2013-12-05

Bank Indonesia Circular Letter No. 15/49/DPKL on Credit Bureau Licensing and Governance

Bank Indonesia issued Circular Letter No. 15/49/DPKL to implement Regulation Number 15/1/PBI/2013 by establishing detailed licensing mechanisms and operational standards for Credit Bureaus (LPIP). The document mandates strict share ownership limits, requiring Indonesian legal entities to hold majority stakes while capping foreign ownership at 20%, and enforces rigorous integrity and competence criteria for Board of Directors and Commissioners. It further outlines a comprehensive approval process involving an Approval in Principle and an Operational License, alongside specific requirements for foreign manpower employment and ongoing supervisory reporting.

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No. 15/ 49 /DPKL Jakarta, December 5, 2013 CIRCULAR LETTER Regarding: Lembaga Pengelola Informasi Perkreditan (Credit Bureau). With the enactment of Bank Indonesia Regulation Number_15/1/PBI/2013 concerning Lembaga Pengelola Informasi Perkreditan (Credit Bureau) (State Gazette of the Republic of Indonesia Year 2013 Number 36, Supplement to the State Gazette of the Republic of Indonesia Number 5402), it is deemed necessary to further stipulate implementing provisions concerning Lembaga Pengelola Informasi Perkreditan (Credit Bureau) in Bank Indonesia Circular Letter as follows: I. GENERAL A. In the context of fulfilling the need of Financial Institutions and non-Financial Institutions for Credit Information which is more diverse, comprehensive, and has added value, the management of Credit Information may be conducted by other parties other than Bank Indonesia. Therefore, in order to allow the measurement of readiness and sustainability of Credit Information management activities, it is necessary to stipulate a further regulation concerning licensing mechanism for Lembaga Pengelola Informasi Perkreditan (LPIP). B. In conducting its business activities, LPIP is gathering and processing Credit Data and/or Other Data in order to produce Credit Information. Therefore, it is deemed necessary to ensure that LPIP implements good governance in conducting all Credit Information management activities in terms of, among other things, policy, human resources, operational procedures, and information technology. C. In order to . . .

C. In order to ensure that the operations of LPIP are performed in accordance with laws and regulations and in line with the objectives of LPIP establishment, Bank Indonesia conduct supervision through examination (on-site) and through analysis of reports, documents, data and/or other information submitted by LPIP to Bank Indonesia (off-site). II. INSTITUTIONAL ASPECTS OF LPIP A. LPIP Share Ownership

  1. The shareholders of LPIP must be in the form of Indonesian legal entity.
  2. Indonesian legal entity as referred to in point 1 shall be owned by: a. Indonesian legal entity; or b. Indonesian legal entity and foreign legal entity through a partnership.
  3. Ownership of share in LPIP by 1 (one) party shall be limited to a maximum of 51% (fifty-one percent) of the paid-up capital.
  4. In the event that the Indonesian legal entity as an LPIP shareholder as referred to in point 1 is partly owned by foreign party, the following conditions shall apply: a. total share ownership of 1 (one) or more foreign party in 1 (one) LPIP shall be limited to a maximum of 20% (twenty percent); b. in the event that 1 (one) foreign party owns more than 1 (one) LPIP, total share ownership of such foreign party in all LPIPs shall be at a maximum of 20% (twenty percent); c. foreign legal entity partly owning an Indonesian legal entity that is an LPIP shareholder, as referred to in point 1, must have at least 3 (three) years experience in the Credit Information management industry. Such experience in the Credit Information management industry shall be proved by, among other things, written . . . Page 2

written proof that such legal entity has experience of owning or managing credit bureau in other countries and/or has experience of conducting business activities producing credit rating or credit scoring products. The aforementioned written proof shall be, among other things, in the form of a statement from the authorities or a copy of articles association of the prospective LPIP shareholder. 5. Share ownership as referred to in points 1 and 2 shall include share ownership based on affiliation among the shareholders, namely, among other things: a. share ownership relationship; and/or b. cooperation or acting in concert in order to achieve common objectives in controlling LPIP with or without written agreement, thus collectively having an option right or other rights to hold the LPIP shares. Examples of chart of LPIP share ownership is as set out in Attachment_A. 6. LPIP shareholders as referred to in point 1 shall be required to meet the following requirements: a. having a commitment to comply with the applicable laws and regulations; b. having a strong commitment to the development of sound operations of LPIP; and c. not registered in the List of Bad Debt. B. The Board of Directors and the Board of Commissioners

  1. In order to meet the integrity requirements, a prospective member of the Board of Directors and the Board of Commissioners must possess at least the following requirements: a. good character and moral, which are reflected by being observant to the applicable provisions and never been sentenced due to being found guilty of comitting criminal act as referred to in Law regulating the criminal act of money . . . Page 3

money laundering, supported by, among other things, a duly stamped letter stating never been sentenced due to being found guilty of a criminal act as mentioned above. b. commitments:

  1. to comply with the applicable laws and regulations;
  2. to implement the Good Corporate Governance principle;
  3. to conduct the development of sound LPIP operations; and
  4. to maintain the confidentiality and security of data and information, which is supported by, among other things, a duly stamped statement letter setting out such commitment.
  1. In order to meet the competence requirements, each prospective member of the Board of Directors and the Board of Commissioners must possess at least: a. knowledge in fields relevant to the assumed position; and b. ability to conduct strategic management in the development of LPIP, which are shown, among other things, by documents describing academic background and/or adequate experience for any positions to be assumed.
  2. In addition to meet the competence requirements as referred to in point 2, a prospective member of the Board of Directors must have commitment to work in a professional manner in accordance with the expertise required for the position to be assumed, supported by a duly stamped statement letter setting out such commitment.
  3. In order to meet the financial reputation requirements, each prospective member of the Board of Directors and the Board of Commissioners must meet at least the following criteria: a. not registered in the List of Bad Debt, namely not recorded as a Debtor or Customer having a facility for Provision of Fund which is in default or anything considered equal thereto; and b. never been declared to be bankrupt or guilty for causing a company . . . Page 4

company being declared to be bankrupt within 5 (five) years prior to the submission of application; which are respectively supported by, among other things, a duly stamped statement letter. 5. In order to support the smoothness of LPIP management activity, at least 1 (one) member of the Board of Directors must have experience and/or knowledge in the Credit Information management industry. Experience in the Credit Information management industry shall be proved by, among other things, having previously assumed a position as a member of the Board of Directors, member of the Board of Commissioners, and/or an officer who reports directly to a member of the Board of Directors or having influence over policy and operations of LPIP or other institutions conducting business activities producing credit rating and credit scoring products. Knowledge in the Credit Information management industry shall be shown by, among other things, a written proof of participation in training on Credit Information. C. Foreign Manpower

  1. In conducting Credit Information management activities, LPIP may employ Foreign Manpower for positions as member of the Board of Directors, member of the Board of Commissioners and/or expert/consultant subject to meet the following requirements: a. having expertise qualifications in the Credit Information management industry; b. not assuming a position in a Financial Institution, both domiciled in Indonesia and outside Indonesia; and c. possessing knowledge about Indonesian economy, language and culture. In the event that LPIP intends to employ foreign expert/consultant, LPIP must first consider the availability of local experts/consultant for the required field and expertise.

  2. In order to . . . Page 5

  3. In order to meet the knowledge requirements of Indonesian economy, language, and culture, Bank Indonesia may interview the Foreign Manpower. Specifically for knowledge in Indonesian language, it shall be proved by an Indonesian Language Proficiency Test Certificate (Uji Kemahiran Berbahasa Indonesia/UKBI) issued by the Ministry of Education and Culture of the Republic of Indonesia or a proof of Indonesian language mastery issued by Indonesian language education institute registered to the authorized institution.

  4. Specifically for prospective member of the Board of Directors and/or prospective member of the Board of Commissioners, who is a Foreign Manpower, in addition to the requirements as referred to in letter B, must also meet the Foreign Manpower requirements as referred to in Law regulating manpower.

  5. LPIP intending to employ Foreign Manpower in conducting its business activity shall be required to inform Bank Indonesia about the plan for Foreign Manpower employment contained in LPIP’s business plan. The contents of the plan for Foreign Manpower employment shall comprise at least: a. name and information on the Foreign Manpower, accompanied by at least the following documents:

  1. a photocopy of passport; and
  2. curriculum vitae and 1 (one) 4x6 cm photograph taken within the last 1 (one) month; b. reasons for employing Foreign Manpower and reasons for not/not yet employing Indonesian Manpower for the field of duty assumed by the Foreign Manpower; c. field of duty and position or title to be filled including the scope and competence; d. term of employment; and e. knowledge transfer program plan, including, among other things, training plan by the Foreign Manpower to supporting personnel.
  1. The Foreign Manpower employment plan must obtain approval from Bank Indonesia. Subsequently, the Foreign Manpower employment . . . Page 6

employment plan approved by Bank Indonesia shall be submitted by LPIP to the Ministry of Manpower and Transmigration for authorization. 6. In the event of a plan to change the Foreign Manpower employment as expert/consultant, LPIP must inform Bank Indonesia about the plan to change the Foreign Manpower employment along with the reason therefor. Subsequently, the plan to change the Foreign Manpower employment approved by Bank Indonesia shall be submitted by LPIP to the Ministry of Manpower and Transmigration for authorization. Such changes may be, among other things, in the form of an extension of term of Foreign Manpower employment or change of title. 7. LPIP must provide the report on Foreign Manpower employment to Bank Indonesia in LPIP’s annual report. The scope of the report on Foreign Manpower employment shall comprise at least: a. name of the Foreign Manpower, accompanied by documents, namely a photocopy of Limited Stay Permit (KITAS) or Permanent Stay Permit (KITAP) issued by the Ministry of Law and Human Rights and a photocopy of the most recent passport; and b. other information about the Foreign Manpower, accompanied by the following documents:

  1. a photocopy of proof or statement on the expertise qualifications;
  2. name of assisting personnel; and
  3. proof of realization of knowledge transfer program conducted by the Foreign Manpower to the assisting personnel. III. LPIP LICENSING A. Approval in Principle
  1. In order to obtain an approval in principle for preparing the establishment of LPIP, one of the prospective shareholders of LPIP shall conduct the following: a. submitting . . . Page 7

a. submitting the application for approval in principle to Bank Indonesia with due observance of Attachment B; and b. making a presentation to Bank Indonesia about the entire plan for LPIP establishment. 2. The application as referred to in item 1.a shall be accompanied by the following documents: a. draft deed of establishment of Limited Liability Company, including draft articles of association setting out at least:

  1. name and domicile;
  2. business activities;
  3. capital;
  4. share ownership;
  5. authority, responsibilities and term of office of the members of the Board of Commissioners and members of the Board of Directors; and
  6. a clause providing for that the appointment of members of the Board of Commissioners and members of the Board of Directors must obtain prior approval from Bank Indonesia; b. share ownership data in the form of list of respective prospective shareholders, accompanied by the following documents:
  7. details of percentage of each share ownership in LPIP;
  8. deed of establishment and the most recent amendment to the articles of association of the prospective shareholders, which have obtained approval from the authorized institution;
  9. financial information of the prospective shareholders for at least the last 3 (three) years. In the event that the prospective shareholders have been conducting business activities for less than 3 (three) years, the financial information provided shall be . . . Page 8

shall be the financial information during the term of its business activities; 4) share ownership information of the prospective shareholders up to the ultimate shareholder; and 5) a proof of having experience in the Credit Information management industry for foreign manpower as referred to in item II.A.4.c. c. list of composition of prospective members of the Board of Directors and members of the Board of Commissioners, accompanied by the following documents:

  1. 1 (one) 4x6 cm photograph taken within the last 1 (one) month;
  2. a copy of identity card of the prospective member of the Board of Directors and members of the Board of Commissioners, namely, among other things, Identity Card (KTP), passport, or other valid identifications;
  3. curriculum vitae;
  4. a statement letter duly stamped from each prospective member of the Board of Directors and prospective member of the Board of Commissioners stating that the party concerned: a) has never been sentenced due to being found guilty of committing a criminal act as referred to in Law regulating the criminal act of money laundering; b) has commitments to: (1) comply with the applicable laws and regulations; (2) implement the Good Corporate Governance principle; (3) conduct the development of sound LPIP operations; (4) maintain the confidentiality and security of data . . . Page 9

of data and information; and (5) work in a professional manner in accordance with the expertise required for the position to be assumed; c) is not registered as a Debtor or Customer having a facility for Provision of Fund which is in default or anything considered equal thereto; d) has never been declared bankrupt; and e) never become a shareholder, member of the Board of Directors, or member of the Board of Commissioners who is declared to be guilty of making a company declared bankrupt by virtue of a court decision within 5 (five) years prior to the date of application submission; d. plan of the composition and organizational structure as well as human resources, containing at least the organization chart, horizontal and vertical responsibilities as well as titles and estimated number of human resources required; e. business plan for the first 3 (three) years setting out at least:

  1. management policy and strategy;
  2. projected financial statements along with assumptions used;
  3. capital plan;
  4. information system technology development plan;
  5. product issuance plan and/or implementation of new activity;
  6. office opening plan;
  7. human resources and organization development plan; and
  8. general overview of Foreign Manpower employment, supported by feasibility studies regarding market opportunity . . . Page 10

opportunity and economic potential; f. strategic plans for medium term namely 3 (three) up to 5 (five) years and for long term namely more than 5 (five) years; g. design of information technology system to be used, containing at least the architectural design of information technology system and information on hardware, software, and communication network; h. design of the requirements for Credit Data of Financial Institution to be obtained from Bank Indonesia, containing at least the type and period of Credit Data required; i. guidelines on internal control system and guidelines on the implementation of Good Corporate Governance, setting out at least the procedures for securing and maintaining the confidentiality of data and/or information, and decision-making mechanism and policy; j. policies and operational procedures; k. proof of capital payment by at least 30% (thirty percent) of the minimum paid-up capital in the form of a photocopy of deposit certificate with a bank in Indonesia and on behalf of “Board of Governors of Bank Indonesia q.q. one of prospective shareholders for the establishment of the relevant LPIP” by setting out at statement that the disbursement of which may only be conducted upon written approval of the Board of Governors of Bank Indonesia; l. a statement letter duly stamped from the prospective shareholders stating that the source of funds used for LPIP establishment as referred to in letter k;

  1. does not originate from any loan or financing facilities of any form whatsoever from banks and/or other parties; and/or
  2. does not originate from and for the purpose of money . . . Page 11

money laundering; and m. other documents and/or statement letters for supporting the documents as referred to in letters a to l upon the request of Bank Indonesia, if necessary. 3. In order to grant an approval in principle, Bank Indonesia shall conduct: a. a research on the completeness and authenticity of the documents; b. an analysis on:

  1. plan for the composition and organizational structure as well as human resources;
  2. business plan for the first 3 (three) years;
  3. medium and long-term strategic plans;
  4. design of information technology system to be used;
  5. design of requirements of Credit Data of the Financial Institution to be obtained from Bank Indonesia;
  6. guidelines on internal control system and guidelines on the implementation of Good Corporate Governance; and
  7. policies and operational procedures; by considering the national interest, direction and policy on Indonesian economic development, as well as the direction and policy of Bank Indonesian including, among other things, the needs of financial industry and market saturation level; and c. interview with the prospective shareholders, prospective members of the Board of Directors, and/or prospective members of the Board of Commissioners, if necessary.
  1. Approval or refusal of the application for approval in principle shall be granted by Bank Indonesia by no later than 60 (sixty) business days as of the date the on which the application documents as referred to in point 2 have been . . . Page 12

have_been completely received. B. Operational License

  1. A request for LPIP operational license shall be submitted to Bank Indonesia with due observance of Attachment C and accompanied by the following documents: a. deed of establishment of Limited Liability Company, setting out the articles of association which have been ratified by the authorized institution; b. list of shareholders along with the details of the respective portion of share ownership; c. list of composition of members of the Board of Directors and members of the Board of Commissioners; d. documents as referred to in items A.2.d, A.2.e, A.2.f, A.2.h, A.2.i, A.2.j, and A.2.m, in case of amendment; e. architectural design of information technology system to be used; f. a proof of payment of the minimum paid-up capital in the form of:
  1. cash funds, proved by a photocopy of deposit certificate with a bank in Indonesia and on behalf of “Board of Governors of Bank Indonesia q.q. one of the shareholders of the relevant LPIP” by setting out a statement that the disbursement of which may only be conducted upon written approval from the Board of Governors of Bank Indonesia; and/or

  2. other forms, the amount of which shall be determined by LPIP at fair value determined in accordance with the market price or by experts not affiliated with LPIP; g. a proof of operational readiness, comprising at least:

  3. proof of ownership, possession, and/or office building lease agreement;

  4. list of fixed assets and inventory;

  5. a photograph of . . . Page 13

  6. a photograph of office building and spatial layout;

  7. a document showing a readiness of information system technology;

  8. a sample form or document to be used in LPIP operations;

  9. Taxpayer Registration Number of LPIP; and h. a statement letter duly stamped from the shareholders, stating that the source of capital contribution:

  10. does not originate from any loan or financing facilities of any form whatsoever from banks and/or other parties; and/or

  11. does not originate from and for the purpose of money laundering.

  1. In order to grant an operational license, Bank Indonesia shall conduct: a. a research on the completeness and authenticity of the documents; b. an analysis on the amended documents as referred to in item B.1.d.; c. an evaluation of information technology system to be used based on the architectural design as referred to in item B.1.e, which may also be conducted by other parties appointed by Bank Indonesia; and d. other analyses based on the consideration of Bank Indonesia.
  2. Approval or refusal of the application for operational license shall be granted by Bank Indonesia by no later than 80 (eighty) business days following the date on which all documents as referred to in point 1 have been completely received. IV. CHANGE . . . Page 14

IV. CHANGE IN PAID-UP CAPITAL, SHAREHOLDERS, MEMBERS OF THE BOARD OF DIRECTORS, AND/OR MEMBERS OF THE BOARD OF COMMISSIONERS A. Change in Paid-up Capital

  1. LPIP shall submit a report on the increase in the total paid￾up capital with due observance of Attachment D, which is accompanied by the following documents: a. an amendment to the articles of association setting out the total paid-up capital which have been ratified by the authorized institution; and b. a statement letter duly stamped from LPIP shareholders stating that the change in paid-up capital:
  1. does not originate from any loan or financing facilities of any form whatsoever from banks and/or other parties; and/or
  2. does not originate from and for the purpose of money laundering.
  1. The report on the increase in paid-up capital must be submitted to Bank Indonesia by no later than 10 (ten) business days following the date on which the process of increasing paid-up capital is completed. B. Change in Shareholder Composition
  2. LPIP shall submit a request for a change in shareholder composition of LPIP, whether or not resulting in replacement, reduction, and/or addition of the number of owners, to Bank Indonesia with due observance of Attachment E and accompanied by the following documents: a. deed of establishment and the most recent amendment of the articles of association of the prospective shareholders, which have been ratified by the authorized institution; b. financial information of the prospective shareholders for at least the last 3 (three) years. In the event that the prospective shareholders have been conducting business . . . Page 15

business activities for less than 3 (three) years, the financial information provided shall be the financial information during the term of its business activities; c. share ownership information of the prospective shareholders up to the ultimate shareholder; and d. a statement letter duly stamped concerning:

  1. commitment to comply with the applicable laws and regulations;
  2. strong commitment to conduct the development of sound LPIP operations; and
  3. not registered on the List of Bad Debt as referred to in item II.A.6.c.
  1. In order to grant an approval to the change in shareholder composition, Bank Indonesia shall conduct: a. an analysis of documents as referred to in point 1; and b. interview with the prospective shareholders, if necessary.
  2. Bank Indonesia shall grant an approval or refusal to the application for the change in shareholder composition by no later than 60 (sixty) business days after the application documents have been completely received.
  3. After obtaining the approval to the change in shareholder composition from Bank Indonesia, LPIP shall hold a General Meeting of Shareholders (GMS) to decide the change in new shareholder composition.
  4. The result of GMS regarding the change in shareholder composition as referred to in point 4 shall be reported to Bank Indonesia by no later than 10 (ten) business days after the GMS is held, accompanied by the following documents: a. in the event of capital contribution:
  1. a proof of contribution;
  2. minutes of GMS;
  3. an amendment to the articles of association drawn up by a notary;
  4. a proof of report on the amendment to the articles of association . . . Page 16

of association as referred to in point 3) to the authorized institution; 5) a statement letter duly stamped from the shareholders that the source of capital contribution: a) does not originate from any loans or financing facilities of any form whatsoever from banks and/or other parties; and/or b) does not originate from and for the purpose of money laundering; and 6) other documents supporting the change in share ownership if necessary. b. in the event that there is no capital contribution:

  1. minutes of GMS;
  2. an amendment to the articles of association drawn up by a notary;
  3. a proof of report on the amendment to the articles of association as referred to in point 2) to the authorized institution; and
  4. other documents supporting the change in share ownership, if necessary. C. Change in Composition of the Members of the Board of Directors and/or the Members of the Board of Commissioners
  1. In the event that LPIP intends to change the composition of the members of the Board of Directors and/or the members of the Board of Commissioners, LPIP shall submit an application to Bank Indonesia with due observance of Attachment F and accompanied by the documents as referred to in item indents III.A.2.c.
  2. In order to grant an approval to the change in the composition of the members of the Board of Directors and/or the members of the Board of Commissioners, Bank Indonesia shall conduct: a. an analysis of the documents as referred to in point 1; and . . . Page 17

and b. interview with the prospective members of the Board of Directors and/or the prospective members of the Board of Commissioners, if necessary. 3. Bank Indonesia shall grant an approval or refusal to the application for the change in the composition of the members of the Board of Directors and/or the members of the Board of Commissioners by no later than 30 (thirty) business days after all documents have been completely received. 4. In the event that the members of the Board of Directors and/or the members of the Board of Commissioners are not appointed within 60 (sixty) business days following the approval of Bank Indonesia, the aforementioned approval of Bank Indonesia shall be invalid. 5. LPIP shall be required to submit to Bank Indonesia a report on: a. appointment of the members of the Board of Directors and/or the members of the Board of Commissioners by no later than 10 (ten) business days following the date of GMS; and/or b. dismissal and/or resignation of the members of the Board of Directors and/or the members of the Board of Commissioners, by no later than 10 (ten) business days following the effective date of dismissal and/or resignation of the parties concerned. D. Acquisition, Merger, or Consolidation

  1. Any LPIP intending to conduct acquisition, merger, or consolidation with another LPIP, must obtain approval from Bank Indonesia.
  2. The Board of Directors of LPIP intending to conduct acquisition, merger, or consolidation must prepare an acquisition, merger, or consolidation plan pursuant to the applicable laws and regulations. The Board of Directors of LPIP . . . Page 18

LPIP shall submit a proposal for plan of acquisition, merger or consolidation to Bank Indonesia. 3. Acquisition, merger, or consolidation process a. Acquisition of LPIP

  1. An application for an approval to acquisition shall_be submitted to Bank Indonesia by the prospective shareholder intending to acquire an LPIP and the LPIP to be acquired.
  2. The application for acquisition as referred to in point 1) shall be accompanied by data on acquisition plan and/or documents comprising at least: a) an approval of GMS to the acquisition plan; b) information on name, total shares, total nominal value, and percentage of share ownership at the time of the submission of application of acquisition and following the acquisition; c) information on share ownership up to ultimate shareholder; d) draft deed of acquisition and reasons for such acquisition from the shareholder intending to acquire and the LPIP to be acquired; e) current financial information of the shareholder intending to acquire for at least the last 3 (three) years. In the event that the prospective shareholder has been conducting business activities for less than 3 (three) years, the financial information provided shall be the financial information during the term of its business activities; f) business plan for the first 3 (three) years following the acquisition; and g) other documents if necessary.
  3. In order to grant an approval to acquisition, Bank Indonesia . . . Page 19

Indonesia shall conduct: a) an analysis of data on acquisition plan and/or documents as referred to in point 2); and b) interview with the prospective shareholders of LPIP, members of the Board of Directors of LPIP, and/or members of the Board of Commissioners of LPIP, who are authorized to give explanations related to the acquisition plan, if necessary. 4) Bank Indonesia shall give an approval or refusal to the application for acquisition by no later than 60 (sixty) business days after the application documents have been completely received. 5) LPIP which has obtained approval from Bank Indonesia shall follow up the acquisition application process in accordance with the laws and regulations regulating acquisition. 6) Acquisition of LPIP shall be effective as of: a) date of approval to the amendment to the articles of association from the authorized institution; or b) date of registration of deed of acquisition and deed of amendment to the articles of association in the company registry if the amendment to the articles of association does not require any approval from the authorized institution. 7) Since the acquisition is effective, the acquired LPIP must: a) submit a report on the implementation of acquisition to Bank Indonesia by no later than 10 (ten) business days following the effectiveness of acquisition accompanied by the following documents: (1) a photocopy of . . . Page 20

(1) a photocopy of the amendment to the articles of association approved by the authorized institution; or (2) a photocopy of the registration of deed of acquisition and deed of a mendment to the articles of association in the company registry if the amendment to the articles of association does not require any approval from the authorized institution; and b) announce the LPIP resulting from the acquisition in 2 (two) daily newspapers widely circulated and in a Supplement to the Official Gazette of the Republic of Indonesia by no later than 10 (ten) business days as of the effective date of such acquisition. b. Merger or consolidation of LPIPs

  1. An application for an approval to merger or consolidation shall be submitted by each LPIP to Bank Indonesia.
  2. An application for an approval to merger or consolidation to Bank Indonesia shall be accompanied by data on merger or consolidation plan and/or documents comprising at least: a) an approval of GMS to the merger or consolidation plan; b) information on the name of shareholder, total shares, total nominal value, and percentage of share ownership at the time of submission of application for merger or consolidation and following the merger or consolidation; c) information on share ownership up to the ultimate shareholder; d) draft deed of amendment to the articles of association or deed of establishment including . . . Page 21

including the articles of association following the merger or consolidation and the reasons and explanation about the merger or consolidation from the Board of Directors of LPIPs intending to conduct a merger or consolidation; e) current financial information of the prospective shareholders of LPIP resulting from the merger or consolidation, for at least the last 3 (three) years, the financial information provided shall be the financial information during the term of its business activities; f) the current management composition and the management composition plan following the merger or consolidation; g) business plan for the first 3 (three) years following the merger or consolidation; h) all plans to fulfill the obligations after the implementation of merger or consolidation for LPIP resulting from the merger and the dissolving LPIP; and i) other documents, if necessary. 3) In order to grant an approval to merger or consolidation, Bank Indonesia shall conduct: a) an analysis of the merger or consolidation plan and/or documents as referred to in point 2); and b) interview with: (1) the shareholders of LPIP, members of the Board of Directors of LPIP, and/or members of the Board of Commissioners of LPIP; and/or (2) the prospective shareholders, prospective members of the Board of Directors, and/or . . . Page 22

and/or prospective members of the Board of Commissioners of LPIP resulting from the merger or consolidation; who are authorized to give explanations related to the merger or consolidation plan, if necessary. 4) Bank Indonesia shall grant an approval or refusal to the application for merger or consolidation by no later than 60 (sixty) business days after the request documents have been completely received. 5) LPIP which has obtained approval to merger or consolidation from Bank Indonesia, shall then submit a application for merger or consolidation to the authorized institution in accordance with the provisions regulating merger and consolidation. 6) The approval to merger or consolidation given by Bank Indonesia shall be effective as of: a) the date of approval to the amendment to the articles of association from the authorized institution; or b) the date of registration of deed of merger or consolidation and deed of the amendment to the articles of association in the company registry in the event that the amendment to the articles of association does not require any approval from the authorized institution. 7) Since the merger or consolidation is effective, LPIP resulting from the merger or consolidation must: a) submit a report on the implementation of merger or consolidation to Bank Indonesia by no later than 10 (ten) business days since the merger or consolidation is effective, accompanied by the following documents: (1) a photocopy of the amendment to the articles . . . Page 23

articles of association approved by the authorized institution; or (2) a photocopy of the registration of deed of merger or consolidation and deed of amendment to the articles of association in the company registry if the amendment to the articles of association does not require any approval from the authorized institution; b) announce the LPIP resulting from the merger or consolidation in 2 (two) daily newspapers widely circulated and in a Supplement to the Official Gazette of the Republic of Indonesia by no later than 10 (ten) business days as of the effective date of such merger or consolidation; and c) take other administrative actions related to the dissolving LPIP due to merger or consolidation in accordance with the applicable laws and regulations, including the matters related to the administrative completeness of the parties which will access information of the dissolving LPIP due to merger or consolidation. V. RIGHTS AND OBLIGATIONS OF LPIP A. LPIP obtaining an operational license may gather and manage the Credit Data and Other Data, which may only be used for generating Credit Information. B. In conducting its operations, LPIP shall have the obligations:

  1. to maintain accuracy, currency, security, and confidentiality of data;
  2. to have a reliable system;
  3. to adopt policies and operational procedures set out in written . . . Page 24

written guidelines; and 4. to have rules which must be complied with by any party using the Credit Information. C. The policies and operational procedures as referred to in item B.3 shall comprise at least:

  1. data security measures, comprising, among other things, as follows: a. data security to maintain accuracy, currency, security, and confidentiality of data with due observance of the applicable provisions. The data security is aimed to prevent the managed data from being lost, damaged, misused and/or stolen; b. asset management related to data security, such as:
  1. computer hardware, server, and building security;
  2. operational security; and
  3. security of information technology aspect (security, confidentiality, reliability, availability aspects of system and data, as well as the authenticity of information technology system); c. identification of risk sources which may occur in the operational activities of LPIP; and d. policies on the handling of information security issues;
  1. access level setting, comprising at least: a. adequate control and management of access right according to the authority stipulated including the prohibitions and sanctions for misusing access right; b. appointment and authorization of officers related to the management of data and information system; and c. separation of access right for input, process and output functions;
  2. procedures for changing data, comprising at least: a. arrangements of the parties which may change data; b. procedures and mechanism for changing data; c. data alteration activity logging; and d. senior . . . Page 25

d. senior officials in charge of data alteration; 4. procedures for Credit Information security shall be conducted through activities at least as referred to in point 1; 5. Business Continuity Plan (BCP), comprising at least: a. activity plan to ensure that BCP can be conducted effectively in order to guarantee the continuity of LPIP activities in case of disruptions; b. the implementation of BCP test for the whole application systems and infrastructure for at least 1 (one) time in 1 (one) year by involving the users, which is reported to Bank Indonesia; c. the implementation of evaluation of BCP for at least 1 (one) time in 1 (one) year; and d. the implementation of BCP updating, if necessary; 6. setting of End-user Computing (EUC), comprising at least: a. the use of EUC for functions other than the main function of LPIP system; and b. monitoring of the development and the use of developed EUC application; 7. Disaster Recovery Plan (DRP), comprising at least the measures to be taken in case of disaster in order to ensure the sustainability of LPIP operations; 8. monitoring of operations including audit trail by, among other things, monitoring the log of each activity in the system; 9. procedures for the delivery of Credit Information, comprising at least: a. arrangements of the parties which may obtain Credit Information; b. availability of supporting documents in hardcopy, electronic form or other forms; and c. procedures for the delivery of Credit Information, comprising at least the procedures, requirements, administration, and costs of the delivery of Credit Information . . . Page 26

Information; 10. procedures for complaint handling and settlement by referring to the provisions in this Bank Indonesia Circular Letter; and 11. data retention schedule provided that in the event of a revocation of operational license, the retention schedule established shall be automatically terminated. D. The rules as referred to in item B.4. shall regulate at least the following:

  1. relationship between LPIP and parties using the Credit Information, comprising at least: a. rights and obligations of each party; b. purposes and limitations on the use of Credit Information; c. complaint handling and settlement mechanism; and d. dispute resolution mechanism;
  2. relationship between LPIP and data source, comprising at least: a. rights and obligation of each party; b. purposes and limitations on data management; c. data updating and correction mechanism; d. obligation of the data source to ensure the legality of use of data in accordance with the applicable provisions; e. obligation of the data source to inform the Debtors or Customers in writing about the utilization of Credit Data and/or Other Data by LPIP, Bank Indonesia, and/or Credit Information users pursuant to the applicable laws and regulations; f. complaint handling and settlement mechanism; and g. dispute resolution mechanism; and
  3. relationship between LPIPs as the management, comprising at least: a. rights and obligations of each party; b. form . . . Page 27

b. form, type and period of data to be transferred; c. data transfer mechanism; d. data updating and correction mechanism; e. complaint handling and settlement mechanism; f. dispute resolution mechanism; and g. period of cooperation. VI. DATA MANAGEMENT BY LPIP A. Source and Flow of Data

  1. Credit Data obtained from Bank Indonesia a. Types of Credit Data which may be provided by Bank Indonesia to LPIP, shall be in the following forms:
  1. data on debtors;
  2. data on management for debtors in the form of business entity;
  3. data on Provision of Fund facilities in the form of: a. data on securities; b. data on credit facilities; c. data on other claims; d. data on equity investment; e. data on Bank Guarantee; f. data on Irrevocable LCs; and/or g. data on channeling;
  4. data on collaterals and guarantors; and/or
  5. data on financial statements of debtors. b. In providing Credit Data as referred to in letter a, Bank Indonesia shall consider the national interest, data availability, and readiness of information technology system in Bank Indonesia. c. The provision of Credit Data as referred to in letter a, shall be conducted in accordance with the forms determined by Bank Indonesia. d. In order to obtain Credit Data from Bank Indonesia, LPIP shall prepare data receiver system in accordance with the information system technology used by Bank Indonesia . . . Page 28

Indonesia, including notifications of receipts and errors in data validation. e. LPIP shall receive sample data from Bank Indonesia, which will be used in the context of internal technical preparation of LPIP upon the approval in principle to the LPIP business establishment process. f. After obtaining an operational license from Bank Indonesia, LPIP shall submit an application for obtaining Credit Data to Bank Indonesia by no later than 60 (sixty) business days as of the date of issuance of operational license, accompanied by a valid receipt and list of officers in charge who will be granted access right for obtaining Credit Data. g. Credit Data as referred to in letter f, shall be provided by Bank Indonesia by no later than 15 (fifteen) business days following the date of application submission, with a historical period of the last 24 (twenty-four) months prior to the month of data when the operational license is granted. h. After obtaining Credit Data as referred to in letter g, LPIP shall subsequently receive current Credit Data from Bank Indonesia on a periodical and incidental basis. i. Credit Data shall be obtained from Bank Indonesia by conducting the following:

  1. Administration of Access Right to Obtain Data a) LPIP shall provide the list of names of officers and/or senior officials authorized to submit the application for data, namely 2 (two) persons at a minimum and 3 (three) persons at a maximum. b) Bank Indonesia shall grant access right along with the password to the officers and/or senior official appointed by LPIP. In the event of a change of the authorized officers and . . . Page 29

and senior officials as referred to in item a), LPIP shall report such change to Bank Indonesia, accompanied by an application for obtaining access right and password for new officers and senior officials by no later than 1 (one) business day as of the occurrence of such change. 2) Obtaining of Data Bank Indonesia shall inform LPIP about the time and address of Uniform Resource Locater (URL) for accessing data. The data may be obtained from Bank Indonesia via online and/or offline. a) The data may be obtained online by taking the following steps: (1) the officers and/or senior officials authorized to access the data log in to the system provided by Bank Indonesia; (2) the authorized officers and/or senior officials download the data provided by Bank Indonesia; and (3) the authorized officers and/or senior officials log out from the system if the data downloading process is completed. b) The data may be obtained offline under the following provisions: (1) the data may be obtained offline if the data cannot be obtained online due to network disruption; (2) in the context of the identification process of officers and/or senior officials authorized to obtain the data offline, LPIP shall issue an assignment letter for the appointed officers and/or senior officials which shall then be submitted to Bank Indonesia. c) The data . . . Page 30

c) The data may be obtained offline as referred to in item b) (1) using the hardware and network in Bank Indonesia. 2. In order to expand and enrich data coverage, LPIP may cooperate with Financial Institutions to obtain Credit Data and Other Data and/or with non-Financial Institutions to obtain Other Data under: a. an agreement between LPIP and Financial Institutions and/or non-Financial Institutions which shall at least set out the provisions as referred to in item V.D.2; and b. the applicable laws and regulations, namely, among other things, the Law concerning consumer protection and the Law concerning public information transparency. B. Cost of Obtaining the Credit Data

  1. In order to obtain the Credit Data from Bank Indonesia, LPIP shall be subject to the following costs: a. initial data costs namely the costs charged to LPIP in order to obtain the Credit Data from Bank Indonesia for the first time; and b. periodical data costs namely the costs charged to LPIP for obtaining current Credit Data on a periodical and/or incidental basis.
  2. The payment of periodical data costs as referred to in item 1.b shall be made in January. For LPIP commencing its business activities after January, the first payment of periodical data costs shall be calculated on a pro rata basis up to the end of the current year, and for the subsequent year such costs will be charged as of January.
  3. The total costs of obtaining the data shall be determined by calculating: a. Data management costs Data management costs shall be calculated from the total investment and operational costs for managing the Credit . . . Page 31

Credit Data internally in Bank Indonesia, without calculating the profit margin. The calculation and determination of the components of data management costs shall be conducted by Bank Indonesia by at least taking account of the economic life of goods, the fair value level of operational costs, and future development plan. b. Number of LPIPs Bank Indonesia shall determine the number of LPIPs as the denominator in determining the cost of obtaining the data. c. Business Category Index Business Category Index shall consist of Commercial, Retail, MSMEs, Combination with MSMEs and Combination without MSMEs. d. Information User Index Information User Index shall be determined by Bank Indonesia consisting of index of Commercial and/or Non-Commercial Bank. 4. The formula for calculating the cost of obtaining the data shall be as follows: a. Formula for calculating the cost of obtaining initial data BPDA = BPnD x IKB x IPI x DS Number of LPIPs BPDA : Biaya Perolehan Data Awal (Cost of Obtaining Initial Data) BPnD : Biaya Pengelolaan Data (Data Management Costs) IKB : Indeks Kategori Bisnis (Business Category Index) IPI : Indeks Pengguna Informasi (Information User Index) DS : Total Months in which the Data Series are obtained for the first time b. Formula . . . Page 32

b. Formula for calculating the cost of obtaining periodical data: BPDB = BPnD x IKB x IPI x N Number of LPIPs BPDB : Biaya Perolehan Data Berkala (Cost of Obtaining Periodical Data) BPnD : Biaya Pengelolaan Data (Data Management Cost) IKB : Indeks Kategori Bisnis (Business Category Index) IPI : Indeks Pengguna Informasi (Information User Index) N : Total months calculated based on the total periods of data distributed up to the end of the year Examples of the calculation of the cost of obtaining the data as referred to in Attachment G. 5. If the formula as referred to in point 4 requires a variable value, it may be adjusted at any time by taking account of the development and needs of financial industry and LPIP in the entirety. C. Obtaining of LPIP Data by Bank Indonesia

  1. In the event that Bank Indonesia requests the Credit Data and/or Other Data directly to LPIP, LPIP shall provide such data according to the specifications requested by Bank Indonesia, namely, among other things, form, type, and period of the Credit Data and/or Other Data.
  2. Delivery of the Credit Data and/or Other Data to Bank Indonesia may be conducted online and/or offline.
  3. If an error is found in the Credit Data and/or Other Data received by Bank Indonesia, LPIP shall correct such data. D. Data . . . Page 33

D. Data Management

  1. In order to ensure that the notification of utilization of the Credit Data and/or Other Data as referred to in item V.D.2.e set out in the agreement has been made by the data source to each Debtor or Customer, LPIP shall request and administer the proof of notification in the form of, among other things, the recapitulation of notification of utilization of Credit Data and/or Other Data to Debtors or Customers.
  2. In conducting the management of Credit Data and/or Other Data, LPIP may update the data only if: a. the data source cannot update the data because the operational license of the data source is revoked or is technically unable to updated the data for any other reasons; or b. there is a final binding verdict instructing LPIP to update the data.
  3. Data updating by LPIP as referred to in item 2.a. shall be conducted upon a written request from the designated party, Financial Institution, non-Financial Institution, Debtor or Customer concerned, setting out at least: a. a request for updating the data along with the reasons therefor and underlying document; and b. data requested for update along with the explanation.
  4. In conducting the management of Credit Data and/or Other Data, LPIP may transfer the Credit Data and/or Other Data to another LPIP within the territory of the Republic of Indonesia under: a. an agreement between LPIPs setting out at least the rules as referred to in item V.D.3; and b. a written approval from the data source.
  5. In the context of maintaining accuracy, currency, security, and confidentiality of data, the placement of server and database of LPIP within the territory of the Republic of Indonesia shall be subject to the laws and regulations concerning electronic information and transaction. The placement of . . . Page 34

The placement of server and database shall not be limited to the placement of goods or physical placement, but shall also include the management of such server or database which must be conducted within the territory of the Republic of Indonesia. The server and database shall include the Data Center and Disaster Recovery Center (DRC). The location of server and database placement shall be reported to Bank Indonesia. VII. CREDIT INFORMATION A. In order to obtain the Credit Information, the parties intending to obtain the Credit Data must have underlying documents relevant to the purpose of obtaining the Credit Information. For example:

  1. A bank intending to obtain the Credit Information in order to extend a credit must have credit application documents from the prospective debtor.
  2. An individual Debtor or Customer intending to obtain the Credit Information in order to know the condition of its financial obligation must submit a proof of personal identity of the Debtor or Customer to LPIP. B. The purpose of the utilization of Credit Information by Financial Institutions shall be in the context of:
  3. the smoothness of provision of fund process, that is to assess the financial condition of the Debtor or prospective Debtor;
  4. the implementation of risk management in supporting the operational activities, namely, among other things, for employee or vendor selection process; and
  5. the compliance with the applicable laws and regulations, such as the regulation of Bank Indonesia concerning the assets quality of commercial banks, requiring commercial banks to determine the quality of provision of fund. C. The purpose of . . . Page 35

C. The purpose of the utilization of Credit Information by non￾Financial Institutions shall be in the context of:

  1. smoothing and securing the operational activities, excluding the marketing activities; and
  2. the compliance with the applicable laws and regulations. D. The purpose of the utilization of Credit Information by another LPIP shall be, among other things, in the context of verification process of any indication of inaccuracy of Credit Data and/or Other Data managed by LPIP. VIII. COMPLAINT HANDLING AND SETTLEMENT A. In the context of handling and settling the complaints from Debtors or Customers, LPIP shall take measures in accordance with the policies and procedures for handling and settling complaints, comprising at least:
  3. complaint reception, both verbally and in writing;
  4. complaint handling and settlement, comprising at least: a. an investigation of complaint regarding the documents and/or data owned by LPIP; b. coordination with the party providing the Credit Data or Other Data; c. correction for the inaccuracy of the product of Data Credit and/or Other Data; and d. settlement period;
  5. monitoring of complaint handling and settlement; and
  6. the organization structure for handling complaints, established adjusted to the size and complexity of business activities of LPIP. B. As a proof of public transparency, specifically to raise public awareness regarding the importance of accuracy of Credit Data and/or Other Data contained in the Credit Information, LPIP shall disseminate or publish, among other things, the benefits of Credit Information and the procedures for filing complaints regarding . . . Page 36

regarding data inaccuracy issues via website. C. In the event that a Debtor or Customer filing complaints regarding the inaccuracy of data that is attributable to LPIP, then LPIP shall settle or handle such complaints by no later than 20 (twenty) business days as of the date on which the complaints is received. In the event that LPIP fails to settle the Debtor or Customer’s complaints within such period, LPIP may request an extension to settle the complaints to the Debtor or Customer for no more than 20 (twenty) business days. The request for extension shall be submitted to the Debtor or Customer within 5 (five) business days prior to the expiration of complaint settlement period. D. The result of complaint settlement or handling shall be informed by LPIP to the Debtor or Customer in writing and/or by using information technology facilities as agreed upon with the Debtor and Customer. E. In the event that the Debtor or Customer filing complaints due to the inaccuracy of data provided by a Financial Institution as the data source, LPIP shall submit a notification to the Financial Institution as the data source under the following provisions:

  1. in the event that the Financial Institution as the data source is a member of LPIP, the complaints regarding the inaccuracy shall be submitted directly to the relevant Financial Institution with a copy to Bank Indonesia; or
  2. in the event that the Financial Institution as the data source is not a member of LPIP, LPIP shall forward the complaints regarding the inaccuracy to Bank Indonesia to be forwarded further to the Financial Institution as the data source. F. In following up the notification as referred to in letter E, the Financial Institution of data source shall be subject to the provisions issued by the authority of each institution concerning the handling of complaints from customers. G. In the event . . . Page 37

G. In the event that data which constitutes the object of complaints needs to be corrected, the Financial Institution of data source shall submit the correction data under the following provisions:

  1. in the event that the inaccurate data is the data submitted through Bank Indonesia, the Financial Institution as the data source shall submit the correction to such data through Bank Indonesia; or
  2. in the event that the inaccurate data is the data submitted directly to LPIP, the Financial Institution as the data source shall submit the correction to such data directly to LPIP. H. In the event of complaints from Debtors or Customers due to inaccurate data provided by non-Financial Institution as the data source, LPIP shall submit notification to the non-Financial Institution as the data source with a copy to Bank Indonesia. IX. SUPERVISION A. Supervision to LPIP provided by Bank Indonesia, either directly (on-site) and/or indirectly (off-site), shall be aimed to ensure that all business activities of LPIP regarding Credit Information are carried out in accordance with the provisions of Bank Indonesia and other related laws and regulations. B. Direct supervision (on-site) shall be carried out by Bank Indonesia through audit conducted regularly and at any time required under the following provisions:
  3. Regular audit shall be conducted at least 1 (one) time a year covering at least the following: a. technology used, at least including the aspects of security, confidentiality, reliability, availability of system and data, as well as the authenticity of information system technology; b. compliance with the provisions of Bank Indonesia and other related laws and regulations, including but not limited . . . Page 38

limited to the management of data, system, confidentiality and security; c. accuracy of the report submitted to Bank Indonesia; and d. implementation of operational policies and procedures. 2. Audit shall be conducted at any time if deemed necessary to verify the results of indirect supervision and/or in the event of indication of misconduct in the implementation of business activities of LPIP. 3. In the context of audit, Bank Indonesia may appoint other parties with the following requirements: a. in the form of legal entity; b. not an affiliated party of LPIP; c. independent; d. competent at its field; and e. having comprehension of the applicable laws and regulations. Audit by other parties may only be conducted for certain matters as set out in the assignment letter from Bank Indonesia. C. Indirect Supervision (off-site) shall be carried out by Bank Indonesia through analysis and evaluation of written report submitted by LPIP to Bank Indonesia. LPIP shall submit the report completely, properly and accurately, consisting of monthly report, semi-annual report, annual report, annual business plan and other incidental reports. D. Provisions for the preparation and submission of monthly report, semi-annual report, annual report and annual business report shall be as follows:

  1. reports shall be prepared by the head office of LPIP on a consolidated basis;

  2. reports shall be prepared by referring to the form as referred to in Attachment H;

  3. reports . . . Page 39

  4. reports shall be submitted to Bank Indonesia via online in the form of electronic data, offline in the form of hard copy, and/or other methods determined by Bank Indonesia;

  5. reports shall be confirmed to be received in accordance with the receipt date by Bank Indonesia;

  6. particularly for annual report, matters to be reported shall at least include the following: a. general information on the management, share ownership, business development and management report; b. annual financial report containing financial position statements (balance sheet), income statements, statements of change in equity and cash flow statements; c. opinion from public accountant; d. other disclosure aspects required in the applicable financial accounting standards; and e. reports on the employment of Foreign Manpower;

  7. annual business plan shall at least contain the following: a. management policies and strategies; b. projected financial statements as well as assumption used; c. plan for capital; d. plan for the development of information system technology e. plan for the issuance of new products and/or implementation of new activities; f. plan for the opening of office; g. plan for the development of human resources and organization; h. plan for the employment of Foreign Manpower; and i. other matters X. TERMINATION . . . Page 40

X. TERMINATION OF BUSINESS ACTIVITIES AND REVOCATION OF OPERATIONAL LICENSE A. Termination of Business Activities and Revocation of Operational License Based on the Request from LPIP

  1. In the event that LPIP will terminate its business activities, LPIP shall submit the application for the termination of business activities to Bank Indonesia in writing by referring to Attachment I and accompanied by the following documents: a. photocopy of the minutes of GMS drawn up by notary concerning the plan for the termination of business activities of LPIP; b. reasons of the termination; c. plan for the settlement of all obligations (action plan) of LPIP which at least includes the following matters:
  1. plan for the settlement of Debtors’ or Customers’ complaints regarding inaccurate data attributable by both the error of LPIP and the error in data source;
  2. plan for the transfer of Credit Data and/or Other Data to Bank Indonesia or other parties designated by Bank Indonesia;
  3. plan for the extermination of data;
  4. plan for the termination of agreement between LPIP and other parties; and
  5. plan for the settlement of other obligations, among other things, the payment of taxes payable, payment of obligations to other parties, payment of salaries payable, payment of office expenses and other relevant costs; d. most recent financial statements; and e. proof of tax settlement based on the results of audit of the Tax Service Office for the last 3 (three) years prior to the date of the application.
  1. After . . . Page 41

  2. After obtaining the letter of termination of business activities from Bank Indonesia, LPIP shall take the following actions: a. terminating all business activities of LPIP; b. announcing the plan for the dissolution of LPIP’s legal entity and the plan for the settlement of obligations of LPIP in 2 (two) daily newspapers having wide circulation by no later than 10 (ten) business days as of the issuance date of the letter of termination of business activities; c. immediately settling all obligations of LPIP; and d. designating a public accountant firm to verify the settlement of obligations of LPIP.

  3. In the event that all obligations of LPIP as referred to in point 2 have been settled, LPIP shall submit an application for the revocation of operational license to Bank Indonesia by referring to Attachment J and accompanied by a report which at least contains the following matters: a. implementation of the termination of business activities; b. implementation of the announcement of the plan for the dissolution of LPIP’s legal entity and the settlement of obligations of LPIP; c. implementation of the settlement of obligations of LPIP; d. report of the verification results from the public accountant firm of the settlement of obligations of LPIP; and e. statement duly stamped from the shareholders that the measures to settle the obligations of LPIP have been completed and in the event of any claim in the future, the shareholders shall be responsible for such claim.

  4. Based on the application for the termination of operational license from LPIP, Bank Indonesia shall conduct examination and/or audit of the settlement of all obligations of LPIP in order to ensure the observance to the implementation of the settlement of all obligations of LPIP as referred to . . . Page 42

as_referred to in item 1.c. 5. Based on the examination and/or audit as referred to in point 4, Bank Indonesia shall issue a decree on the revocation of operational license of LPIP. B. Revocation of Operational License by Bank Indonesia

  1. Bank Indonesia shall revoke the operational license of LPIP in the following events: a. LPIP violates the provisions of Bank Indonesia with sanction in the form of revocation of operational license; and/or b. there is final binding verdict enforcing LPIP to not be able to perform its business activities.
  2. After revoking the operational license, Bank Indonesia shall announce the intended revocation of operational license in 2 (two) daily newspapers having wide circulation by no later than 10 (ten) business days as of the date of revocation of operational license of LPIP.
  3. Following the revocation of operational license, the liquidator of LPIP shall settle obligations consisting of the following matters: a. settlement of complaint from Debtor or Customer by no later than 40 (forty) business days; b. transfer of Credit Data and/or Other Data, if necessary, to Bank Indonesia or other parties designated by Bank Indonesia with the time frame as agreed by both parties after the complaint from Debtor or Customer is settled; c. exterminating the data; d. termination of agreement between LPIP and other parties; and e. settlement of other obligations in accordance with the applicable laws and regulations. C. Procedures for the extermination of data shall be carried out as follows:
  4. In the event that the operational license of LPIP is revoked upon . . . Page 43

upon the request of LPIP, the plan for the extermination of data shall be submitted along with the application for the termination of business activity by LPIP. 2. Plan for the extermination of data as referred to in point 1 shall at least contain the following matters: a. period of the implementation of extermination of data; b. list of the types of data maintained and to be exterminated, including Credit Data and Other Data obtained by LPIP directly from other data sources other than Bank Indonesia. The aforementioned Credit Data and Other Data may be in the form of electronic and non-electronic data (hardcopy); c. parties designated as witnesses in the implementation of extermination of data. The parties acting as witnesses shall be from the data source of LPIP in a minimum of 2 (two) people; and d. extermination mechanism or method to be used. 3. In the event that the operational license of LPIP is revoked by Bank Indonesia, the extermination of data as referred to in item B.3.c may only be conducted after the settlement of obligations as referred to in items B.3.a and B.3.b. 4. The extermination of data as referred to in item B.3.c shall be implemented by the liquidator of LPIP by no later than 20 (twenty) business days after the settlement of obligations as referred to in item B.3.b. 5. In order to ensure that the process of the extermination of data is conducted properly and correctly, the implementation of the aforementioned extermination shall be witnessed by the parties acting as witnesses from the data source of LPIP in a minimum of 2 (two) people and supervised by Bank Indonesia or the parties designated by Bank Indonesia; 6. The liquidator of LPIP and witnesses shall sign the Minutes of the Extermination of Data which at least contain the following information: a. time . . . Page 44

a. time of the extermination of data (day, date, month, year); b. the exterminated data, which at least contains the type, amount and source of data; c. parties conducting the extermination; d. parties witnessing the extermination. XI. SANCTION IMPOSITION PROCEDURE The payment of pecuniary sanction by LPIP to Bank Indonesia shall be made through transfer to “LPIP administrative sanction collection” Account with Bank Indonesia under the following provisions: A. In the event that the transfer is made through clearing, shall be set out in the remarks column namely “the payment of pecuniary sanction from LPIP AAA against [type of violation, sample of error/delay/non-submission of monthly report and/or correction of monthly report] for the period of MM￾YYYY”. B. In the event that the transfer is made through BI-RTGS, shall be set out in the remarks column namely “Transaction Reference Number (TRN)” and it shall also be set out in the remarks column that “the payment of pecuniary sanction from LPIP AAA against error/delay/non-submission of monthly report and/or correction of monthly report for the period of MM-YYYY”. Photocopy of the receipt of payment of pecuniary sanction shall be submitted by LPIP to Bank Indonesia. XII. MAILING ADDRESS Submission of the application, report and photocopy of the receipt of payment of pecuniary sanction, shall be addressed to Bank Indonesia in the following address: Department . . . Page 45

Department of Report Management and Compliance c.q. Group of National Credit Information Management Bank Indonesia Jl. M.H.Thamrin No. 2 Jakarta 10350 XIII. MISCELLANEOUS Attachments A up to J shall form an integral part of this Bank Indonesia Circular Letter. The provisions set out in this Bank Indonesia Circular Letter shall be applicable as of December 5, 2013. For public cognizance, hereby ordering the promulgation of this Bank Indonesia Circular Letter by publishing it in the Official Gazette of the Republic of Indonesia. Hence, please be informed accordingly. BANK INDONESIA [signed and initialed] PERRY WARJIYO DEPUTY GOVERNOR Page 46

ATTACHMENT TO BANK INDONESIA CIRCULAR LETTER NUMBER 15/49/DPKL DATED DECEMBER 5, 2013 CONCERNING LEMBAGA PENGELOLA INFORMASI PERKREDITAN (CREDIT BUREAU) EXAMPLES OF SHARE OWNERSHIP STRUCTURE AND LPIP LICENSING DOCUMENTS BANK INDONESIA

Page I TABLE OF CONTENTS Table of Contents I A Description of LPIP Share Ownership Structure ………...... A-1 A.1 Example of BHI Share Ownership in LPIP …………………… A-1 A.2 Example of Maximum Share Ownership by Foreign Parties in LPIP.............................................................................. A-3 A.3 Example of Maximum Share Ownership by 1 (one) Party in LPIP…........................................................................... A-9 B Example of Application for Approval in Principle to the Establishment of LPIP ……………………………………......... B-1 C Example of Application for Operational License of LPIP … C-1 D Example of Report on the Increase of Paid-up Capital of LPIP ………....................................................................... D-1 E Example of Application for Approval to the Change in the Composition of LPIP Share Ownership……………………… E-1 F Example of Application for Approval to the Change in the Composition of the Members of the Board of Directors and/or Members of the Board of Commissioners of LPIP .. F-1 G Example of the Calculation of Data Acquisition Cost …..... G-1 H Report Submission Form ……………………………………..... H-1 H.1 Example of Cover Letter for Monthly Report Submission … H-1 H.2 Example of Cover Letter for Semi-Annual Report Submission....................................................................... H-4 H.3 Example of Cover Letter for Annual Report Submission … H-5 H.4 Example of Cover Letter for Annual Business Report Submission ……................................................................ H-6 I Example of Application for Approval to the Termination of Business Activity ………………………………………………… I-1 J Example of Application for Approval to the Revocation of Operational License …………………………………………….. J-1 A. Description of . . .

A. Description of LPIP Share Ownership Structure List of Abbreviations

  1. BHI : Badan Hukum Indonesia (Indonesian Legal Entity)
  2. BHA: Badan Hukum Asing (Foreign Legal Entity)
  3. LPIP: Lembaga Pengelola Informasi Perkreditan (Credit Bureau)
  4. WNA: Warga Negara Asing (Foreign Citizen)
  5. WNI: Warga Negara Indonesia ( Indonesian Citizen) A.1. Example of BHI Share Ownership in LPIP Illustration A.1.1 Illustration A.1.1 shows the share ownership structure of PT. LPIP with the following explanation: PT. LPIP is owned by 3 (three) parties, namely BHI A, BHI B and BHI C, without any ownership relationship among BHIs and without any ownership by foreign parties. Thus, the maximum share ownership for 1 (one) party in PT. LPIP shall be 51%. Department . . . Illustration A.1.2 . . . Page A-1

Illustration A.1.2 Illustration A.1.2 shows the share ownership structure of PT. LPIP with the following explanation: PT. LPIP is owned by 3 (three) parties, namely BHI A, BHI B and BHI C, without any ownership relationship among BHIs and without any ownership by foreign parties. However, no parties own shares in the amount of maximum limit of share ownership determined, namely 51%. A.2 Example of . . . Page A-2

A.2 Example of Maximum Share Ownership in LPIP by Foreign Parties Illustration A.2.1: Illustration A.2.1 shows the ownership structure of PT. LPIP with the following explanation:

  1. There are foreign parties as the owner of PT. LPIP in layer 2, namely BHA Y through BHI A, and BHA Z through BHI C.
  2. The total of share ownership of foreign parties (BHA Y and BHA Z) shall be as follows: a. BHA Y = (% share ownership of BHA Y in BHA I multiplied by % share ownership of BHI A in PT. LPIP) = 30% x 50% = 15% The ownership of BHA Y in PT. LPIP is 15%; b. BHA Z = (% share ownership of BHA Z in BHI C multiplied by % share ownership of BHI C in PT. LPIP) = 50% x 10% = 5% The share ownership of BHA Z in PT. LPIP is 5%; The total . . . Page A-3

The total ownership of foreign parties through BHA Y and BHA Z in PT. LPIP is 20%. 3. The total ownership of foreign parties in PT. LPIP have reached the maximum limit determined, namely 20%. Other BHIs (BHI D, BHI E, BHI F, BHI G) is not allowed to be owned by foreign parties up to the ultimate shareholder. Illustration A.2.2 . . . Page A-4

Illustration A.2.2: Illustration A.2.2 shows the ownership structure of PT. LPIP with the following explanation:

  1. There are foreign parties as the owner of PT. LPIP in layer 3, namely BHA Y and WNA Z.
  2. The total of share ownership of foreign parties (BHA Y and WNA Z) shall be as follows: a. BHA Y = (% share ownership of BHA Y in BHI C multiplied by % share ownership of BHI C in BHI A multiplied by % share ownership of BHI A in PT._LPIP) = 75% x 40% x 50% = 15% The share ownership of BHA Y in PT. LPIP is 15%; b. WNA Z = (% share ownership of WNA Z in BHI F multiplied by % share ownership of BHI F in BHI B multiplied by % share ownership of BHI B in PT._LPIP) = 20% x 50% x 50% = 5% The share ownership of WNA Z in PT. LPIP is 5%; The total . . . Page A-5

The total share ownership of foreign parties through BHA Y and WNA Z in PT. LPIP is 20%. 3. The total share ownership of foreign parties in PT. LPIP have reached maximum limit determined, namely 20%. Other BHIs (BHI D, BHI E, BHI H) are not allowed to be owned by foreign parties up to the ultimate shareholder. Illustration A.2.3 . . . Page A-6

Illustration A.2.3 Illustration A.2.3 shows the share ownership structure of PT. LPIP with the following explanation:

  1. There are foreign parties as the owner of PT. LPIP, namely BHA X in layer 2, BHA Y in layer 3 and WNA Z in layer 4.
  2. The total of share ownership of foreign parties (BHA X, BHA Y and WNA Z) shall be as follows: BHA X = (% share ownership of BHA X in BHI A multiplied by % share ownership of BHI A in PT. LPIP) = 20% x 50% = 10% The share ownership of BHA X in PT. LPIP is 10%; a. BHA Y = (% share ownership of BHA Y in BHI E multiplied by % share ownership of BHI E in BHI B multiplied by % share ownership of BHI B in PT._LPIP) = 20% x 50% x 50% = 5% The share ownership of BHA Y in PT. LPIP is 5%; b. WNA Z . . . Page A-7

b. WNA Z = (% share ownership of WNA Z in BHI F multiplied by % share ownership of BHI F in BHI C multiplied by % share ownership of BHI C in BHI A multiplied by % share ownership of BHI A in PT. LPIP) = 25% x 50% x 80% x 50% = 5% The share ownership of WNA Z in PT. LPIP is 5%; The total share ownership of BHA X, BHA Y and WNA Z in PT. LPIP is 20%. 3. The total share ownership of foreign parties in PT. LPIP has reached maximum limit determined, namely 20%. Other BHIs (BHI D, BHI G, BHI H) are not allowed to be owned by foreign parties up to the ultimate shareholder. A.3. Example of . . . Page A-8

A.3. Example of Maximum Share ownership by 1 (one) Party in 1 (one) LPIP Illustration A.3.1 Illustration A.3.1 shows the share ownership structure of PT. LPIP with the following explanation:

  1. There is 1 (one) party, namely: BHI A which constitutes the shareholder in PT. LPIP (in layer 1) and also the owner of PT. LPIP through BHI C (in layer 2). The maximum share ownership of BHI A in PT. LPIP is 51%.
  2. Total share ownership of BHI A in PT. LPIP shall be as follows: BHI A = (% share ownership of BHI A in PT. LPIP) added by (% share ownership of BHI A in BHI C multiplied by % share ownership of BHI C in PT._LPIP) = 31% + (50% x 40%) = 51% Share ownership of BHI A in PT. LPIP is 51%.
  3. Total share ownership of BHI A in PT. LPIP has reached maximum limit (51%), thus BHI A is not allowed to increase its share ownership in PT. LPIP.
  4. Calculation of the maximum share ownership of 1 (one) party in 1 (one) LPIP, shall be also applied for the position in other layers. For example, the share ownership of BHI D in PT. LPIP is as follows: BHI D . . . Page A-9

BHI D = (% share ownership of BHI D (layer 2) in BHI A (layer 1) multiplied by % share ownership of BHI A in PT. LPIP) added by (% share ownership of BHI D (layer 3) in BHI A (layer 2) multiplied by % share ownership of BHI A (layer 2) in BHI C multiplied by % share ownership of BHI C in PT. LPIP) = (99% x 31%) + (99% x 50% x 40%) = 50% Share ownership of BHI D in PT. LPIP is 50%. Illustration A.3.2 . . . Page A-10

Illustration A.3.2

Illustration A.3.2 shows the share ownership structure of PT. LPIP with the following explanation:

  1. There is 1 (one) foreign party, namely: BHA X as the owner of PT. LPIP through BHI_A and BHI C (in layer 2). Total maximum share ownership of BHA X in PT._LPIP is 20%.

  2. Total share ownership of BHA X in PT. LPIP shall be as follows: a. Share ownership of BHA X through BHI A = (% share ownership of BHA X in BHI A) multiplied by (% share ownership of BHI A in PT. LPIP) = 50% x 30% = 15% b. Share ownership of BHA X through BHI C = (% share ownership of BHA X in BHI C) multiplied by (% share ownership of BHI C in PT. LPIP) = 10% x 50% = 5% Total share ownership of BHA X in PT. LPIP is 20%

  3. Total . . . Page A-11

  4. Total share ownership of BHA X has reached maximum limit (20%), thus BHA X is not allowed to increase its share ownership in PT. LPIP.

  5. Calculation of the maximum share ownership of 1 (one) party in 1 (one) LPIP, shall be also applied for the position in other layers. A.4 Example of . . . Page A-12

A.4 Example of Maximum Share ownership by 1 (one) Party in several LPIP Illustration A.4.1 Illustration A.4.1 shows the share ownership structure of PT. LPIP with the following explanation:

  1. There is 1 (one) party of BHI, namely: BHI C which becomes the shareholder in several LPIP, namely: in PT. LPIP 1 and PT. LPIP 2. Total maximum share ownership of BHI C in all LPIP is 51%.

  2. Total share ownership of BHI C in all LPIP shall be as follows: a. Share ownership of BHI C as the shareholder of PT. LPIP 1 is: BHI C in PT. LPIP 1 = 21% b. Share ownership of BHI C in PT. LPIP 2 is: BHI C = (% share ownership of BHI C in BHI E) multiplied by (% share ownership of BHI E in PT. LPIP 2) = 60% x 50% = 30% Total share ownership of BHI C in all LPIP is: 21% + 30% = 51%.

  3. Total . . . Page A-13

  4. Total share ownership of BHI C has reached the share ownership maximum limit in all LPIP (51%), thus BHI C is not allowed to increase its share ownership in another PT. LPIP. Illustration A.4.2 . . . Page A-14

Illustration A.4.2 Illustration A.4.2 shows the share ownership structure of PT. LPIP with the following explanation:

  1. There is 1 (one) foreign party, namely: BHA X which becomes the shareholder in several LPIP, namely: in PT. LPIP 1 and in PT. LPIP

  2. Total maximum share ownership of BHA X in all LPIP is 20%.

  3. Total share ownership of BHA X in all LPIP shall be as follows: a. Share ownership of BHA X in PT. LPIP 1 = (% share ownership of BHA X in BHI B) multiplied by (% share ownership of BHI B in PT. LPIP 1) = 20% x 50% = 10% Share ownership of BHA X in PT. LPIP 1 is 10% b. Share ownership of BHA X in PT. LPIP 2 = (% share ownership of BHA X in BHI E) multiplied by (% share ownership of BHI E in PT. LPIP 2) = 20% x 50% = 10% Share ownership of BHA X in PT. LPIP 2 is 10%. Total share ownership of BHA X in all LPIP is: 10% + 10% = 20%.

  4. Total . . . Page A-15

  5. Total share ownership of BHA X has reached the share ownership maximum limit in all LPIP (20%), thus BHA X is not allowed to increase its share ownership in another PT. LPIP. b. Example of . . . Page A-16

B. Example of Application for Approval in Principle to the Establishment of LPIP city, date-month-year No. : Attachment : …… (in words) file(s) To Governor of Bank Indonesia Jl. M. H. Thamrin No. 2 JAKARTA 10350 Attn. Department of Report Management and Compliance c.q Group of National Credit Information Management Regarding: Application for Approval in Principle to Lembaga Pengelola Informasi Perkreditan - LPIP (Credit Bureau) We hereby file an application in order to obtain approval in principle of LPIP establishment to be named ………. domiciled in …………, ….….. Regency/City ………, ................ Province. In order to complete the application, we hereby enclose the following:

  1. Draft deed of establishment of Limited Liability Company, including draft of the articles of association;

  2. Share ownership data in the form of list of respective prospective shareholders accompanied by the required documents;

  3. List of compositions of prospective members of the Board of Directors and members of the Board of Commissioners accompanied by the required documents;

  4. Plan of the composition and organizational and structure as well as human resources;

  5. Business plan for the first 3 (three) years;

  6. Strategic . . . Page B-1

  7. Strategic plans for medium term and long term;

  8. Design of information technology system to be used;

  9. Design of the requirements for Credit Data of Financial Institution to be obtained from Bank Indonesia;

  10. Guidelines on internal control system and guidelines on the implementation of Good Corporate Governance;

  11. Policies and operational procedures;

  12. A photocopy of deposit certificate in the amount of Rp……………………. (…………….) on behalf of the Board of Governors of Bank Indonesia q.q. ……………………………. for the establishment of LPIP …………… which constitutes of …… % (…… per one hundred) of the minimum paid-up capital required containing that the disbursement may only be conducted after obtaining written approval from the Board of Governors of Bank Indonesia.

  13. A statement letter duly stamped from the prospective shareholders stating that the source of funds used for LPIP share ownership: a. does not originate from any loan or financing facilities in any form whatsoever from banks and/or other parties; and/or b. does not originate from and for the purpose of money laundering. Please be informed accordingly. Name and signature of the prospective shareholder (……………………………………) C. Example of . . . Page B-1

C. Example of Application for the Operational License of LPIP city, date-month-year No. : Attachment : …… (in words) file(s) To Governor of Bank Indonesia Jl. M.H. Thamrin No. 2 JAKARTA 10350 Attn. Department of Report Management and Compliance c.q Group of National Credit Information Management Regarding: Application for the Operational License of Lembaga Pengelola Informasi Perkreditan - LPIP (Credit Bureau) By referring to Bank Indonesia letter Number …………… dated …………….. concerning the Approval in Principle to LPIP, we hereby: Name of LPIP : …………………………… Address : …………………………… submit the application for obtaining operational license of LPIP. In order to complete the application, we hereby enclose the following:

  1. Deed of establishment of LPIP, including the articles of association which have been ratified by the authorized institution;

  2. List of shareholders accompanied by the documents required;

  3. List of compositions of the members of the Board of Directors and members of the Board of Commissioners along with the documents required;

  4. Composition and organizational structure as well as human resources *);

  5. Business plan for the first 3 (three) years *);

  6. Strategic plans for medium-term and long-term *);

  7. Architectural design of the information technology system to be used;

  8. List of . . . Page C-1

  9. List of the Credit Data required from Financial Institution to be obtained from Bank Indonesia *);

  10. Guidelines on the internal control system and guidelines on the implementation of Good Corporate Governance *);

  11. Policies and operational procedures;

  12. A photocopy of deposit certificate in the amount of Rp……………………. (…………….) in the name of the Board of Governors of Bank Indonesia q.q. …………………………. as the repayment of minimum paid-up capital …………… which constitutes …… % (…… per one hundred) of the total minimum paid-up capital required, and has been filled in with the statement that the disbursement may only be conducted after obtaining written approval from the Board of Governors of Bank Indonesia;

  13. A photocopy of document as the proof of payment of the remaining paid-up capital in other forms (non-cash);

  14. A proof of operational readiness as well as the documents required;

  15. Statement duly stamped from the shareholders that the source of funds used in the context of LPIP share ownership: a. does not originate from any loan or financing facilities in any form whatsoever from banks and/or other parties; and/or b. does not originate from and for the purpose of money laundering. Please be informed accordingly. (Board of Directors) (………………………………..) Remarks: *) Only submitted in the event of changes. D. Example of . . . Page C-2

D. Example of Report on the Increase in Paid-Up Capital of LPIP city, date-month-year No. : Attachment : …… (in words) file(s) To Bank Indonesia Jl. M.H. Thamrin No. 2 JAKARTA 10350 Attn. Department of Report Management and Compliance c.q Group of National Credit Information Management Regarding: Report on the Increase in Paid-Up Capital of Lembaga Pengelola Informasi Perkreditan - LPIP (Credit Bureau) In relation to the increase in paid-up capital of LPIP, we hereby enclose the following:

  1. An amendment to the articles of association which has been obtained by the authorized institution dated ……………….. as the copy attached.
  2. Statement duly stamped from the shareholders of LPIP that the change in paid-up capital: a. does not originate from any loan or financing facilities in any form whatsoever from banks and/or other parties; and/or b. does not originate from and for the purpose of money laundering. Please be informed accordingly. (Board of Directors) ( ………………………………. ) E. Example of . . . Page D-1

E. Example of Application for Approval to the Change in Shareholder Composition of LPIP city, date-month-year No. : Attachment : …… (in words) file(s) To Bank Indonesia Jl. M.H. Thamrin No. 2 JAKARTA 10350 Attn. Department of Report Management and Compliance c.q Group of National Credit Information Management Regarding: Application for Approval to the Change in Shareholder Composition of Lembaga Pengelola Informasi Perkreditan - LPIP (Credit Bureau) We hereby file application for the change in shareholder composition of LPIP due to the removal/deduction/addition of shares*) with the following information: A. Current LPIP share ownership: No. Name of Shareholder Total Shares Nominal Amount (in thousand Rp) Percentage (%) 1. 2. Etc. Total B. Plan . . . Page E-1

B. Plan for new LPIP share ownership: No. Name of Shareholder Total Shares Nominal Amount (in thousand Rp) Percentage (%) 1. 2. Etc. Total In order to complete the application, we hereby file the required documents from the prospective shareholders as attached. Please be informed accordingly. (Board of Directors) (………………………………..) Remarks: *) delete if necessary F. Example of . . . Page E-2

F. Example of Application for Approval to the Change in the Composition of the Members of the Board of Directors and/or Members of the Board of Commissioners of LPIP city, date-month-year No : Attachment : …….. (in words) file(s) To Bank Indonesia Jl. M.H. Thamrin No. 2 JAKARTA 10350 Attn. Department of Report Management and Compliance c.q Group of National Credit Information Management Regarding: Application for Approval to the Change in the Composition of the Members of the Board of Directors and/or Members of the Board of Commissioners of LPIP We hereby file application for the change in the composition of the members of the Board of Directors and/or the Board of Commissioners of LPIP ) as follows: A. Current composition of the Members of the Board of Directors and/or Members of the Board of Commissioners of LPIP): No. Name of the Board of Directors and/or the Board of Commissioners *) Position 1. 2. Etc. B. Plan of . . . Page F-1

B. Plan of the New Composition of the Members of the Board of Directors and/or Members of the Board of Commissioners of LPIP *): No. Name of the Board of Directors and/or the Board of Commissioners *) Position 1. 2. Etc. We hereby enclose the documents required. Please be informed accordingly. (Board of Directors) (…………………………………..) Remarks: *) delete if necessary G. Example of . . . Page F-2

G. Example of the Calculation of the Cost of Obtaining the Data

  1. Components of the Calculation For example, based on the calculation and analysis, Bank Indonesia determines that the amount of calculation components of the Data Acquisition Cost is as follows: a. Example of Data Acquisition Cost (Biaya Pengelolaan Data/BPnD) : Rp900,000,000.00 (Nine Hundred Million Rupiah) per month. b. Example of Total LPIP : 3 (three) LPIP c. Example of Business Category Index (Indeks Kategori Bisnis/IKB)
  1. Commercial : 0.8
  2. Retail : 1
  3. MSMEs : 0.5
  4. Combination – MSMEs : 0.6
  5. Combination – non MSMEs : 0.7 d. Example of Information User Index (Indeks Pengguna Umum/IPI)
  6. Commercial Banks (Bank Umum/BU) :0.7
  7. Non Commercial Banks : 0.5
  8. Combination of BU/non BU : 0.6 e. Example of Data Series (DS) During the initial phase, Bank Indonesia will provide data series for the last 24 (twenty-four) months prior to the operation of LPIP. For example . . . Page G-1

For example, LPIP will operate in January 2015, the data series to be provided shall be as follows: Data to be provided Dec 2012 Jan 2013 …. Oct 2014 Nov 2014 Data Provision Period

    • …. - Dec 2014

f. Sample of the Total Months of Data (N) The total months of data are calculated for each period in January, thus the total months of data for LPIP which does not commence its operation in January will be calculated up to the end of the year. For example, LPIP will commence its operation in September 2015, the months of data to be provided shall be as follows: Data to be provided Agt 2015 Sep 2015 Oct 2015 Nov 2015 Data Provision Period Sep 2015 Oct 2015 Nov 2015 Dec 2015 Therefore, up to the end of 2015, the total of months to be calculated is 4 (four). The subsequent year will be started from January. 2. Example of Cases a. PT. LPIP ABC commences its operation in January 2015 with specific business focus to support retail credit provision (for example, credit card). Meanwhile, the members of LPIP using such product are from among Commercial Banks existing in Indonesia. The total costs to be charged shall be as follows:

  1. Example of Initial Data Acquisition Cost During the initial phase of the operation, Bank Indonesia provides 24-month data series (the data from December 2012 up to November 2014), thus the cost of obtaining initial data charged to LPIP shall be as follows: BPDA . . . Page G-2

BPDA = BPnD x IKB x IPI x DS Number of LPIP BPnD : Rp900,000,000.00 IKB : Retail (1) IPI : Commercial Bank (0.7) DS : 24 Number of LPIP : 3 BPDA = Rp900,000,000.00 x 1 x 0.7 x 24 3 BPDA= Rp5,040,000,000.00 (Five Billion and Forty Million Rupiah). 2) Example of Cost of Obtaining Periodical Data The cost of obtaining periodical data will be calculated annually for each period in January. BPDB = BPnD x IKB x IPI x N Number of LPIP BPnD : Rp900,000,000.00 IKB : Retail (1) IPI : Commercial Bank (0.7) N : 12 (data from December 2014 up to November 2015, provided in the period of January up to December 2015) Number of LPIP : 3 BPDB = Rp900,000,000.00 x 1 x 0.7 x 12 3 BPDB = Rp2,520,000,000.00 (Two Billion Five Hundred and Twenty Million Rupiah). b. By referring to . . . Page G-3

b. By referring to the same example of case in number 1 (one) above, in the event that PT. LPIP ABC begins to operate in September 2015, the calculation of the cost of obtaining data shall be as follows:

  1. Example of Cost of Obtaining Initial Data There is no change in the calculation since the variable of business category, user criteria and the total of data series provided by Bank Indonesia are fixed. Therefore, the amount of the cost of initial obtaining data is Rp5,040,000,000.00 (Five Billion and Forty Million Rupiah).
  2. Example of the Cost of Obtaining Periodical Data Since the period of the calculation of periodical data cost is once every January, the following calculation of the cost of obtaining periodical data shall be applied prorate for the LPIP beginning its operation in a month other than January, namely as follows: a) Example of the Cost of Periodical Data in the First Year BPDB = Rp900,000,000.00 x 1 x 0.7 x 4 3 The variable component is the amount of N (the total period of data distributed up to the end of the year), namely 4 (four) consisting of the data from August, September, October and November 2015. BPDB = Rp840,000,000.00 (Eight Hundred and Forty Million Rupiah) b) Example of the Cost of Periodical Data for the Subsequent Year The cost of periodical data for the subsequent year shall be calculated by using the same method as the calculation in item a. The amount of . . . Page G-4

The amount of the cost of periodical data is Rp2,520,000,000.00 (Two Billion Five Hundred and Twenty Million Rupiah). c. By referring to the same example of case set out in point 1 (one) above, in the event that PT. LPIP ABC serves not only to commercial bank, but also rural banks and Financial Institutions, the calculation of the amount of such cost shall be as follows:

  1. Example of Initial Data Acquisition Cost BPDA = Rp900,000,000.00 x 1 x 0.6 x 24 3 IPI : Combination of BU and non-BU (0.6) BPDA = Rp4,320,000,000.00 (Four Billion Three Hundred and Twenty Million Rupiah).
  2. Example of the Cost of Obtaining Periodical Data BPDB = Rp900,000,000.00 x 1 x 0.6 x 12 3 BPDA = Rp2,160,000,000.00 (Two Billion One Hundred and Sixty Million Rupiah). H. Report . . . Page G-5

H. Report Submission Form H. 1. Example of Cover Letter for Monthly Report Submission city, date-month-year No. : Attachment : ….. (in words) file(s) To Bank Indonesia Jl. M.H. Thamrin No. 2 JAKARTA 10350 Attn. Department of Report Management and Compliance c.q Group of National Credit Information Management Regarding: Submission of Monthly Report for the Period of … (month-year) We hereby submit Monthly Report for the Period of ….. (month￾year)* as attached. Please be informed accordingly. (Board of Directors) (…………………………………) Attachement . . . Page H-1

Attachment to Monthly Report for the Period of …. (month-year)

  1. Total Debtors (detailed as Natural Debtors and Business Entity Debtors);
  2. Total Customers (detailed as Natural Debtors and Business Entity Debtors);
  3. Total Provision of Fund Facilities (detailed based on the type of facility);
  4. Total Financial Institutions becoming the members of LPIP (detailed based on the category of business activities);
  5. Total non-Financial Institutions becoming the members of LPIP (detailed based on the category of business activities);
  6. Total demand for Credit Information from the members (detailed based on the purposes of such demand);
  7. Total demand for Credit Information from the community (detailed based on the purpose of such demand); Number 1 up to number 6 may be presented in the form of series (table and/or chart) at least for the last 3 (three) months.
  8. Data on the handling of complaints from Debtors or Customers a. Total complaints from Debtors or Customers due to the data on Credit Information: Jan …. …. Total complaints being handled: a. Debtors b. Customers Total new complaints in current month: a. Debtors b. Customers Total complaints proved to be invalid: a. Debtors b. Customers . . . Page H-2

b. Customers Total unresolved complaints in current month a. Debtors b. Customers b. Total complaints from Debtors or Customers due to delivery of Credit Information to the incorrect Debtors or Customers; c. Total complaints from Debtors or Customers due to the Debtors’ or Customers’ data are mixed in the Credit Information; d. Total complaints from Debtors or Customers that becoming lawsuit. H. 2. Example of . . . Page H-3

H. 2. Example of Cover Letter for Semi-annual Report Submission city, date-month-year No. : Attachment : …. (in words) file(s) To Bank Indonesia Jl. M. H. Thamrin No. 2 JAKARTA 10350 Attn. Department of Report Management and Compliance c.q Group of National Credit Information Management Regarding: Submission of Biannual Report for the Period of Semester (I/II)* year .. We hereby submit the attached Report of Semester (I/II)* year …. as required. Please be informed accordingly. (Board of Directors) (………………………………….) Remarks: *) delete if necessary H. 3. Example of . . . Page H-4

H.3. Example of Cover Letter for Annual Report Submission city, date-month-year No. : Attachment : …. (in words) file(s) To Bank Indonesia Jl. M.H. Thamrin No. 2 JAKARTA 10350 Attn. Department of Report Management and Compliance c.q Group of National Credit Information Management Regarding: Submission of Annual Report for the Period of the Year... We hereby submit the attached Annual Report for the Period of the Year …… as required. Please be informed accordingly. (Board of Directors) (…………………………………) H.4. Example of . . . Page H-5

H.4. Example of Cover Letter for Annual Business Plan Submission city, date-month-year No. : Attachment : …… (in words) file(s) To Bank Indonesia Jl. M.H. Thamrin No. 2 JAKARTA 10350 Attn. Department of Report Management and Compliance c.q Group of National Credit Information Management Regarding: Submission of Annual Business Plan for the Period of the Year …. We hereby submit the attached Annual Business Plan for the Period of the Year … as required. Please be informed accordingly. (Board of Directors) (…………………………………) I. Example of . . . Page H-6

I. Example of Letter of Application for Approval to the Termination of Business Activities city, date-month-year No. : Attachment : ….. (in words) file(s) To Bank Indonesia Jl. M.H. Thamrin No. 2 JAKARTA 10350 Attn. Department of Report Management and Compliance c.q Group of National Credit Information Management Regarding: Application for Approval to the Termination of Business Activities of Lembaga Pengelola Informasi Perkreditan – LPIP (Credit Bureau) We hereby file applciation for approval in the termination of business activities of LPIP ………. by the reason of …………………….. We herewith submit documents with the following details:

  1. A photocopy of minutes of the General Meeting of Shareholders concerning the plan for the termination of business activities of LPIP;
  2. Report of the plan and reasons of the termination of business activities of LPIP;
  3. Plan for the settlement of all obligations (action plan) of LPIP;
  4. Most recent financial statements; and
  5. Proof of tax settlement for the last 3 (three) years. Please be informed accordingly. (Board of Directors) (……………………………….) J. Example of . . . Page I-1

J. Example of Application for Approval to the Revocation of Operational License city, date-month-year No. : Attachment : …… (in words) file(s) To Bank Indonesia Jl. M.H. Thamrin No. 2 JAKARTA 10350 Attn. Department of Report Management and Compliance c.q Group of National Credit Information Management Regarding: Application for Approval to the Revocation of Operational License of Lembaga Pengelola Informasi Perkreditan - LPIP (Credit Bureau) We hereby file application for approval to the revocation of operational license (name of LPIP) …….. as of ……………… We hereby submit the report containing the following information:

  1. Implementation of the termination of business activities;
  2. Implementation of the announcement of the plan for dissolution and settlement of obligations;
  3. Implementation of the settlement of obligations;
  4. Report on the verification results from public accountant firm upon the settlement of obligations; and
  5. Statement duly stamped from the shareholders concerning the settlement of obligations. Please . . . Page J-1

Please be informed accordingly. (Board of Directors) (……………………………….) DEPUTY GOVERNOR OF BANK INDONESIA [signed and initialed] PERRY WARJIYO DEPUTY GOVERNOR Page J-2