FINANCIAL SERVICES AUTHORITY REGULATION

REPUBLIC OF INDONESIA

NUMBER 38 OF 2025

ON

LAWSUITS BY THE FINANCIAL SERVICES AUTHORITY

FOR CONSUMER PROTECTION IN THE FINANCIAL SERVICES SECTOR

BY THE GRACE OF GOD THE ALMIGHTY,

THE BOARD OF COMMISSIONERS OF THE FINANCIAL SERVICES AUTHORITY,

Considering:
a. that the Financial Services Authority was established with the objective that all activities within the financial services sector can be conducted in an orderly, fair, transparent, and accountable manner, capable of realizing a financial system that grows sustainably and stably, and capable of protecting consumer interests; b. that as a consumer protection effort, the Financial Services Authority has the authority to conduct legal defense by filing lawsuits to recover the wealth of the injured party and/or to obtain compensation from the party causing the loss in accordance with Article 30 paragraph (1) letter b and Article 30 paragraph (2) of Law Number 21 of 2011 concerning the Financial Services Authority as amended by Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector;
c. that based on the considerations referred to in letters a and b, it is necessary to establish a Financial Services Authority Regulation concerning Lawsuits by the Financial Services Authority for Consumer Protection in the Financial Services Sector;

Recalling:

1. Law Number 21 of 2011 concerning the Financial Services Authority (State Gazette of the Republic of Indonesia Year 2011 Number 111, Supplement to the State Gazette of the Republic of Indonesia Number 5253) as amended by Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);

2. Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);

DECIDES:

To Establish: A FINANCIAL SERVICES AUTHORITY REGULATION CONCERNING LAWSUITS BY THE FINANCIAL SERVICES AUTHORITY FOR CONSUMER PROTECTION IN THE FINANCIAL SERVICES SECTOR.

CHAPTER I

GENERAL PROVISIONS

Article 1

In this Financial Services Authority Regulation:

1. Financial Services Institution, hereinafter abbreviated as FSI, is a financial services institution as referred to in the law concerning the development and strengthening of the financial sector.

2. Financial Services Business Actor, hereinafter abbreviated as FSBA, is:
   a. FSI and/or parties conducting business activities of fund collection, fund disbursement, and/or fund management in the financial services sector; and b. other financial services business actors, both those conducting business activities conventionally and those based on Sharia principles, in accordance with regulations in the financial services sector.

3. Consumer is every person who owns and/or utilizes products and/or services provided by FSBA.

4. Every Person is an individual, corporation, or business entity, whether formed as a legal entity or not, or other bodies.

5. Consumer Protection is all efforts ensuring legal certainty to provide protection to Consumers.

6. Lawsuit is a claim submitted to the court by the Financial Services Authority in the event of a dispute which, based on the Financial Services Authority's assessment, involves violations by a party against regulations in the financial services sector resulting in material losses to Consumers and/or FSIs to obtain a court decision.

7. Other Financial Services Institutions are pawnshops, guarantee institutions, Indonesian export financing institutions, secondary housing financing companies, technology-based joint funding service providers, and institutions managing mandatory public funds, including social security, pension, and welfare program providers, as referred to in regulations concerning pawnshops, guarantees, Indonesian export financing institutions, secondary housing financing companies, and mandatory public fund management, as well as other financial services institutions supervised by the Financial Services Authority based on regulations.

Article 2

FSBAs consist of:
a. FSIs including:

1. commercial banks;
2. rural economy banks;
3. securities companies;
4. pension funds;
5. insurance companies;
6. reinsurance companies;
7. financing companies;
8. infrastructure financing companies;
9. venture capital companies;
10. microfinance institutions; and
11. Other Financial Services Institutions;
    b. parties conducting business activities of fund collection, fund disbursement, and fund management in the financial services sector, which are licensed and supervised by the Financial Services Authority based on regulations; and
    c. other financial services business actors, including parties implementing financial sector technology innovations in the financial services sector, which are licensed and supervised by the Financial Services Authority based on regulations, both conducting business activities conventionally and Sharia-based.

CHAPTER II

AUTHORITY TO FILE LAWSUITS FOR CONSUMER PROTECTION IN THE FINANCIAL SERVICES SECTOR

Article 3

(1) The Financial Services Authority has the authority to conduct legal defense by filing Lawsuits for Consumer Protection.

(2) The Financial Services Authority files Lawsuits as referred to in paragraph (1) against:
a. FSBAs that have a license or previously had a license from the Financial Services Authority; and/or b. other parties acting in bad faith causing losses.

Article 4

(1) Lawsuits as referred to in Article 3 paragraph (1) are lawsuits based on legal standing granted by law and are not class action lawsuits.

(2) Lawsuits as referred to in paragraph (1) are filed based on tortious acts.

(3) Lawsuits as referred to in paragraph (1) are conducted based on the Financial Services Authority's assessment.

(4) Lawsuits as referred to in paragraph (1) are filed without requiring a special power of attorney from the Consumer.

(5) Lawsuits as referred to in paragraph (1) are filed in court in accordance with regulations.

Article 5

The filing of Lawsuits for Consumer Protection applies the principles of:
a. public interest; b. benefit;
c. legal certainty; and
d. justice.

CHAPTER III

OBJECTIVES OF LAWSUITS FOR CONSUMER PROTECTION IN THE FINANCIAL SERVICES SECTOR

Article 6

(1) Lawsuits as referred to in Article 3 paragraph (1) aim to:
a. recover the wealth of the injured party from the party causing the loss, whether under the control of the party causing the loss or under the control of other parties acting in bad faith; and/or b. obtain compensation from the party causing losses to Consumers and/or FSIs as a result of violations of regulations in the financial services sector.

(2) Compensation as referred to in paragraph (1) letter b is used to pay compensation to the injured party.

CHAPTER IV

IMPLEMENTATION OF LAWSUITS FOR CONSUMER PROTECTION IN THE FINANCIAL SERVICES SECTOR

First Section

Coordination and Announcement of Lawsuits

Article 7

The Financial Services Authority may coordinate with external parties in the process of filing Lawsuits.

Article 8

(1) The Financial Services Authority announces the list of Consumers to be included in the Lawsuit before filing the Lawsuit as referred to in Article 3.

(2) The announcement as referred to in paragraph (1) is conveyed at least through:
a. the official website and social media of the Financial Services Authority; b. notice boards at the Financial Services Authority offices; and
c. national newspapers.

(3) The announcements as referred to in paragraph (2) are conducted for the first time on the same date.

(4) Announcements via the official website and social media of the Financial Services Authority and notice boards at the Financial Services Authority offices as referred to in paragraph (2) letters a and b are implemented for a period of 30 (thirty) working days calculated from the date of the first announcement as referred to in paragraph (3).

(5) Announcements via national newspapers as referred to in paragraph (2) letter c are implemented at least 3 (three) times for a period of 30 (thirty) working days calculated from the date of the first announcement as referred to in paragraph (3).

(6) Announcements as referred to in paragraph (1) contain at least:
a. the list of Consumers to be included in the Lawsuit; b. Consumer rights to declare withdrawal from the Consumer list; and
c. the time limit for submitting withdrawal statements by Consumers.

(7) Announcements as referred to in paragraph (6) may contain requests for supporting documents to be submitted by Consumers who do not submit withdrawal statements.

Article 9

(1) Consumers who do not wish to be included in the list of Consumers to be included in the Lawsuit as referred to in Article 8 paragraph (1) must submit a written withdrawal statement to the Financial Services Authority.

(2) Withdrawal statements as referred to in paragraph (1) contain at least:
a. the name and identity proof of the Consumer; and b. the Consumer's statement that they do not wish to join the Lawsuit filed by the Financial Services Authority.

(3) Withdrawal statements as referred to in paragraph (1) are submitted by Consumers to the Financial Services Authority within a maximum period of 30 (thirty) working days calculated from the date of the first announcement as referred to in Article 8 paragraph (3).

(4) Withdrawal statements as referred to in paragraph (1) are submitted to the Financial Services Authority offline and/or online.

(5) The procedure for submitting withdrawal statements as referred to in paragraph (4) is stated in the announcement as referred to in Article 8 paragraph (1).

(6) Consumers submitting withdrawal statements as referred to in paragraph (1) may file separate lawsuits in accordance with regulations.

(7) Consumers as referred to in paragraph (1) are not entitled to recover wealth and/or compensation from Lawsuits from the Financial Services Authority.

Article 10

(1) In the event that the announcement contains requests for supporting documents as referred to in Article 8 paragraph (7), Consumers who do not submit withdrawal statements as referred to in Article 9 paragraph (1) submit:
a. copies of identity proofs; b. copies of proofs of ownership or utilization of products and/or services; and
c. other supporting documents related to the utilization of products and/or services (if any).

(2) Supporting documents as referred to in paragraph (1) are submitted by Consumers to the Financial Services Authority in writing within a maximum period of 45 (forty-five) working days calculated from the date of the announcement.

Article 11

(1) The Financial Services Authority does not accept withdrawal statements as referred to in Article 9 paragraph (1) after the time limit as referred to in Article 9 paragraph (3) has expired.

(2) The Financial Services Authority does not accept requests to add Consumer names to the list of Consumers to be included in the Lawsuit as referred to in Article 8 paragraph (1).

Second Section

Filing of Lawsuits

Article 12

The Financial Services Authority, in filing Lawsuits as referred to in Article 3 paragraph (1), grants special powers of attorney to:
a. Financial Services Authority employees; b. workers through fixed-term employment agreements with the Financial Services Authority; and/or
c. other parties who, according to regulations, can act as attorneys in filing Lawsuits.

Article 13

(1) Drafting and/or regulation regarding:
a. the content of Lawsuits; and/or b. the mechanism for paying compensation, are implemented in accordance with regulations.

(2) The content of Lawsuits as referred to in paragraph (1) letter a may be accompanied by a list of wealth owned by the injured party located under the control of the defendant or other parties and/or a list of the defendant's wealth.

Article 14

(1) The liquidation process of FSBAs and/or other parties does not hinder the authority of the Financial Services Authority to file Lawsuits against FSBAs and/or other parties undergoing liquidation.

(2) In the event that FSBA:
a. is in a banking restructuring program implemented by an institution managing deposit insurance and insurance policy guarantee programs, the Financial Services Authority may only file Lawsuits against assets other than the assets of banks participating in the banking restructuring program; b. is a bank in resolution handled by an institution managing deposit insurance and insurance policy guarantee programs, the Financial Services Authority may only file Lawsuits against assets other than the assets of banks in resolution;
c. is in a liquidation process implemented by an institution managing deposit insurance and insurance policy guarantee programs, the Financial Services Authority may only file Lawsuits against assets other than liquidation assets; or
d. is a bank receiving short-term liquidity loans or financing from the Bank of Indonesia, the Financial Services Authority may only file Lawsuits against bank assets not used as collateral for such loans or financing.

CHAPTER V

IMPLEMENTATION OF COURT DECISIONS ON LAWSUITS FOR CONSUMER PROTECTION IN THE FINANCIAL SERVICES SECTOR

Article 15

(1) In the event that a court decision that has acquired permanent legal force fully or partially grants the Lawsuit, the Financial Services Authority:
a. informs Consumers and/or related parties regarding the plan and mechanism for distributing compensation payments based on the court decision that has acquired permanent legal force, through communication channels designated by the Financial Services Authority; b. implements the distribution of compensation payments based on the court decision that has acquired permanent legal force; and
c. administers the results of the implementation of compensation payment distribution.

(2) The Financial Services Authority implements court decisions as referred to in paragraph (1) after the court hands over the execution results to the Financial Services Authority in accordance with regulations.

Article 16

(1) Consumers are not charged costs for the implementation of Lawsuits up to the implementation of court decisions.

(2) Costs required for the implementation of Lawsuits up to the implementation of court decisions are charged to the Financial Services Authority's budget in accordance with regulations.

Article 17

The Financial Services Authority may appoint third parties to implement the distribution and/or administer the results of compensation payment distribution based on court decisions as referred to in Article 15 paragraph (1) letters b and/or c.

Article 18

In the event that there are Consumers:
a. who reject the compensation results; and/or b. who are not found during the compensation payment distribution process as referred to in Article 15 paragraph (1) letter b, the Financial Services Authority deposits Consumer loss payments to the court or other institutions/parties in accordance with regulations.

CHAPTER VI

REPORTS ON THE IMPLEMENTATION OF DECISIONS

Article 19

(1) The Financial Services Authority prepares reports on the implementation of decisions regarding the distribution of compensation payments.

(2) Reports on the implementation of decisions regarding the distribution of compensation payments as referred to in paragraph (1) are submitted to the court.

(3) Reports on the implementation of decisions regarding the distribution of compensation payments as referred to in paragraph (1) contain at least:
a. the name and identity of Consumers; b. the classification of Consumers who received, Consumers who rejected, and Consumers who were not found;
c. the nominal amount of compensation for each classification of Consumers as referred to in letter b; and
d. the date of compensation payment distribution.

(4) The implementation of compensation payment distribution is declared complete after the Financial Services Authority submits the report as referred to in paragraph (2).

(5) The Financial Services Authority publishes a summary of the report on the implementation of decisions regarding the distribution of compensation payments as referred to in paragraph (1).

CHAPTER VII

CLOSING PROVISIONS

Article 20

Upon the enactment of this Financial Services Authority Regulation, Article 98 paragraph (1) letter b, Article 99, and Article 100 of Financial Services Authority Regulation Number 22 of 2023 concerning Consumer and Community Protection in the Financial Services Sector (State Gazette of the Republic of Indonesia Year 2023 Number 40/OJK, Supplement to the State Gazette of the Republic of Indonesia Number 62/OJK) are repealed and declared invalid.

Article 21

This Financial Services Authority Regulation takes effect upon enactment.

To ensure that everyone knows it, it is ordered to enact this Financial Services Authority Regulation by placing it in the State Gazette of the Republic of Indonesia.

Established in Jakarta on 18 December 2025

THE CHAIRMAN OF THE BOARD OF COMMISSIONERS
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA,

MAHENDRA SIREGAR

Enacted in Jakarta on [Date]

THE MINISTER OF LAW OF THE REPUBLIC OF INDONESIA,

SUPRATMAN ANDI AGTAS

STATE GAZETTE OF THE REPUBLIC OF INDONESIA YEAR 2025 NUMBER [Number]

EXPLANATION

OF

FINANCIAL SERVICES AUTHORITY REGULATION

REPUBLIC OF INDONESIA

NUMBER 38 OF 2025

ON

LAWSUITS BY THE FINANCIAL SERVICES AUTHORITY

FOR CONSUMER PROTECTION IN THE FINANCIAL SERVICES SECTOR

I. GENERAL

The establishment of the Financial Services Authority aims to ensure that all activities within the financial services sector are conducted in an orderly, fair, transparent, and accountable manner, capable of realizing a financial system that grows sustainably and stably, and protects the interests of Consumers and the community. The Financial Services Authority has the authority to take preventive actions against losses to Consumers and the community, provide complaint services, and conduct legal defense. In conducting legal defense, the Financial Services Authority has the authority to file Lawsuits against parties harming Consumers.

Lawsuits conducted by the Financial Services Authority are based on the principle of legal standing exercised by the institution based on law. The filing process is executed following supervision actions based on regulations in the financial services sector. Lawsuits filed by the Financial Services Authority do not represent a specific party or a class action of persons with similar facts or legal grounds, but are based on authority granted by Law.

Lawsuits are filed based on the Financial Services Authority's assessment of FSBAs and/or other parties causing losses to consumers in the financial services sector due to violations of regulations in the financial services sector.

Based on these considerations, it is necessary to draft a Financial Services Authority Regulation concerning Lawsuits by the Financial Services Authority for Consumer Protection in the Financial Services Sector, which generally contains main materials arranged systematically, including regulating the authority to file Lawsuits, implementation of Lawsuits, implementation of decisions, and reporting on the implementation of decisions.

II. ARTICLE BY ARTICLE

Article 1

Sufficiently clear.

Article 2

Letter a

Number 1

Sufficiently clear.

Number 2

Sufficiently clear.

Number 3

Sufficiently clear.

Number 4

Sufficiently clear.

Number 5

Sufficiently clear.

Number 6

Sufficiently clear.

Number 7

Sufficiently clear.

Number 8

Sufficiently clear.

Number 9

Sufficiently clear.

Number 10

Sufficiently clear.

Number 11

Examples of Other Financial Services Institutions managing mandatory public funds, including social security, pension, and welfare program providers, as referred to in regulations on mandatory public fund management, include BPJS Kesehatan, BPJS Ketenagakerjaan, BP Tapera, and PT Asabri (Persero).

Letter b

Parties conducting business activities of fund collection, fund disbursement, and fund management in the financial services sector, as well as those supervised by the Financial Services Authority based on regulations, include PT Permodalan Nasional Madani and Funding Service Providers.

Letter c

The term "financial sector technology innovation" refers to technology-based innovations impacting products, activities, services, and business models in the digital financial ecosystem.

Parties implementing financial sector technology innovations in the financial services sector include parties conducting:

1. Securities transaction settlement, including clearing processes, settlement processes, ownership recording, and securities storage in the capital market;
2. Fund raising, including technology innovations in raising public funds through securities offerings using electronic system providers (securities crowdfunding), adhering to relevant regulations including capital market laws;
3. Investment management, including technology innovations in investment management;
4. Risk management, including technology innovations for product development, claim handling, distribution, and sales;
5. Fund collection and/or disbursement, including digital banking and technology-based peer-to-peer lending;
6. Market supporters, which are technology innovations supporting FSI needs, including data collection;
7. Activities related to digital financial assets, including crypto assets which are financial assets stored or represented digitally; and
8. Other digital financial services activities.

Article 3

Paragraph (1)

Sufficiently clear.

Paragraph (2)

Letter a

Licenses granted by the Financial Services Authority include registration, recording, approval, determination, and/or issuance of licenses.

The term "previously had a license" refers to FSBAs whose licenses have been revoked by the Financial Services Authority and are still in the liquidation process.

Letter b

The term "other parties" includes controlling shareholders, beneficial owners, market manipulators, issuers, public companies, and supporting professions in the financial services sector.

Examples of bad faith:

1. Other parties controlling wealth belonging to Consumers obtained in violation of regulations.
2. Intentional transfer of assets to avoid obligations.
3. Concealment of beneficial owners.

Article 4

Paragraph (1)

The Financial Services Authority files Lawsuits with legal standing based on Article 30 paragraph (1) letter b and Article 30 paragraph (2) of Law Number 21 of 2011 concerning the Financial Services Authority as amended by Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector.

Legal standing can be interpreted as the right of the Financial Services Authority as the plaintiff in court during the Lawsuit process. The Financial Services Authority files Lawsuits not because the Financial Services Authority has a direct connection...

with the losses suffered by Consumers, but rather to implement the mandate of the law. The Financial Services Authority, as the regulator, conducts an assessment to file a Lawsuit in order to provide Consumer Protection.

What is meant by "not a class action lawsuit" is a Lawsuit conducted by the Financial Services Authority as the regulator, not to represent itself and not to represent a group having common facts or legal basis.

Paragraph (2)

What is meant by "unlawful act" is any act that violates the law and causes loss to others, obligating the person who caused the loss due to their fault to compensate for that loss.

Elements of an unlawful act, namely:
a. an act that violates provisions of legislation in the financial services sector carried out by the party to be sued; b. there is fault committed by the party to be sued;
c. there is material loss suffered by the Consumer; and
d. there is a causal relationship between the unlawful act by the party to be sued and the loss suffered by the Consumer.

Paragraph (3)

What is meant by "Financial Services Authority assessment" is the consideration of the Financial Services Authority before filing a Lawsuit that the violation committed by a party against legislation in the financial services sector results in material loss for Consumers in the financial services sector, and supervisory actions have been carried out based on provisions of legislation in the financial services sector.

The Financial Services Authority has the authority to consider the consequences of material loss from the violation that occurred and proceed to the stage of filing a Lawsuit with the court. The Financial Services Authority files a Lawsuit not at the request of the Consumer.

Paragraph (4)

Clearly sufficient.

Paragraph (5)

Clearly sufficient.

Article 5

Letter a

What is meant by "public interest" is a principle that defends and protects Consumer interests and promotes general welfare.

Letter b

What is meant by "benefit" is that the filing of a Lawsuit provides a positive impact for Consumer Protection efforts and prevents greater losses for Consumers and the financial services industry, and provides a deterrent effect on parties who violate provisions of legislation in the financial services sector.

Letter c

What is meant by "legal certainty" is that the filing of a Lawsuit is carried out by prioritizing the basis of legislation.

Letter d

What is meant by "justice" is that the filing of a Lawsuit is to provide Consumer Protection in obtaining the return of assets and/or compensation for losses.

Article 6

Clearly sufficient.

Article 7

What is meant by "external parties" includes ministries/agencies, law enforcement officials, external legal advisors, legal practitioners, and academics.

Examples of Financial Services Authority coordination with law enforcement officials in the event of an overlap between the Lawsuit case and alleged criminal offenses, specifically regarding elements of unlawful acts, seizure of guarantees, and asset tracing.

Article 8

Paragraph (1)

What is meant by "Consumer list" is the names of Consumers who have been verified by the Financial Services Authority and entered into the Consumer list.

The Consumer list can be conveyed by the Financial Services Authority through links in announcements.

Paragraph (2)

Letter a

Clearly sufficient.

Letter b

What is meant by "Financial Services Authority office" is the central Financial Services Authority office and/or Financial Services Authority offices in the regions.

Announcements at Financial Services Authority offices are adjusted to the coverage area of the PUJK and/or other parties being sued.

Letter c

National newspapers can be in the form of print media and/or electronic media.

Paragraph (3)

Clearly sufficient.

Paragraph (4)

What is meant by "announcement date" is the date the announcement is published on the official website and social media of the Financial Services Authority and the date the announcement is published on the bulletin board at the Financial Services Authority office.

Paragraph (5)

The implementation of 3 (three) announcements is carried out by paying attention to a reasonable time interval between announcements and paying attention to the final deadline for announcements.

Paragraph (6)

Clearly sufficient.

Paragraph (7)

Clearly sufficient.

Article 9

Paragraph (1)

Clearly sufficient.

Paragraph (2)

Letter a

What is meant by "identity proof" includes National Identity Number (NIK).

Letter b

Clearly sufficient.

Paragraph (3)

Clearly sufficient.

Paragraph (4)

Submission of offline exit statements is done by:

1. handed over directly; or
2. sent through a courier service company.

Paragraph (5)

Clearly sufficient.

Paragraph (6)

Clearly sufficient.

Paragraph (7)

Clearly sufficient.

Article 10

Paragraph (1)

Letter a

Copy of identity proof in the form of Identity Card, passport, and/or residence permit.

Letter b

What is meant by "proof of ownership of products and/or utilization of services" includes insurance policies, deposit receipts, mutual fund confirmation letters, copies of credit agreements, and copies of financing agreements, which can be in electronic form.

Letter c

What is meant by "other supporting documents" includes Dispute Resolution Effort Documents.

Paragraph (2)

Clearly sufficient.

Article 11

Clearly sufficient.

Article 12

What is meant by "employee" is an employee of the Financial Services Authority appointed based on a Decree of the Commissioners of the Financial Services Authority for an indefinite period and employees assigned from other institutions/agencies who work at the Financial Services Authority.

Examples of other parties:

1. external legal advisors; and
2. state attorneys,

based on a special power of attorney which according to provisions of legislation can become a representative in filing a Lawsuit.

What is meant by "external legal advisor" is a law firm or legal research and development institution, legal consultant, advocate, or individual, whose activities provide legal services, both in Indonesia and/or outside Indonesia.

Article 13

Paragraph (1)

What is meant by "provisions of legislation" includes Supreme Court regulations regarding the procedures for adjudicating lawsuits filed by the Financial Services Authority as a consumer protection effort.

Paragraph (2)

Clearly sufficient.

Article 14

Paragraph (1)

What is meant by "other party" is a legal entity that can undergo a liquidation process.

Paragraph (2)

Clearly sufficient.

Article 15

Paragraph (1)

Letter a

What is meant by "related party" includes the Deposit Insurance Institution, Bank Indonesia, and the Attorney General's Office of the Republic of Indonesia.

Letter b

Clearly sufficient.

Letter c

Clearly sufficient.

Paragraph (2)

Clearly sufficient.

Article 16

Paragraph (1)

What is meant by "implementation of Lawsuit" includes from the announcement to the implementation of the trial in court.

What is meant by "implementation of court decision" includes the distribution of compensation to the injured party.

Paragraph (2)

See explanation of paragraph (1).

Article 17

Clearly sufficient.

Article 18

What is meant by "institution/other party according to legislation" includes estate administration offices.

Article 19

Paragraph (1)

Clearly sufficient.

Paragraph (2)

Clearly sufficient.

Paragraph (3)

Letter a

See explanation of Article 9 paragraph (2) letter a.

Letter b

Clearly sufficient.

Letter c

Clearly sufficient.

Letter d

What is meant by "date of distribution of compensation payment" is the date of receipt or date of rejection of the distribution of compensation payment to the Consumer.

Paragraph (4)

Clearly sufficient.

Paragraph (5)

Publication is carried out, among others, through the Financial Services Authority website.

Article 20

Clearly sufficient.

Article 21

Clearly sufficient.

SUPPLEMENT TO THE STATE GAZETTE OF THE REPUBLIC OF INDONESIA NUMBER ⸙ ---