Operation of Information Technology-Based Crowdfunding Services (LPBBTI)

To:
Directors of Information Technology-Based Crowdfunding Service Organizers, At your offices.

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

In accordance with the mandate of Article 25 paragraph (3), Article 26 paragraph (8), Article 29 paragraph (2) and (3), Article 35 paragraph (6), Article 36 paragraph (9), Article 44 paragraph (2), Article 51 paragraph (3), Article 101 paragraph (6), and Article 104 paragraph (2) of Financial Services Authority Regulation Number 10/POJK.05/2022 concerning Information Technology-Based Crowdfunding Services (State Gazette of the Republic of Indonesia Year 2022 Number 2/OJK, Supplement to the State Gazette of the Republic of Indonesia Number 2/OJK), it is necessary to further regulate the operation of information technology-based crowdfunding services in this Financial Services Authority Circular Letter as follows:

I. GENERAL PROVISIONS
In this Financial Services Authority Circular Letter, the following terms are defined as:

1. Information Technology-Based Crowdfunding Services, hereinafter abbreviated as LPBBTI, are the provision of financial services to match fund providers with fund recipients in conducting conventional financing or financing based on Sharia principles directly through an electronic system using the internet.

2. Financing is the disbursement of funds from fund providers to fund recipients with a promise to be paid or returned according to a specific time frame in LPBBTI transactions.

3. Sharia Principles are Islamic legal principles based on fatwas and/or Sharia compliance statements issued by institutions having authority in determining fatwas in the Sharia field.

4. Electronic System is a series of electronic devices and procedures that function to prepare, collect, process, analyze, store, display, announce, send, and/or disseminate electronic information in the field of financial services.

5. Information Technology is a technique to collect, prepare, store, process, announce, analyze, and/or disseminate information in the field of financial services.

6. LPBBTI Organizer, hereinafter referred to as Organizer, is an Indonesian legal entity that provides, manages, and operates LPBBTI, either conventionally or based on Sharia Principles.

7. Fund Recipient is an individual, legal entity, and/or business entity that receives Financing.

8. Fund Provider is an individual, legal entity, and/or business entity that provides Financing.

9. LPBBTI User, hereinafter referred to as User, is the Fund Provider and Fund Recipient.

10. Sharia Supervisory Board, hereinafter abbreviated as DPS, is a board that has the task and function of supervision and provides advice to the Directors regarding the operation of the Organizer's activities to ensure compliance with Sharia Principles.

11. Personal Data is any data about a person, whether identifiable and/or identifiable separately or combined with other information, whether directly or indirectly through Electronic Systems and/or non-electronic systems.

II. BUSINESS ACTIVITIES OF LPBBTI ORGANIZERS

1. The business activities of the Organizer consist of:
   a. provision; b. management; and
   c. operation,
   of LPBBTI.

2. The provision business activity as referred to in item 1 letter a is that the Organizer provides an Electronic System that matches Fund Providers and Fund Recipients in conducting Financing transactions directly, and provides other facilities in the course of business activities, including:
   a. facilitation of provision:

3. escrow account; and

4. virtual account or payment gateway;
   b. provision of financing risk analysis facilities submitted by Fund Recipients;
   c. provision of user identity verification and document authenticity facilities;
   d. provision of financing risk transfer facilities; e. provision of risk transfer facilities for collateral objects (if there are collateral objects); f. provision of complaint facilities; and g. provision of information regarding Financing for Users.

5. The management business activity as referred to in item 1 letter b is that the Organizer conducts user identity verification, processing of User data and other personal data in accordance with business operation activities, disbursement of funds from Fund Providers to Fund Recipients, payment of Financing from Fund Recipients to Fund Providers, and conducts collection from Fund Recipients.

6. The operation business activity as referred to in item 1 letter c is that the Organizer fully operates the Electronic System owned.

III. BUSINESS ACTIVITIES BASED ON SHARIA PRINCIPLES

1. Organizers based on Sharia Principles must fulfill Sharia Principles in carrying out business activities, including the use of contracts.

2. Fulfillment of Sharia Principles in the use of contracts as referred to in item 1 must be supported by:
   a. fatwas and/or Sharia compliance statements from institutions having authority in determining fatwas in the Sharia field that form the basis for the use of contracts; and b. opinions from the Organizer's DPS regarding the use of specific contracts for business activities based on Sharia Principles, after obtaining approval or confirmation from institutions having authority in determining fatwas in the Sharia field.

3. The Financial Services Authority provides approval, recording, or rejection of contracts used by Organizers based on Sharia Principles as referred to in item 2.

4. The DPS conducts analysis and evaluation of the fulfillment and application of Sharia Principles at least covering:
   a. financing disbursement activities; b. standard operating procedures;
   c. Sharia financing marketing practices; and
   d. accounting application.

5. Evaluation of the fulfillment and application of Sharia Principles as referred to in item 4 is conducted periodically every month in the form of written reports and reported to the Directors.

IV. FINANCING DISBURSEMENT AND REPAYMENT MECHANISM

1. Before prospective Users register with the Organizer, the Organizer displays matters that need to be considered on the Organizer's Electronic System, including:
   a. LPBBTI is the provision of financial services to match Fund Providers with Fund Recipients in conducting conventional financing or financing based on Sharia principles directly through Electronic Systems using the internet; b. LPBBTI business activities are subject to all relevant regulations concerning LPBBTI;
   c. The Organizer is an Indonesian legal entity that provides, manages, and operates LPBBTI, either conventionally or based on Sharia Principles;
   d. The Organizer is licensed and supervised by the Financial Services Authority; e. The Organizer may only access, obtain, store, manage, process, and/or use User Personal Data after obtaining User consent; f. The Organizer may only access the camera, location, and microphone on Users' devices; g. Users must understand the transaction and LPBBTI contract contents, including the upper limit of Financing facilities adjusted to Users' ability to transact; h. all Financing risks arising in LPBBTI transactions are borne entirely by Fund Providers. The Organizer is responsible in case of negligence or errors caused by the Organizer resulting in losses for Fund Providers;
   i. Users guarantee the authenticity of all submitted documents. For any document forgery or other criminal acts committed by Users, the Organizer may take legal action, including processing such matters to the relevant authorities;
   j. The Organizer does not charge any fees to Users for complaint services; k. The Organizer submits dispute resolution and collection procedures to Fund Providers and Fund Recipients in case of Financing default by Fund Recipients; and
   l. other matters that need to be considered regarding the characteristics of products owned by the Organizer.

2. In conducting Financing, the Organizer must ensure that Users understand the matters that need to be considered as referred to in item 1.

3. The mechanism for submitting requests for granting and receiving Financing is as follows:
   a. prospective Users must first be registered with the Organizer; b. prospective Users registered with the Organizer submit:

1. a request for granting Financing, if the User is a prospective Fund Provider; or
2. a request for receiving Financing, if the User is a prospective Fund Recipient,
   through the Organizer's Electronic System;
   c. The Organizer conducts analysis of the request for granting Financing as referred to in letter b item 1), including:
3. verification of the authenticity of submitted documents in accordance with the Organizer's standard operating procedures;
4. clarification and confirmation, whether through direct face-to-face, electronic face-to-face, and/or non-electronic face-to-face meetings with prospective Fund Providers as regulated in Financial Services Authority Regulations regarding the implementation of anti-money laundering, counter-terrorism financing, and counter-proliferation financing programs in the financial services sector; and
5. analysis of prospective Fund Providers;
   d. documents as referred to in letter c item 1) consist of at least:
6. individuals at least:
   a) identity card/driver's license/passport; b) tax identification number (if any); c) self-portrait photo; and d) account number;
7. business entities (including legal entities and international organizations) at least:
   a) identity card/driver's license/passport of the owner/director members; b) business registration number/company registration certificate/company business license/business decision letter/company domicile certificate letter or equivalents for international organizations; c) tax identification number, except for international organizations; d) documents for:
   (1) legal entities;
   (a) establishment deed;
   (b) latest amendment of articles of association; and (c) letters:
   i. approval or receipt of notification from the competent authority; or
   ii. ratification letter from the competent authority for individual corporate legal entities;
   (2) non-legal business entities:
   (a) establishment documents along with the latest amendments; and (b) documents showing registration or ratification of the business entity from the relevant authority; or (3) international organizations:
   (a) establishment documents; and
   (b) documents showing articles of association or equivalents; e. reports showing operational transactions and the latest profit and loss; and f. other supporting documents; e. analysis of prospective Fund Providers as referred to in letter c item 3) is identity analysis; f. identity analysis as referred to in letter e consists of at least:
8. type of Fund Provider;
   a) individual; or b) business entity (including legal entities and international organizations);
9. individual data;
   a) Fund Provider's name; b) identity card/driver's license/passport number; c) tax identification number (if any); d) telephone number; e) place of birth; f) date of birth; g) gender; h) occupation; i) income; j) source of income; and k) complete domicile address; and
10. business entity data (including legal entities and international organizations):
    a) business registration number or similar; b) tax identification number, except for international organizations; c) business field; d) telephone number; e) complete domicile address; f) income; and g) owner/director identity:
    (1) name;
    (2) identity card/driver's license/passport number; (3) tax identification number; (4) telephone number; and (5) complete domicile address; g. The Organizer conducts scoring assessment of the request for receiving Financing as referred to in letter b item 2), including:
11. verification of the truthfulness of submitted documents in accordance with the Organizer's standard operating procedures;
12. clarification and confirmation, whether through direct face-to-face, electronic face-to-face, and/or non-electronic face-to-face meetings with prospective Fund Recipients as regulated in Financial Services Authority Regulations regarding the implementation of anti-money laundering, counter-terrorism financing, and counter-proliferation financing programs in the financial services sector;
13. processing of data from other parties relevant to assessment needs (if necessary); and
14. analysis of prospective Fund Recipients;
    h. assessment as referred to in letter g considers the feasibility and ability of prospective Fund Recipients to fulfill Financing payment obligations, namely character and repayment capacity. Additionally, Organizers may consider other aspects such as capital, economic prospects, and/or collateral objects;
    i. assessment of repayment capacity as referred to in letter h for consumptive financing is conducted by reviewing the comparison between the principal payment amount and economic benefits paid by Fund Recipients with Fund Recipients' income, set at a maximum of:
15. 50% (fifty percent) in the first year after this Financial Services Authority Circular Letter is established;
16. 40% (forty percent) in the second year after this Financial Services Authority Circular Letter is established; and
17. 30% (thirty percent) in the third year after this Financial Services Authority Circular Letter is established.

The term Consumptive Financing refers to Multi-purpose Financing as referred to in Article 25 paragraph (1) letter b of Financial Services Authority Regulations concerning LPBBTI.

The term principal payment amount and economic benefits refers to the total amount of principal payments and economic benefits paid by Fund Recipients to all creditors, including Organizers, banks, financing companies, venture capital companies, leasing companies, and other financial service institutions.

Fund Recipients' income is known, among others, from the income amount declared by Fund Recipients to Fund Providers; j. The Organizer must ensure that Fund Recipients do not receive Financing through more than 3 (three) Organizers, including the Organizer in question; k. documents as referred to in letter g item 1) consist of at least:

1. individuals at least:
   a) identity card/driver's license/passport; b) tax identification number (if any); c) self-portrait photo; and d) account number (if required);
2. business entities (including legal entities) at least:
   a) identity card/driver's license/passport of the owner/director members; b) business registration number/company registration certificate/company business license/business decision letter/company domicile certificate letter; c) tax identification number; d) documents for:
   (1) legal entities:
   (a) establishment deed;
   (b) latest amendment of articles of association; and (c) letters:
   i. approval or receipt of notification from the competent authority; or
   ii. ratification letter from the competent authority for individual corporate legal entities;
   (2) non-legal business entities:
   (a) establishment documents along with the latest amendments; and (b) documents showing registration or ratification of the business entity from the relevant authority; e) reports showing operational transactions and the latest profit and loss; and f. other supporting documents;
   l. analysis of prospective Fund Recipients as referred to in letter g item 4) includes identity analysis as well as feasibility and ability; and
   m. identity analysis as referred to in letter l consists of at least:
3. Fund Recipient's name;
4. type of Fund Recipient;
   a) individual; or b) business entity (including legal entities);
5. individual data at least:
   a) identity card/driver's license/passport number; b) tax identification number (if required); c) telephone number; d) place of birth; e) date of birth; f) gender; g) highest education; h) occupation; i) income; j) source of income; and k) complete domicile address;
6. business entity data (including legal entities) at least:
   a) business registration number or similar; b) tax identification number; c) business field; d) telephone number; e) complete domicile address; f) business entity income; and g) owner/director identity:
   (1) name;
   (2) identity card/driver's license/passport number; (3) tax identification number; (4) telephone number; and (5) complete domicile address; and
7. emergency contact.

4. After the Organizer conducts analysis of prospective Fund Recipients, the Organizer determines the feasibility of prospective Fund Recipients and provides information to prospective Fund Recipients that:
   a. if prospective Fund Recipients are deemed feasible, the Organizer provides the assessment results along with the tenor and economic benefits of the submitted Financing; or b. if prospective Fund Recipients are deemed unfeasible, the Organizer provides the unfeasibility to prospective Fund Recipients, which may be accompanied by reasons for rejection.

5. Requests for receiving Financing as referred to in item 3 letter b item 2) and the assessment results of prospective Fund Recipients deemed feasible as referred to in item 4 letter a are displayed on the Organizer's Electronic System.

6. Financing activities implementation
   a. Prospective Fund Providers select prospective Fund Recipients on the Organizer's Electronic System. b. Prospective Users sign LPBBTI contracts using electronic signatures.
   c. Fund Providers disburse Financing through virtual accounts or payment gateways to be placed in the Organizer's escrow account and forwarded to Fund Recipients.
   d. The Organizer provides notifications of granting and receiving Financing to Users, including through Electronic Systems. e. In implementing Financing activities, Organizers must observe the following:

1. for consumer and public protection, every Organizer is not permitted to conduct unhealthy Financing;
2. Unhealthy Financing as referred to in item 1) is Financing that imposes unfair terms, conditions, economic benefits, and/or late penalties on Fund Recipients, which do not consider Fund Recipients' repayment capacity, or Financing received by Fund Recipients from more than 3 (three) Organizers;
3. examples of unhealthy Financing include:
   a) setting terms, economic benefit conditions, and/or late penalties containing elements of fraud; b) setting terms, economic benefit conditions, and/or late penalties that do not consider Fund Recipients' ability to repay Financing; or c) Financing to small and medium enterprises, micro financing, and/or other forms of Financing that impose unfair terms, economic benefit conditions, and/or late penalties.

7. In the context of installment payments and/or Financing repayment, Fund Recipients make payments through virtual accounts or payment gateways to be placed in the Organizer's escrow account and forwarded to Fund Providers.

8. Repayment of installments and/or Financing through collection by third parties is conducted in accordance with the manner as referred to in item 7.

V. USE OF OUTSOURCED WORKFORCE

1. Organizers may entrust part of the work execution to third parties through outsourcing agreements.

2. The form of outsourcing agreements as referred to in item 1 is conducted by Organizers through agreements:
   a. work contracting; and/or b. provision of workforce services.

3. Organizers are prohibited from outsourcing work that executes functions:
   a. Financing feasibility assessment; and/or b. Information Technology.

4. Work concerning Financing feasibility assessment as referred to in item 3 letter a is part of the Organizer's organizational structure that executes functions to conduct Financing feasibility assessments.

5. In executing functions as referred to in item 3 letter a, Organizers may cooperate with credit information management institutions to add reference data in conducting Financing feasibility assessments.

6. The nature of cooperation as referred to in item 5 is only related to the provision of Financing assessment data and is not related to the provision of final Financing feasibility assessments on the Organizer's Electronic System.

7. Work that cannot be transferred regarding Information Technology functions as referred to in item 3 letter b is work related to Information Technology development and Information Technology operations.

8. Work included in Information Technology operations as referred to in item 7 includes:
   a. user access management activities; b. database management activities;
   c. backup and restore activities;
   d. troubleshooting; and e. disaster recovery.

9. Organizers are prohibited from entrusting part of the work to third parties as referred to in item 1, except to third parties meeting the following requirements:
   a. third parties are legal entities in Indonesia; b. third parties are registered in associations of similar third-party companies;
   c. do not affect the Organizer's reputation; and
   d. implemented in accordance with labor regulations.

10. Organizers are responsible for the execution of activities entrusted to third parties.

VI. MAXIMUM ECONOMIC BENEFIT LIMITS

1. Organizers must fulfill maximum economic benefit limits for Financing in facilitating Financing.

2. Economic benefits charged by Organizers are interest rates, including:
   a. interest/margin/profit sharing; b. administrative fees/commission fees/platform fees/ujrah equivalent to such costs; and
   c. other costs, excluding late penalties, stamp duties, and taxes.

3. Maximum economic benefit limits as referred to in item 2 are established based on Financing types, namely:
   a. for productive financing, namely:

1. 0.1% (zero point one percent) per calendar day of the Financing value stated in the Financing contract, valid for 2 (two) years from January 1, 2024; and

2. 0.067% (zero point zero six seven percent) per calendar day of the Financing value stated in the Financing contract, valid from January 1, 2026; and
   b. for consumptive financing limited to short-term tenors less than 1 (one) year, namely:

3. 0.3% (zero point three percent) per calendar day of the Financing value stated in the Financing contract, valid for 1 (one) year from January 1, 2024;

4. 0.2% (zero point two percent) per calendar day of the Financing value stated in the Financing contract, valid for 1 (one) year from January 1, 2025; and

5. by 0.1% (zero point one percent) per calendar day
   from the value of Financing stated in the Financing Agreement, which shall apply since January 1, 2026.
   The following is a simulation of the maximum economic benefit calculation limit:

6. Productive Financing
   Financing Recipient A submits a Financing application to Organizer Z on January 5, 2024, with the following details:
   a) maximum economic benefit limit as per letter a number 1) is 0.1% (zero point one percent) per calendar day from the value of Financing stated in the Financing Agreement; b) Financing provided as per the Financing Agreement is Rp1,000,000.00 (one million rupiah); c) tenor is 90 (ninety) calendar days; d) interest/margin/profit share is Rp30,000.00 (thirty thousand rupiah); e) administrative costs/commission fees/platform fees/ujrah are Rp50,000.00 (fifty thousand rupiah); f) other costs are Rp5,000.00 (five thousand rupiah); g) total economic benefit = Rp30,000.00 (thirty thousand rupiah) + Rp50,000.00 (fifty thousand rupiah) + Rp5,000.00 (five thousand rupiah) = Rp85,000.00 (eighty-five thousand rupiah); h) percentage of economic benefit = total economic benefit / (Financing provided as per the Financing Agreement x tenor) = Rp85,000.00 (eighty-five thousand rupiah) / [Rp1,000,000.00 (one million rupiah) x 90 (ninety)] = 0.0944% (zero point zero nine four four percent). Based on the calculation above, the economic benefit amount of 0.0944% (zero point zero nine four four percent) meets the maximum economic benefit limit that can be provided, which is 0.1% (zero point one percent) per calendar day from the value of Financing stated in the Financing Agreement.

7. Consumer Financing
   Financing Recipient B submits a Financing application to Organizer Y on February 10, 2024, with the following details:
   a) maximum economic benefit limit as per letter b number 1) is 0.3% (zero point three percent) per calendar day from the value of Financing stated in the Financing Agreement; b) Financing provided as per the Financing Agreement is Rp1,000,000.00 (one million rupiah); c) tenor is 30 (thirty) calendar days; d) interest/margin/profit share is Rp40,000.00 (forty thousand rupiah); e) administrative costs/commission fees/platform fees/ujrah are Rp45,000.00 (forty-five thousand rupiah); f) other costs are Rp5,000.00 (five thousand rupiah); g) total economic benefit = Rp40,000.00 (forty thousand rupiah) + Rp45,000.00 (forty-five thousand rupiah) +

Rp5,000.00 (five thousand rupiah) = Rp90,000.00 (ninety thousand rupiah); h) percentage of economic benefit = total economic benefit / (Financing provided as per the Financing Agreement x tenor) = Rp90,000.00 (ninety thousand rupiah) / [Rp1,000,000.00 (one million rupiah) x 30 (thirty)] = 0.3% (zero point three percent). Based on the calculation above, the economic benefit amount of 0.3% (zero point three percent) meets the maximum economic benefit limit that can be provided, which is 0.3% per calendar day from the value of Financing stated in the Financing Agreement.
4. The maximum late penalty limit as referred to in number 2 letter c is determined based on the type of Financing, namely:
a. for Productive Financing, namely:

1. by 0.1% (zero point one percent) per calendar day from the outstanding balance of Financing, which shall apply for 2
   two years since January 1, 2024; and
2. by 0.067% (zero point zero six seven percent) per calendar day from the outstanding balance of Financing, which shall apply
   since January 1, 2026; and b. Consumer Financing conducted in installments, namely:
3. by 0.3% (zero point three percent) per calendar day from the outstanding balance of Financing, which shall apply for 1 (one)
   year since January 1, 2024;
4. by 0.2% (zero point two percent) per calendar day from the outstanding balance of Financing, which shall apply for 1 (one)
   year since January 1, 2025; and
5. by 0.1% (zero point one percent) per calendar day
   from the outstanding balance of Financing, which shall apply since January 1, 2026.

5. All economic benefits and late penalties that can be imposed on Users must not exceed 100% (one hundred percent)
   of the value of Financing stated in the Financing Agreement.
6. The determination of the maximum economic benefit and late penalty limits as referred to in number 3 and number 4
   can be evaluated periodically in accordance with policies established by the Financial Services Authority (OJK) by considering among other things economic conditions and the development of the LPBBTI industry.
   VII. RISK MITIGATION FACILITIES FOR USERS
7. Activities facilitating risk mitigation for Users must at least:
   a. conduct risk analysis of Financing submitted by Financing Recipients; b. verify User identity and document authenticity;
   c. conduct optimal debt collection for disbursed Financing;
   d. facilitate Financing risk transfer; and

e. facilitate risk transfer over collateral objects, if there are collateral objects.
2. Financing risk analysis as referred to in number 1 letter a:
a. is conducted when the Financing Recipient submits a Financing application by processing data received when the Financing Recipient submits registration and/or based on other data owned by the Organizer; and b. is used to assess the feasibility of the Financing Recipient to fulfill Financing obligations.
3. User identity verification and document authenticity as referred to in number 1 letter b is conducted on information and
documents submitted to the Organizer and/or based on other data owned by the Organizer.
4. In conducting Financing risk analysis as referred to in number 2 and User identity verification
as referred to in number 3, the Organizer may utilize data from:
a. information management service providers that are registered or licensed by the relevant authority; b. government agencies or state-owned enterprises or local government-owned enterprises; and/or
c. other institutions that are registered or licensed by the relevant authority.
5. Data utilization as referred to in number 4 is carried out by complying with statutory regulations regarding
Personal Data Protection.
6. Financing risk transfer as referred to in number 1 letter d can be conducted through insurance or guarantee mechanisms.
7. In conducting Financing risk transfer as referred to in number 6, the Organizer may cooperate with
insurance companies or guarantee companies that have business licenses from the Financial Services Authority (OJK) in accordance with statutory regulations.
8. In cooperating with insurance companies or guarantee companies:
a. cooperation is conducted with at least 2 (two) insurance companies or guarantee companies; and b. the Organizer only acts as a facility provider for cooperation among Fund Providers.
9. Cooperation as referred to in number 7 is stipulated in a written agreement.
10. The written agreement as referred to in number 9 must use the Indonesian language or Indonesian language
alongside a foreign language.
11. The use of insurance or guarantee as referred to in number 6 is an agreement between the Fund Provider
and the insurance company or guarantee company.

12. In using insurance or guarantee as referred to in number 11, the Fund Provider acts as the insured or guarantee recipient.
13. In the event of claim payment, the insurance company or guarantee company directly pays the claim to the
    Fund Provider and/or beneficiary.
14. In the event that claim payment has been paid by the insurance company or guarantee company as referred to
    in number 13, the Organizer must ensure that claim payment information is communicated to the Fund Provider.
15. In the context of risk transfer over collateral objects as referred to in number 1 letter e, the Organizer may:
    a. insure the collateral object; and/or b. cooperate with other parties that have the authority to accept or store collateral objects in accordance with statutory regulations.
    VIII. DATA AND INFORMATION MANAGEMENT
16. Organizers, in conducting business activities, may only access the camera, location, and microphone on devices owned by Users.
17. Organizers are not permitted to disseminate all personal data and information of Users to other parties.
18. Provisions as referred to in number 2 are excepted in the event:
    a. there is written consent from the User; and/or b. there are exceptions by statutory regulations.
19. In the event the User provides written consent as referred to in number 2 letter a, the Organizer may provide
    personal data and/or information of the User and ensure that the other party does not provide and/or use personal data and/or information of the User for purposes other than those agreed upon between the Organizer and the other party.
20. The Organizer ensures that Users know the purpose of data and information usage and the risks attached to written consent or recorded consent provided by the User.
21. Written consent from the User as referred to in number 5 is expressed in the form of a statement
    and consent and is documented by the Organizer.
22. Data and information as referred to in number 2 must be secured through methods that can ensure the process
    of reading data and information is conducted by authorized parties.
23. User data and information obtained and utilized by the Organizer must meet the following criteria:
    a. communication of data and information usage limits to the User; b. communication of any changes in the purpose of data and information usage to the User, if any; and

c. the media and methods used in obtaining and utilizing data and information are guaranteed to be confidential,
secure, and intact.
9. User data and information destroyed by the Organizer must meet the following criteria:
a. meet retention aspects based on statutory regulations and audit interests as well as examination by sector supervisory and regulatory authorities; and b. ensure that no data and information remain and can be utilized again.
10. The Organizer must prevent unauthorized access to data and information.
11. The Organizer must maintain the confidentiality, security, integrity, and availability of:
a. personal data and information; b. transaction data; and
c. financial data,
which it manages from the time the data is obtained until the data is destroyed.
IX. FINANCING QUALITY LEVEL

1. The Organizer conducts Financing quality assessment.
2. Financing quality as referred to in number 1 consists of:
   a. current; b. special attention;
   c. less current;
   d. doubtful; and e. non-performing.
3. Financing quality as referred to in number 1 is categorized as follows:
   a. current if there is no delay in principal and/or economic benefit payment of Financing; b. special attention if there is a delay in principal and/or economic benefit payment of Financing that has exceeded the due date up to 30 (thirty) calendar days;
   c. less current if there is a delay in principal and/or economic benefit payment of Financing that has
   exceeded the due date 30 (thirty) calendar days up to 60 (sixty) calendar days; d. doubtful if there is a delay in principal and/or economic benefit payment of Financing that has exceeded the due date 60 (sixty) calendar days up to 90 (ninety) calendar days; and e. non-performing if there is a delay in principal and/or economic benefit payment of Financing that has exceeded the due date 90 (ninety) calendar days.

X. PUBLICATION OF FINANCING PERFORMANCE

1. The Organizer must publish Financing performance on the main page of the website, application, and/or Electronic System
   owned by the Organizer, containing information at least:
   a. the value of disbursed Financing; b. the number of Fund Providers;
   c. the number of Financing Recipients; and
   d. the repayment success rate.
2. Information as referred to in number 1 letter a to letter c is communicated:
   a. since commencing business activities; b. in the current year; and
   c. as of the final position.
3. Publication of the repayment success rate (TKB) as referred to in number 1 letter d is conducted by displaying all
   repayment success rates for Financing facilitated by the Organizer based on the LPBBTI Financing quality level.
4. TKB as referred to in number 3 is displayed with the following details:
   a. written using the format:

1. TKB0 = xx.xx%;
2. TKB30 = xx.xx%;
3. TKB60 = xx.xx%; and
4. TKB90 = xx.xx%,
   including an explanation regarding TKB as follows:
   a) TKB0 is a measure of the Organizer's success rate in facilitating the settlement of Financing obligations within a period up to 0 (zero) calendar days counted from the due date; b) TKB30 is a measure of the Organizer's success rate in facilitating the settlement of Financing obligations within a period up to 30 (thirty) calendar days counted from the due date; c) TKB60 is a measure of the Organizer's success rate in facilitating the settlement of Financing obligations within a period up to 60 (sixty) calendar days counted from the due date; and d) TKB90 is a measure of the Organizer's success rate in facilitating the settlement of Financing obligations within a period up to 90 (ninety) calendar days counted from the due date; b. placed on the main screen in the upper right section of all Organizer websites, applications, and/or Electronic Systems; and
   c. placed in a position that is easily visible and clearly readable.

5. The calculation used to determine TKB is as follows:
   a. TKB 0 = 100% − TWP 0
   TWP 0 =
   Final position of defaulters above 0 calendar days Total final position X 100 % b. TKB 30 = 100% − TWP 30 TWP 30 = Final position of defaulters above 30 calendar days Total final position X 100 %

c. TKB 60 = 100% − TWP 60
TWP 60 =
Final position of defaulters above 60 calendar days Total final position X 100 % d. TKB 90 = 100% − TWP 90 TWP 90 = Final position of defaulters above 90 calendar days Total final position X 100 %
6. TKB as referred to in number 5 can be improved in the event:
a. the Financing Recipient has made full payment for all Financing received and for payment obligations arising from such Financing; b. the Fund Provider has received payment from the insurance company or guarantee company for claim liabilities and/or collateral submitted; and
c. the Fund Provider has written off and forgiven the Financing provided.
7. Financing performance information is updated at least 1 (one) time per week.
XI. DEBT COLLECTION

1. The Organizer must conduct debt collection independently or by appointing another party to conduct debt collection.
2. The Organizer must provide information regarding Financing due dates to Financing Recipients to make payments
   periodically before Financing matures and becomes collectible.
3. In the event the Financing Recipient defaults, the Organizer must conduct debt collection at least by providing a
   warning letter after the Financing period has expired and after the due date as per the Financing Agreement between the Fund Provider and the Financing Recipient.
4. Debt collection can be conducted by:
   a. desk collection, which is indirect debt collection including via message media, phone calls, video calls, and other intermediaries; and/or b. field collection, which is direct face-to-face debt collection.
5. In conducting Debt Collection as referred to in number 4, the Organizer must ensure that:
   a. collection personnel have received adequate training regarding collection tasks and collection ethics in accordance with applicable regulations; b. in the event the Organizer conducts collection cooperation with another party to the Financing Recipient, the other party must have human resources that have obtained certification in the field of collection from a professional certification institution registered with the Financial Services Authority (OJK).
   c. the identity of each collection personnel is well accounted for by the Organizer;
   d. collection personnel, in conducting debt collection, comply with the following collection ethics:

1. using official identity cards issued by other parties cooperating with the Organizer, which are
   accompanied by a photo of the respective person;

2. debt collection is not permitted to be conducted using threats, violence, and/or
   tacts that humiliate the Financing Recipient;

3. debt collection is not permitted to be conducted using
   physical or verbal pressure;

4. conducted by avoiding the use of words and/or actions that intimidate and
   demean ethnicity, religion, race, and inter-group relations (SARA), dignity, honor, and self-esteem, in the physical world as well as in the cyber world (cyber bullying) towards the Financing Recipient, the Financing Recipient's emergency contact, relatives, friends, family, and assets;

5. debt collection is not permitted to be conducted towards parties other than the Financing Recipient;

6. debt collection using communication media
   is not permitted to be conducted continuously in a manner that is disruptive;

7. debt collection can only be conducted through personal channels, at the collection address, or the domicile of the Financing Recipient;

8. debt collection can only be conducted between 08.00
   and 20.00 hours in the time zone of the Financing Recipient's address; and

9. debt collection outside the location and/or time as referred to in number 7) and number 8) can only be conducted
   based on prior consent and/or agreement with the Financing Recipient; and e. other parties providing debt collection services cooperating with the Organizer also comply with the collection ethics established by the Organizer association.

6. Debt collection by appointing another party as referred to in number 1 is conducted in the form of a written agreement and
   evaluated periodically.
7. The debt collection agreement with another party as referred to in number 6 must at least cover:
   a. scope of work; b. agreement term;
   c. contract value;
   d. cost structure and payment mechanism; e. rights, obligations, and responsibilities of the Organizer and/or the other party, including:

1. the Organizer's authority to evaluate and examine the other party regarding debt collection conducted;

2. the obligation of the other party, including labor used, to maintain the confidentiality and security of the Organizer's and/or User's information;

3. the obligation of the other party to submit reports and information to the Organizer in writing and periodically;

4. the obligation of each party to comply with statutory regulations;

5. the obligation of the parties to protect User rights and interests related to the debt collection conducted;

6. the obligation of the other party to have a contingency plan; and

7. the willingness of the other party to provide examination access to the Financial Services Authority (OJK) and/or other competent authorities together with
   the Organizer when necessary; f. size and standards of work implementation; g. criteria or conditions for terminating the agreement before the end of the agreement term (early termination); h. sanctions and penalties; and
   i. dispute resolution.

8. The Organizer is fully responsible for all impacts arising from cooperation with other parties as referred to in number 1.
   XII. EMERGENCY CONTACT USAGE CONFIRMATION
9. The use of emergency contacts is only intended to confirm the whereabouts of the Financing Recipient and is not
   used to conduct debt collection for Financing to the owner of the emergency contact data.
10. The Organizer must conduct confirmation and obtain consent from the owner of the emergency contact data for the use of emergency contacts.
11. Confirmation as referred to in number 2 is conducted by explaining:
    a. confirming the emergency contact data submitted by the Financing Recipient; b. confirming the relationship between the owner of the emergency contact data and the Financing Recipient who submitted the emergency contact;
    c. explaining what is meant by emergency contact to the owner of the emergency contact data; and
    d. explaining the risks that will be attached when agreeing to become an emergency contact.
12. The Organizer documents the confirmation and consent provided by the owner of the emergency contact data.
    XIII. REPORTING ON THE SETTLEMENT OF RIGHTS AND OBLIGATIONS
13. The Organizer prepares a report on the settlement of rights and obligations in the event:
    a. the Organizer converts from a conventional Organizer to a Sharia Principle-based Organizer; b. the Organizer cannot continue its operational activities; or
    c. the Organizer is declared bankrupt.
14. The settlement of rights and obligations of the Organizer conducting conversion as referred to in number 1 letter a is conducted
    with User consent, in the event the User does not agree then:
    a. the Organizer's rights and obligations to Users remain settled; or b. the portfolio is transferred to an Organizer with a similar business organization principle.

This copy is consistent with the original
Legal Director 1
Legal Department signed
Mufli Asmawidjaja
3. The settlement of the Organizer's rights and obligations to Users is conducted by:
a. the final position of total transfer of Financing that has not been paid off; and/or b. other mechanisms agreed upon by the User.
4. Other mechanisms agreed upon by the User as referred to in number 3 letter b can be conducted by
the Organizer bringing together the Fund Provider and the Financing Recipient who then both parties can agree on the settlement of the Financing Agreement.
5. The settlement of the Organizer's rights and obligations to Users as referred to in number 3 is written in the LPBBTI Agreement.
6. The report on the settlement of rights and obligations as referred to in number 1 is conducted by referring to regulations regarding
licensing applications, approval applications, and electronic reporting for Organizers.
XIV. TRANSITIONAL PROVISIONS

1. Financing Agreements signed before this Financial Services Authority Circular takes effect are declared to remain valid until the end of the Financing Agreement.
2. In the event that Financing Agreements signed before this Financial Services Authority Circular takes effect
   require changes after the Circular takes effect, changes to such Financing Agreements must comply with the provisions in this Financial Services Authority Circular.
   XV. CLOSING
   Provisions in this Financial Services Authority Circular shall take effect on the date of establishment.
   Established in Jakarta on November 8, 2023
   EXECUTIVE HEAD OF SUPERVISOR FOR PAYMENT INSTITUTIONS, VENTURE CAPITAL COMPANIES, MICRO FINANCE INSTITUTIONS, AND OTHER FINANCIAL SERVICE INSTITUTIONS FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA, AGUSMAN signed