In 2024, the Financial Services Authority (Otoritas Jasa Keuangan – “OJK”) established a framework for the organization of Information Technology-Based Joint Funding Services (Layanan Pendanaan Bersama Berbasis Teknologi Informasi/LPBBTI), which are commonly known as the Peer-to-Peer (“P2P”) lending services, through the issuance of Regulation No. 40 of 2024 (“Regulation 40/2024”).[1] Among the various provisions set out therein, Regulation 40/2024 requires organizers of said P2P lending services (“Organizers”) to comply with certain soundness level requirements, ultimately achieving a minimum composite rating of 3 (i.e. fairly sound, indicating ability to withstand significant adverse changes in business conditions and other external factors).[2] These composite ratings are determined based on a comprehensive and structured analysis of the following factors:[3]
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