Dear.

Board of Directors of the Information Technology-Based Joint Funding Service

Provider.

COPY
CIRCULAR LETTER OF THE FINANCIAL SERVICES
AUTHORITY OF THE REPUBLIC OF INDONESIA
NUMBER 19/SEOJK.06/ 2023
CONCERNING
THE OPERATION OF INFORMATION TECHNOLOGY-BASED JOINT
FUNDING SERVICES

In connection with the mandate of Article 25 paragraph (3), Article 26

paragraph (8), Article 29 paragraph (2) and paragraph (3), Article 35 paragraph
(6), Article 36 paragraph (9), Article 44 paragraph (2), Article 51 paragraph (3),
Article 101 paragraph (6), and Article 104 paragraph (2) of the Financial
Services Authority Regulation Number 10/POJK.05/2022 concerning
Information Technology-Based Joint Funding Services (State
Gazette of the Republic of Indonesia Year 2022 Number 2/OJK, Supplement
to State Gazette of the Republic of Indonesia Number 2/OJK), it is necessary
to further regulate the implementation of information technology-based joint
funding services in the Financial Services Authority Circular Letter as
follows:

I. GENERAL CONDITIONS
In this Circular Letter of the Financial Services Authority, what is
meant by:
1. Information Technology-Based Joint Funding Services, hereinafter
abbreviated as LPBBTI, is the provision of financial services to
connect funders and fund recipients in conducting
conventional funding or based on sharia principles directly through
an electronic system using the internet.
2. Funding is the distribution of funds from a funder to a fund
recipient with a promise to be paid or returned in accordance with
a certain period of time in LPBBTI transactions.
3. Sharia Principle is the principle of Islamic law based on fatwa
and/or sharia conformity statement issued by an institution that
has the authority in stipulating fatwa in the field of Sharia.
4. Electronic System is a series of electronic devices and procedures
that function to prepare, collect, process, analyze, store, display,
announce, transmit, and/or disseminate electronic information in
the field of financial services.
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5. Information Technology is a technique to collect, prepare, store,

process, announce, analyze, and/or disseminate information in the
field of financial services.
6. LPBBTI Operator, hereinafter referred to as the Operator, is an
Indonesian legal entity that provides, manages and operates
LPBBTI either conventionally or based on Sharia Principles.
7. Fund Recipients are individuals, legal entities, and/or business
entities that receive Funding.
8. Funders are individuals, legal entities, and/or business entities
that provide Funding.
9. LPBBTI Users, hereinafter referred to as Users, are Funders and
Fund Recipients.
10. The Sharia Supervisory Board, hereinafter abbreviated as DPS, is a
board that has the duty and function of supervising and providing
advice to the Board of Directors regarding the implementation of the
Operator's activities in accordance with Sharia Principles.
11. Personal Data is any data about a person either identified and/or
identifiable individually or in combination with other information
either directly or indirectly through Electronic and/or non-electronic
Systems.

II. BUSINESS ACTIVITIES OF LPBBTI ORGANIZERS

1. The business activities of the Organizer consist of:
a. providing business;
b. management; and
c. operation,
LPBBTI.
2. Providing business activities as referred to in number 1 letter a,
namely the Organizer provides an Electronic System that brings
together Fund Providers and Fund Recipients in conducting
Funding transactions directly and provides other facilities in the
context of organizing business activities, among others:
a. facilitation of provision:
1. escrow account; and
2. virtual account or payment gateway;
b. provision of risk analysis facilities on Funding proposed by the
Fund Recipient;
c. provision of verification facilities for User identity and
document authenticity;
d. provision of Funding risk transfer facilities;
e. provision of risk transfer facilities for the collateral object (if
there is a collateral object);
f. provision of means of complaint; and
g. provision of information related to Funding for Users.
3. Management business activities as referred to in number 1 letter
b, namely the Organizer conducts identity verification activities
 -3-

Users, processing of User data and other personal data in

accordance with business operations, disbursement of funds from
Funders to Fund Recipients, payment of Funding from Fund
Recipients to Funders, and billing to Fund Recipients.
4. Operation of business activities as referred in number 1 letter c,
namely the Organizer fully operates the Electronic System owned.

III. BUSINESS ACTIVITIES BASED ON SHARIA PRINCIPLES

1. Organizers based on Sharia Principles comply with Sharia
Principles in carrying out business activities including the use of
contracts.
2. The fulfillment of Sharia Principles in the use of contracts as
referred to in number 1 must be supported:
a. fatwa and/or sharia conformity statement from an institution
that has the authority to issue fatwa in the field of sharia which
is the basis for the use of the contract; and
b. opinion from the Organizer's DPS on the use of certain
contracts for business activities based on Sharia Principles,
after obtaining approval or confirmation from an institution
that has the authority to determine fatwas in the field of
sharia.
3. The Financial Services Authority provides approval, registration,
or rejection of the contract used by the Organizer based on Sharia
Principles as referred to in number 2.
4. DPS analyzes and evaluates the fulfillment and application of Sharia
Principles, at least including:
a. Funding distribution activities;
b. standard operating procedures;
c. sharia funding marketing practices; and
d. application of accounting.
5. Evaluation of the fulfillment and application of Sharia Principles
as referred to in number 4 is carried out periodically every month
in the form of a written report and reported to the Board of
Directors.

IV. FUNDING DISTRIBUTION AND REPAYMENT MECHANISM

1. Before prospective Users register with the Organizer, the Organizer
displays things that need to be considered on the Organizer's
Electronic System including:
a. LPBBTI is the provision of financial services to bring together
Fund Providers and Fund Recipients in conducting
conventional Funding or based on Sharia Principles directly
through an Electronic System using the internet;
b. LPBBTI's business activities are subject to all provisions of
laws and regulations related to LPBBTI;
c. Organizer is an Indonesian legal entity that provides,
manages and operates LPBBTI either conventionally or
based on Sharia Principles;
 -4-

d. The organizers are licensed and supervised by the Financial

Services Authority;
e. The Organizer may only access, obtain, store, manage,
process and/or use the User's Personal Data after obtaining
consent from the User;
f. The Organizer can only access the camera, location, and
microphone on the User's device;
g. Users must understand the transaction and the contents of the
LPBBTI agreement, including the upper limit of the Funding
facility adjusted to the User's capacity to conduct transactions;
h. all Funding risks arising in LPBBTI transactions shall be borne
entirely by the Funders. The Organizer shall be liable in the
event of negligence or error caused by the Organizer and
causing loss to the Funder;
i. The User guarantees the authenticity of all documents
submitted. For any falsification of documents or other
criminal acts committed by the User, the Organizer may take
legal action including processing the action in question to the
competent authorities;
j. The Organizer does not charge any fees to Users for
complaint services;
k. The Organizer informs settlement and collection procedures
to the Funder and Fund Recipient in the event of Funding
default committed by the Fund Recipient; and
l. Other things to consider in relation with the characteristics of
the product owned by the Organizer.
2. In conducting Funding, the Organizer must ensure that Users
understand the matters that need to be considered as referred to in
number 1.
3. The mechanism for submitting applications for granting and
receiving Funding is as follows:
a. prospective Users must first be registered with the Organizer;
b. prospective Users who have registered with the Organizer
apply:
1) application for the providing of Funding, in the event
that the User is a prospective Funding Provider; or
2) application for the recipient of Funding, in the event that
the User is a prospective Fund Recipient,
through the Organizer's Electronic System;
c. The Organizer conducts an analysis of the application for the
provision of Funding as referred to in letter b number 1),
including by:
1) verify the authenticity of the documents submitted in
accordance with the Organizer's standard operating
procedures;
2) clarify and confirm either through direct face-to-face,
electronic face-to-face,
 -5-

and/or not face-to-face electronically to prospective

Funders as stipulated in the Financial Services Authority
Regulation regarding the implementation of anti-money
laundering programs, prevention of terrorism financing,
and prevention of funding for the proliferation of
weapons of mass destruction in the financial services
sector; and
3) analysis of prospective Funders;
d. documents as referred to in letter c number 1) consist of:
1) f o r i n d i v i d u a l p e r s o n a t l e a s t :
a) identity card/driver's license/passport;
b) taxpayer identification number (if any);
c) selfies; and
d) account number;
2) for business entities (including legal entities and
international institutions) at least:
a) identity card/driver's license/passport of the
owner/member of the board of directors;
b) business registration number / company
registration certificate / company business license /
business decision letter / company domicile
certificate or its equivalent for international
institutions;
c) taxpayer identification number, except for
international organizations;
d) document for:
(1) legal entity;
(a) deed of establishment;
(b) the last amendment to the articles of
association; and
(c) Letter:
i. approval or receipt of notification
from the competent authority; or
ii. a letter of ratification from the
authorized agency for individual
corporate legal entities;
(2) unincorporated business entities:
(a) the establishment document along with
the latest amendment; and
(b) documents showing registration or
legalization of business entities from
relevant agencies; or
(3) international institutions:
(a) establishment documents; and
(b) documents showing the articles of
association or equivalent;
e) a report that can show the latest operating
transactions and profit or loss; and
f) other supporting documents;
 -6-

e. analysis of prospective Funders as referred to in letter c

number 3) namely identity analysis;
f. identity analysis as referred to in letter e consists of at least:
1) type of Funder;
a) individual person; or
b) business entities (including legal entities and
international institutions);
2) data of individual persons;
a) name of the Fu n d e r ;
b) identity number of identity card/driver's
license/passport;
c) taxpayer identification number (if any);
d) phone number;
e) place of birth;
f) date of birth;
g) gender;
h) occupation;
i) income;
j) source of income; and
k) complete domicile address; and
3) data of business entities (including legal entities and
international institutions):
a) business identification number or similar;
b) taxpayer identification number except for
international organizations;
c) field of business;
d) phone number;
e) complete domicile address;
f) income; and
g) identity of the owner/director:
(1) Name;
(2) identity card number/driver's license/passport;
(3) taxpayer identification number;
(4) phone number; and
(5) complete domicile address;
g. The Organizer carries out an assessment (scoring) of the
application for recipient of Funding as referred to in letter b
number 2), including by:
1) verify the accuracy of the documents submitted in
accordance with the Organizer's standard operating
procedures;
2) clarify and confirm either through direct face-to-face,
electronic face-to-face, and/or electronic non-face-to-
face to prospective Fund Recipients as stipulated in the
Financial Services Authority Regulation regarding the
implementation of anti-money laundering programs,
prevention of financing
 -7-

terrorism, and prevention of financing the proliferation

of weapons of mass destruction in the financial services
sector;
3) processing data from other parties relevant to the needs
of the assessment (if needed); and
4) analysis of prospective Fund Recipients;
h. The assessment as referred to in letter g takes into account the
eligibility and ability of prospective Fund Recipients to fulfill
Funding payment obligations, namely character and repayment
capacity. In addition, the Organizer may also pay attention to
other aspects such as capital, economic prospects (condition of
economy), and/or collateral;
i. assessment of repayment capacity as referred to in letter h
for consumptive Funding, among others, is carried out by
examining the comparison between the amount of principal
payments and economic benefits paid by the Fund Recipient
and the income of the Fund Recipient which is set at a
maximum of:
1) 50% (fifty percent) in the first year after the Circular
Letter of the Financial Services Authority is stipulated;
2) 40% (forty percent) in the second year after the Circular
Letter of the Financial Services Authority is stipulated;
and
3) 30% (thirty percent) in the third year after the Circular
Letter of the Financial Services Authority is stipulated.
Consumptive funding means multipurpose funding as
referred to in Article 25 paragraph (1) letter b of the
Financial Services Authority Regulation regarding LPBBTI.
What is meant by the amount of principal payments and
economic benefits is the entire amount of principal payments
and economic benefits paid by the Fund Recipient to all
creditors, including the Organizer, banks, finance companies,
venture capital companies, pawnshop companies, and other
financial service institutions.
The income of the Fund Recipient is known, among others,
from the amount of income declared from the Fund
Recipient to the Fund Provider;
j. The Organizer must ensure that Fund Recipients do not receive
Funding through more than 3 (three) Organizers, including the
Organizer;
k. documents as referred to in letter g number 1) consists of at
least:
1) i n d i v i d u a l person at least:
a) identity card / driver's license/passport;
b) taxpayer identification number (if any);
c) selfies; and
d) account number (if required);
2) business entities (including legal entities) at least:
 -8-

a) identity card / driving license/passport of the

owner/member of the board of directors;
b) business registration number / company
registration certificate / company business license /
business decision letter / company domicile
certificate;
c) taxpayer identification number;
d) document for:
(1) legal entity:
(a) deed of establishment;
(b) the last amendment to the articles of
association; and
(c) Letter:
i. approval or receipt of notification
from the competent authority; or
ii. legalization letter from the authorized
agency for individual corporate legal
entities;
(2) unincorporated business entities:
(a) the establishment document along with
the latest amendment; and
(b) documents showing registration or
legalization of business entities from
relevant agencies;
e) a report that can show the latest operating
transactions and profit or loss; and
f) other supporting documents;
l. analysis of prospective Fund Recipients as referred to in
letter g number 4) includes analysis of identity and eligibility
and ability; and
m . identity analysis as referred to in letter l consists of at least:
1) name of the Fund Recipient;
2) type of Fund Recipient;
a) an individual person; or
b) business entities (including legal entities);
3) data of the least number of natural persons:
a) identity number of identity card/driver's
license/passport;
b) taxpayer identification number (if required);
c) phone number;
d) place of birth;
e) date of birth;
f) gender;
g) last education ;
h) occupation;
i) income;
j) source of income; and
k) complete domicile address;
 -9-

4) data business entity (including legal entity) at least :

a) business identification number or similar;
b) taxpayer identification number;
c) field of business;
d) phone number;
e) complete domicile address;
f) business entity income; and
g) identity of the owner/director:
(1) name;
(2) identity number of identity card/driver's
license/passport;
(3) taxpayer identification number;
(4) phone number; and
(5) complete domicile address; and
5) emergency contact .
4. After the Organizer analyzes the prospective Fund Recipient, the
Organizer determines the eligibility of the prospective Fund
Recipient and informs the prospective Fund Recipient that:
a. in the event that the prospective Fund Recipient is declared
eligible, the Organizer submits the results of the assessment
along with the tenor and economic benefits of the Funding it
proposes; or
b. in the event that the prospective Fund Recipient is declared
ineligible, the Organizer conveys the ineligibility to the
prospective Fund Recipient and may be accompanied by the
reasons for its rejection.
5. The application for receipt of Funding as referred to in number 3
letter b number 2) and the results of the assessment of prospective
Fund Recipients who are declared eligible as referred to in
number 4 letter a, are displayed on the Organizer's Electronic
System.
6. Implementation of activities Funding
a. Prospective Funders select prospective Fund Recipients on the
Organizer's Electronic System.
b. Prospective Users sign the LPBBTI agreement using an
electronic signature.
c. The Funder channels Funding through a virtual account or
payment gateway to be placed in the Organizer's escrow
account and forwarded to the Fund Recipient.
d. The Organizer provides notification of the provision and
receipt of Funding to Users, among others, through the
Electronic System.
e. In implementing Funding activities, the Organizer must pay
attention to the following matters:
1) In the interest of consumer and public protection, each
Provider is not allowed to conduct unhealthy Funding;
2) Unhealthy Funding as referred to in number 1) is
Funding that imposes unreasonable terms, conditions,
economic benefits, and/or late fees on Fund Recipients,
which does not take into account the ability to repay the
Fund.
 - 10 -

(repayment capacity) of the Fund Recipient, or Funding

received by the Fund Recipient more than 3 (three)
Organizers;
3) examples of unhealthy funding includes:
a) setting conditions, provision of economic benefits,
and/or late fees that contain elements of deception;
b) the establishment of terms, conditions of economic
benefits, and/or late fees that do not take into
account the ability of the Fund Recipient to return
the Funding; or
c) Funding to small and medium enterprises,
microfinancing, and/or other forms of funding that
impose unreasonable terms, conditions of economic
benefits, and/or late fees.
7. In order to pay installments and / or repayments of Funding, the
Fund Recipient makes payments through a virtual account or
payment gateway to be placed in the Organizer's escrow account
and forwarded to the Funder.
8. Repayment of installments and/or Funding through collection by
other parties is carried out in accordance with the method as
referred to in number 7.

V. USE OF OUTSOURCED LABOR

1. The organizer may assign part of the work to a third party under
an outsourcing agreement.
2. The form of outsourcing agreement as referred to in number 1 is
carried out by the Organizer through an agreement:
a. work contracting; and/or
b. provision of labor services.
3. Organizers are prohibited from outsourcing the work that
performs the function:
a. Funding eligibility assessment; and/or
b. Information Technology.
4. The work related to Funding feasibility assessment as referred to
in number 3 letter a is part of the Organizer's organizational
structure that carries out the function to conduct Funding
feasibility assessment.
5. In carrying out the function as referred to in number 3 letter a, the
Organizer may cooperate with credit information management
institutions to add data references in assessing the feasibility of
Funding.
6. The nature of cooperation as referred to in number 5 is only
related to the provision of Funding assessment data and is not
related to the provision of the final Funding eligibility assessment
on the Electronic System owned by the Organizer.
7. Work that cannot be transferred to the Information Technology
function as referred to in number 3 letter b is work related to
Information Technology development and Information Technology
operations.
 - 11 -

8. Works that includes Information Technology operations as referred to in

number 7 include:
a. user access management activities;
b. database management activities;
c. backup and restore activities;
d. troubleshooting; and
e. disaster recovery.
9. The Organizer is prohibited from assigning part of the work to
third parties as referred to in point 1 other than to third parties
that meet the provisions:
a. third parties in the form of legal entities in Indonesia;
b. third parties are registered with third-party peer associations;
c. does not affect the reputation of the Organizer; and
d. implemented in accordance with the provisions of laws and
regulations in the field of labor.
10. The organizer shall be responsible for the implementation of
activities handed over to third parties.

VI. MAXIMUM LIMIT OF ECONOMIC BENEFITS

1. The Organizer must comply with the provisions of the maximum
limit of economic benefits of Funding in facilitating Funding.
2. The economic benefit to which the Organizer is subject is the rate of
return, including:
a. i n t e r e s t / m a r g i n / p r o f i t sharing;
b. administration fee/commission fee/platform fee/ujrah which
is equivalent to such fee; and
c. other fees, other than late fees, stamp duty, and taxes.
3. The maximum limit of economic benefits as referred to in
number 2 is determined based on the type of Funding, namely:
a. for productive funding, viz:
1) 0.1% (zero point one percent) per calendar day of the
Funding value stated in the Funding agreement, 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 Funding value stated in the Funding
agreement, effective from January 1, 2026; and
b. for consumptive funding that is limited to short-term funding
tenors of less than 1 (one) year, namely:
1) 0.3% (zero point three percent) per calendar day of the
Funding value stated in the Funding agreement, which is
valid for 1 (one) year from January 1, 2024;
2) 0.2% (zero point two percent) per calendar day of the
Funding value stated in the Funding agreement, which is
valid for 1 (one) year from January 1, 2025; and
 - 12 -

3) 0.1% (zero point one percent) per calendar day of the

Funding value stated in the Funding agreement,
effective from January 1, 2026.
The following is a simulation of the calculation of the maximum
economic benefit limit:
1) Productive funding
Fund recipients A submits Funding to Organizer Z on January 5, 2024
with the following details:
a) the maximum limit of economic benefits as stated in
letter a number 1) is 0.1% (zero point one percent) per
calendar day of the Funding value stated in the Funding
agreement;
b) Funding provided as in the Funding agreement is
Rp1,000,000.00 (one million rupiah);
c) 90 (ninety) calendar days tenor;
d) interest/margin/profit sharing Rp30,000.00 (thirty
thousand rupiah);
e) administration fee/commission fee/platform fee/ujrah
Rp50,000.00 (fifty thousand rupiah);
f) other costs Rp5,000.00 (five thousand rupiah);
g) total economic benefit = Rp30,000 (thirty thousand
rupiah) + Rp50,000 (fifty thousand rupiah) + Rp5,000
(five thousand rupiah) = Rp85,000 (eighty-five thousand
rupiah);
h) economic benefit percentage = total economic benefit /
(Funding provided as in the Funding agreement x tenor)
= Rp85,000.00 (eighty five thousand rupiah) /
[Rp1,000,000.00 (one million rupiah) x 90 (ninety)] =
0.0944% (zero point zero nine four four percent).
Based on the above calculation, the amount of economic
benefit of 0.0944% (zero point zero nine four four percent)
meets the maximum limit of economic benefit that can be
provided which is 0.1% (zero point one percent) per calendar
day of the Funding value stated in the Funding agreement.
2) Consumptive funding
Fund recipients B submits Funding to Organizer Y on February 10, 2024
with the following details:
a) the maximum limit of economic benefits as stated in
letter b number 1) is 0.3% (zero point three percent) per
calendar day of the Funding value stated in the Funding
agreement;
b) Funding provided as in the Funding agreement is
Rp1,000,000.00 (one million rupiah);
c) tenor of 30 (thirty) calendar days;
d) interest/margin/profit sharing of Rp40,000.00 (forty
thousand rupiah);
e) administration fee/commission fee/platform fee/ujrah
IDR 45,000.00 (forty-five thousand rupiah);
f) other costs Rp5,000.00 (five thousand rupiah);
g) total economic benefit = Rp40,000.00 (forty thousand
rupiah) + Rp45,000.00 (forty-five thousand rupiah) +
 - 13 -

Rp5,000.00 (five thousand rupiah) = Rp90,000.00 (ninety

thousand rupiah);
h) economic benefit percentage = total economic benefit /
(Funding provided as in the Funding agreement x tenor)
= Rp90,000.00 (ninety thousand rupiah) /
[Rp1,000,000.00 (one million rupiah) x 30 (thirty)] =
0.3% (zero point three percent).
Based on the above calculation, the amount of economic
benefits of 0.3% (zero point three percent) meets the
maximum limit of economic benefits that can be provided,
which is 0.3% per calendar day of the Funding value stated
in the Funding agreement.
4. The maximum limit of late penalty as referred to in number 2
letter c is determined based on the type of Funding, namely:
a. for productive funding, viz:
1) 0.1% (zero point one percent) per calendar day of the
outstanding value of the Funding, 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 outstanding value of the Funding, effective
January 1, 2026; and
b. Consumptive funding done in stages viz:
1) 0.3% (zero point three percent) per calendar day of the
outstanding value of the Funding, which is valid for 1
(one) year from January 1, 2024;
2) 0.2% (zero point two percent) per calendar day of the
outstanding value of the Funding, which is valid for 1
(one) year from January 1, 2025; and
3) 0.1% (zero point one percent) per calendar day of the
outstanding value of the Funding, effective January 1,
2026.
5. All economic benefits and late fees that can be imposed on Users
do not exceed 100% (one hundred percent) of the Funding value
stated in the Funding agreement.
6. The determination of the maximum limit of economic benefits
and late fees as referred to in point 3 and point 4 may be
evaluated periodically in accordance with the policies stipulated
by the Financial Services Authority by considering, among
others, economic conditions and the development of the LPBBTI
industry.

VII. RISK MITIGATION FACILITIES FOR USERS

1. Activities to facilitate risk mitigation for Users at least:
a. conduct a risk analysis of the Funding proposed by the Fund
Recipient;
b. do verify identity User and the
authenticity of the document;
c. collecting the Funding channeled optimally;
d. facilitate the transfer of Funding risks; and
 - 14 -

e. facilitate the transfer of risk on the collateral object, if there

is a collateral object.
2. Funding risk analysis as referred to in number 1 letter a:
a. conducted at the time the Fund Recipient applies for Funding
by processing data received when the Fund Recipient applies
for registration and/or based on other data owned by the
Organizer; and
b. used to assess the eligibility of Fund Recipients to fulfill
Funding obligations.
3. Verification of User identity and authenticity of documents as
referred to in number 1 letter b is carried out on information and
documents submitted to the Organizer and/or based on other data
owned by the Organizer.
4. In order to conduct Funding risk analysis as referred to in number
2 and verification of User identity as referred to in number 3, the
Organizer may utilize data from:
a. information management service providers that have been
registered or licensed by the relevant authority;
b. government agencies or state-owned enterprises or
regionally-owned enterprises; and/or
c. other institutions that have been registered or licensed by the
relevant authorities.
5. Data utilization as referred to in number 4 is carried out by
fulfilling the provisions of laws and regulations regarding the
protection of Personal Data.
6. Funding risk transfer as referred to in number 1 letter d can be
done through insurance or guarantee mechanisms.
7. In transferring the Funding risk as referred to in number 6, the
Organizer may cooperate with insurance companies or guarantee
companies that have a business license from the Financial
Services Authority in accordance with statutory provisions.
8. In cooperation with insurance companies or guarantee companies:
a. cooperation is carried out with at least 2 (two) insurance
companies or guarantee companies; and
b. The Organizer only acts as a provider of cooperation facilities for
the Funders.
9. Cooperation as referred to in number 7 is set forth in a written
agreement.
10. The written agreement as referred to in point 9 must use
Indonesian or Indonesian alongside a foreign language.
11. The use of insurance or guarantee as referred to in number 6 is an
agreement between the Funder and the insurance company or
guarantee company.
 - 15 -

12. In using insurance or guarantee as referred to in number 11, the

Funder acts as the insured or the recipient of the guarantee.
13. In the event of a claim payment, the insurance company or
guarantee company directly pays the claim to the Fund Provider
and/or beneficiary.
14. In the event that the claim payment has been paid by the
insurance company or guarantee company as referred to in point
13, the Organizer must ensure that the claim payment information
is submitted to the Funder.
15. In the context of transferring risk over the object of guarantee as
referred to in number 1 letter e, the Organizer may:
a. insure the object of collateral; and/or
b. cooperate with other parties who have the authority to
accommodate or store collateral objects based on the
provisions of laws and regulations.

VIII. DATA AND INFORMATION MANAGEMENT

1. The organizer in carrying out business activities can only access
the camera, location, and microphone on the User's device.
2. The Organizer is not allowed to disseminate all personal data and
information of the User to other parties.
3. The provisions as referred to in number 2 are exempted in the
event that:
a. there is written consent from the User; and/or
b. there is an exception by the provisions of laws and
regulations.
4. In the event that the User provides written consent as referred to in
number 3 letter a, the Organizer may provide the User's personal
data and/or information and ensure that the other party does not
provide and/or use the User's personal data and/or information for
purposes other than those agreed between the Organizer and the
other party.
5. The Organizer ensures that the User is aware of the purpose of
the use of data and information and the risks inherent in the
written or recorded consent given by the User.
6. The written consent of the User as referred to in number 5 is
stated in the form of a statement and approval and documented by
the Organizer.
7. Data and information as referred to in number 2 must be secured
through a method that can ensure the process of reading data and
information is carried out by authorized parties.
8. User data and information obtained and utilized by the Provider
must meet the following criteria:
a. delivery of data and information utilization restrictions to
Users;
b. submission of any changes in the purpose of utilization of
data and information to the User, if any; and
 - 16 -

c. media and methods used in obtaining and utilizing data and

information are guaranteed confidentiality, security, and
integrity.
9. User data and information destroyed by the Organizer must meet the
following criteria:
a. fulfill retention aspects based on laws and regulations and
the audit and examination needs of sector supervisory and
regulatory authorities; and
b. Ensure that no data and information is left behind and can be
reused.
10. Providers must prevent unauthorized access to data and
information.
11. Organizers must maintain confidentiality, security, integrity, and
availability of the:
a. personal data and information;
b. transaction data; and
c. financial data,
which he manages since data obtained until the data is destroyed.

IX. FUNDING QUALITY LEVEL

1. The Organizer conducts a Funding quality assessment.
2. Funding Quality as referred to in number 1 consists of:
a. current;
b. special mention;
c. sub standard;
d. doubtful; and
e. bad debt.
3. Quality Funding as referred to at number 1
is categorized as follows:
a. Current if there are no delays in principal payments and/or
economic benefits of the Fund;
b. Special attention if there is a delay in payment of principal
and / or economic benefits of Funding that has exceeded
maturity up to 30 (thirty) calendar days;
c. Substandard if there is a delay in payment of principal and/or
economic benefits of Funding that has exceeded the due date
of 30 (thirty) calendar days up to 60 (sixty) calendar days;
d. Doubtful if there is a delay in payment of principal and/or
economic benefits of Funding that has exceeded the due date
of 60 (sixty) calendar days up to 90 (ninety) calendar days;
and
e. Bad debt if there is a delay in payment of principal and / or
economic benefits of Funding that has exceeded the maturity
of 90 (ninety) calendar days.
 - 17 -

X. FUNDING PERFORMANCE PUBLICATION

1. The Organizer must publish the Funding performance on the
main page of the website, application, and/or Electronic System
owned by the Organizer which contains information at least:
a. value of Funding disbursed;
b. number of Funders;
c. number of Fund Recipients; and
d. pay success rate.
2. Information as referred to in number 1 letter a through letter c is
submitted:
a. since commencing business activities;
b. in the current year; and
c. final position.
3. Publication of the success rate of payment (TKB) as referred to in
number 1 letter d is carried out by displaying the entire success rate
of payment for Funding facilitated by the Provider based on the
quality level of LPBBTI Funding.
4. TKB as referred to in number 3 is displayed with the following
details:
a. written using the format:
1) TKB0 = xx.xx%;
2) TKB30 = xx.xx%;
3) TKB60 = xx.xx%; and
4) TKB90 = xx.xx%,
including an explanation of TKB as follows:
a) TKB0 is a measure of the Organizer's success rate in
facilitating the settlement of Funding obligations within
a period of up to 0 (zero) calendar days from maturity;
b) TKB30 is a measure of the Organizer's success rate in
facilitating the settlement of Funding obligations within
a period of up to 30 (thirty) calendar days from
maturity;
c) TKB60 is a measure of the Organizer's success rate in
facilitating the settlement of Funding obligations within
a period of up to 60 (sixty) calendar days from maturity;
and
d) TKB90 is a measure of the Organizer's success rate in
facilitating the settlement of Funding obligations within
a period of up to 90 (ninety) calendar days from
maturity;
b. placed on the main screen at the top right of the entire
website, application, and/or Electronic System of the
Organizer; and
c. placed in a position that is easy to see and can be read
clearly.
5. The calculation used to determine TKB is as follows:
a. TKB 0 = 100% - TWP 0
Default end position above 0 calendar days
TWP 0 = X 100 %
Total end
position
b. TKB 30 = 100% - TWP 30
Final default position above 30 calendar days
TWP 30 = X 100 %
Total end position
 - 18 -

c. TKB 60 = 100% - TWP 60

Final default position above 60 calendar days
TWP 60 = X 100 %
Total end position
d. TKB 90 = 100% - TWP 90
Final default position above 90 calendar days
TWP 90 = X 100 %
Total end position
6. TKB as referred to in number 5 can be corrected in the event that:
a. The Fund Recipient has made payment in full of all Funding
received as well as for payment obligations arising from
such Funding;
b. The Funder has received payment from the insurance
company or guarantee company for the coverage claim
and/or guarantee submitted; and
c. The Funder has written off and written off the Funding
provided.
7. Funding performance information is updated at least 1 (one) time a
week.

XI. CHARGING
1. The organizer must carry out the collection independently or by
appointing another party to carry out the collection.
2. The Organizer must provide information regarding the maturity
of Funding to the Fund Recipient to make periodic payments
before the Funding is due and collectible.
3. In the event that the Fund Recipient defaults, the Organizer must
collect at least by giving a warning letter after the Funding period
expires and after maturity as in the Funding agreement between
the Funder and the Fund Recipient.
4. Collection can be done by:
a. desk collection, namely indirect billing, among others,
through the media of messages, telephone calls, video calls, and
other intermediaries; and/or
b. field collection is direct face-to-face billing.
5. In conducting Collection as referred to in number 4, the Organizer
must ensure that:
a. Collection personnel have received adequate training related to
collection duties and collection ethics in accordance with applicable
regulations;
b. in the event that the Organizer conducts collection cooperation
carried out by other parties to the Fund Recipient, such other
parties must have human resources who have obtained
certification in the field of collection from a professional
certification institution registered with the Financial Services
Authority.
c. The identity of each collection staff is properly maintained by the
Organizer;
d. Collection personnel in carrying out collections adhere to the
following collection ethics:
1) use an official identity card issued by another party that
cooperates with the Organizer, which is equipped with a
photo of the person concerned;
 - 19 -

2) Collection is not allowed to be carried out by using

threats, violence and/or actions that humiliate the
Recipient of Funds;
3) Collection is not allowed to be done by using physical
or verbal pressure;
4) by avoiding the use of words and/or actions that
intimidate and demean ethnicity, religion, race, and
intergroup (SARA), dignity, and self-esteem, in the
physical world or in cyberspace (cyber bullying) to the
Fund Recipient, the Fund Recipient's emergency
contacts, relatives, colleagues, family, and property;
5) Collection is not allowed to be made to parties other
than the Fund Recipient;
6) Collection by means of communication is not allowed to be
carried out in a continuous and disruptive manner;
7) collection can only be done through personal channels,
at the place of collection address, or domicile of the
Fund Recipient;
8) Collection can only be done from 8:00 a.m. to 8:00 p.m. in
the time zone of the recipient's address; and
9) Collection outside the place and/or time as referred to in
number 7) and number 8) may only be carried out on the
basis of prior approval and/or agreement with the Fund
Recipient; and
e. other parties providing collection services that cooperate with the
Organizer also comply with the billing ethics set by the
Organizer's association.
6. Collections by appointing other parties as referred to in number 1 is
carried out in the form of a written agreement and evaluated
periodically.
7. Collection agreement by appointing other parties as referred to in
number 6 at least includes:
a. scope of work;
b. the term of the agreement;
c. contract value;
d. fee structure and payment mechanism;
e. rights, obligations, and responsibilities of the Organizer and
other parties, among others:
1) the Organizer's authority to evaluate and examine other
parties for billing;
2) obligations of other parties including labor used to
maintain the confidentiality and security of information
of the Organizer and/or User;
3) the obligation of other parties to submit reports and
information to the Organizer in writing and periodically;
4) the obligation of each party to comply with the
provisions and laws and regulations;
5) obligations of the parties to protect the rights and
interests of Users in relation to the billing carried out;
 - 20 -

6) the obligation of the other party to have a contingency

plan; and
7) the willingness of other parties to provide access to
inspection to the Financial Services Authority and/or
other authorized authorities together with the Organizer
in the event that it is needed;
f. measures and standards of work execution;
g. criteria or conditions for termination of the agreement
before the end of the term of the agreement (early termination);
h. sanctions and penalties; and
i. dispute resolution .
8. The Organizer shall be fully responsible for all impacts arising
from cooperation with other parties as referred to in point 1.

XII. CONFIRM THE USE OF EMERGENCY CONTACTS

1. The use of emergency contacts is only intended to confirm the
existence of the Fund Recipient and is not used to collect Funding
from the owner of the emergency contact data.
2. Organizers must confirm and obtain consent from the owner of
the emergency contact data for the use of emergency contacts.
3. Confirmation as referred to in number 2 is done by explaining
things:
a. confirm data contact emergency that submitted by the Fund Recipient;
b. confirm the relationship between the owner of the
emergency contact data and the Fund Recipient requesting
emergency contact;
c. explain what an emergency contact is to theemergency contact data
owner; and
d. explain the risks that will be attached when agreeing to be an
emergency contact.
4. The organizer documents the confirmation and consent given by
the owner of the emergency contact data.

XIII. REPORTING OF SETTLEMENT OF RIGHTS AND OBLIGATIONS

1. The organizer prepares a report on the settlement of rights and
obligations in terms of:
a. The Organizer converts from a conventional Organizer to an
Organizer based on Sharia Principles;
b. the Organizer is unable to continue its operational activities; or
c. The organizer is declared bankrupt.
2. The settlement of the rights and obligations of the Organizer to
convert as referred to in number 1 letter a is carried out with the
consent of the User, in the event that the User does not agree
then:
a. the Organizer's rights and obligations to the User are still
settled; or
b. The portfolio is transferred to an Organizer with similar
business principles.
 - 21 -

3. Settlement of the Organizer's rights and obligations to the User is

carried out in a manner:
a. the final position of the transfer of the total Funding that has
not been repaid; and/or
b. other mechanisms agreed upon by the User.
4. Other mechanisms agreed by the User as referred to in number 3
letter b can be carried out by the Organizer bringing together the
Fund Provider and the Fund Recipient which then the two parties
can agree on the completion of the Funding agreement.
5. The settlement of the rights and obligations of the Operator to the
User as referred to in paragraph 3 shall be written in the LPBBTI
agreement.
6. The report on the settlement of rights and obligations as referred
to in number 1 is carried out with reference to the provisions
regarding license applications, approval applications, and
electronic reporting for Organizers.

XIV.TRANSITIONAL PROVISIONS
1. The Funding Agreement that has been signed before this Circular
Letter of the Financial Services Authority comes into force, shall
remain in force until the expiration of the Funding agreement.
2. In the event that the Funding agreement that has been signed
before this Circular Letter comes into effect requires amendment
after the enactment of this Circular Letter, the amendment to the
Funding agreement must comply with the provisions in this
Circular Letter.

XV. CLOSING
The provisions of this Circular Letter of the Financial Services
Authority s h a l l take effect on the date of enactment.

Established in Jakarta
on November 8, 2023

EXECUTIVE HEAD OF SUPERVISION OF

FINANCING INSTITUTIONS,
COMPANY
VENTURE CAPITAL,
MICROFINANCE INSTITUTIONS, AND OTHER
FINANCIAL SERVICES INSTITUTIONS
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA,

ttd

AGUSMAN
This copy is in accordance with the
original Legal Director 1
Ministry of Law ttd

Mufli Asmawidjaja