of business activities that a Provider may allocate parts of work, namely related to funding assessment and/or information technology.
  3. Business and Operational Activities. POJK 10/2022 sets out extensive rules and requirements concerning the business activities and operation of a Provider, among others:
    • a Provider may only be in the form of a limited liability company;
    • POJK 10/2022 further sets out the types of business activities of a Provider, dividing them into conventional and sharia models and acknowledging 2 (two) types of lending, namely productive and multifunction (multiguna);
    • the use of the payment methods of escrow account, fund account, and virtual account or payment gateway is similarly regulated under POJK 10/2022. However, POJK 10/2022 stipulates a specific maximum period for the fund placement in an escrow account, i.e., 2 (two) working days for the lender and 1 (one) working day for the borrower.
  4. Sharia-based P2P Lending. POJK 10/2022 recognizes the concept of Sharia-based P2P lending, which in essence, P2P lending conducted based on provisions of Islamic law in accordance with fatwa and/or statements of conformity with sharia from Dewan Syariah Nasional Majelis Ulama Indonesia. Additionally, POJK 10/2022 also provides the possibility of conversion from conventional P2P lending to sharia-based P2P lending. As it is already possible to convert, POJK 10/2022 now expressly prohibits conventional Provider to conduct sharia-based P2P Lending activities and must stop all marketing of sharia-based P2P Lending products. Consequently, Providers conducting concurrent sharia-based and conventional P2P Lending activities must settle any outstanding rights and obligations within 6 (six) months since the enactment of POJK 10/2022.
  5. Funding Quality of Provider. POJK 10/2022 now introduces rates of funding quality of Providers into current loans (lancar), loans with special attention (dalam perhatian khusus), non-current loans (kurang lancar), doubtful loans (diragukan), and non-performing loans (macet). Further implementation of this provision will be regulated by the OJK.
  6. Debt Collection. POJK 10/2022 stipulates a general guideline on debt collection in the event of a defaulting borrower through the use of a warning letter to such borrower. POJK 10/2022 also stipulates that Providers may enter into a cooperation with certain qualified third parties, such as those with certifications, to conduct debt collection to its borrowers. Further implementation of this provision will be regulated by the OJK.
  7. Reporting to OJK. Similar to the previous regime, a Provider is required to conduct regular (which consists of monthly and annual reporting) and incidental reporting to OJK. However, Providers are now required to submit an annual financial statement audited by public accountant. Other activities also require a Provider to submit a report to OJK, for example: (i) branch opening; (ii) change of name and Electronic System; (iii) change of domicile; and (iv) change of business model. In addition, POJK 10/2022 now also provides a more extensive set of template forms for submission of reports and/or approval applications to OJK in its Appendix.
  8. Cooperation with Government Agencies and Third Parties. POJK 10/2022 governs on the cooperation between a Provider and third parties, either financial or non-financial institutions, including in relation to the cooperation on data sharing. POJK 10/2022 also opens the possibility for Providers to enter into a cooperation with government agencies to support government programs to become a distribution partner for state securities (surat berharga). However, such cooperation can only be for securities offering in the primary market.
  9. Electronic System, Technical Requirements, and Personal Data Protection. There are several key-items stipulated in POJK 10/2022 relating to the applicable requirements for the Electronic System used by the Providers in performing its business activities, among others: (i) the obligation to own, control, and operate the Electronic System; (ii) prohibition on the number of Electronic System owned by a Provider; (iii) data submission obligation to fintech lending data center maintained by OJK through system integration; (iv) the obligation to have Electronic System processing record; and (v) relevant security requirements for the Electronic System. Personal data protection-wise, POJK 10/2022 adopts a similar approach to the personal data protection provisions adopted in other financial services regulations and still relies on a consent of data subject as the primary legal basis for personal data processing activities.
  10. Further Provisions by OJK. Several matters under POJK 10/2022 will be regulated further by OJK, namely on licensing procedure and mechanism; types of business activities, lender and borrower; risk management; escrow account, virtual account, fund account, and other means of fund transfer; cooperation; data and information processing; lending quality; reporting procedure and mechanism, success rate of repayment (tingkat keberhasilan bayar/TKB), and debt collection.

POJK 10/2022 is in force as of the date of its enactment, July 4, 2022. The new regulation revokes POJK 77/2016 in its entirety and Article 30 letter a of OJK Regulation No. 4/POJK.05/2021 of 2021 dated March 17, 2021 on Risk Management in for the Use of Information Technology by Non-bank Financial Institutions (“POJK 4/2021”). However, the provisions under the previous regime’s implementing regulations still apply so long as they do not contradict to the new POJK 10/2022.

We note that while POJK 10/2022 provides a more extensive regulatory framework for the P2P lending business industry, there are still some aspects that remain unregulated under the POJK 10/2022. In the near future, we expect that OJK will issue more guidelines and legal products to supplement the effective implementation of POJK 10/2022.

Please look forward to our next articles within the series, where we will provide more in-depth elaboration on the notable changes under POJK 10/2022.

July 20, 2022

AKSET

Please contact Abadi Abi Tisnadisastra (atisnadisastra@aksetlaw.com), Alfa Dewi Setiawati (asetiawati@aksetlaw.com), Noor Prayoga Mokoginta (nmokoginta@aksetlaw.com), Clara Anastasia So (canastasia@aksetlaw.com), Caleb Nathanael Sitorus (csitorus@aksetlaw.com), M. Satria Kasmaliputra (mkasmaliputra@aksetlaw.com), and Ammarsyarif G. Goenawan (agoenawan@aksetlaw.com) for further information.

Disclaimer:

The foregoing material is the property of AKSET and may not be used by any other party without prior written consent.  The information herein is of general nature and should not be treated as legal advice, nor shall it be relied upon by any party for any circumstance.  Specific legal advice should be sought by interested parties to address their particular circumstances.

Any links contained in this document are for informational purposes and are available and relevant at time this publication is made.  We provide no liability whatsoever in respect of any information or content in such links.

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POJK 10 2022 on P2P Lending

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by Pilanita Silaen