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ASOSIASI FINTECH PENDANAAN BERSAMA INDONESIA (AFPI) & the Supervision Peer-to-Peer Lending Companies In Indonesia

Indonesia’s peer-to-peer lending industry is experiencing massive growth. To help regulate institutions in the space, on October 5th, 2018, the Indonesian Financial Services Authority (OJK) established Asosiasi Fintech Pendanaan Bersama Indonesia (AFPI), the country’s official association for peer-to-peer lending businesses.

OJK inaugurated the association through Letter No. S-5/D.05/2019 dated March 8th, 2019, and now requires every peer-to-peer lending company to be registered as a member prior to obtaining a registration certificate from OJK itself. With a membership of 106 companies as of April 5th, 2019, the AFPI has been assigned by OJK to define and implement standards and certifications for its members.

To support its duties and functions as a platform for peer-to-peer lending business actors, AFPI recently issued a Code of Conduct regarding IT-Based Money Lending Services (“Code of Conduct”).

This Code of Conduct may affect the operations of peer-to-peer lending companies that have just started their business. Among other terms, the Code of Conduct prohibits peer-to-peer lending providers from the following: stipulating a total loan fee amount that exceeds flat interest rates of 0.8% (zero point eight percent) per day,1stipulating a total fee amount (including overdue fee and other fees) that exceeds the principal loan amount, 2 and making direct collections from default borrowers who are 90 (ninety) days overdue from the maturity date.3 Additionally, peer-to-peer lending providers are required to maintain the confidentiality of its user’s data – they are only permitted to access the camera, microphone, and location of its users.

In order to be more effective its supervisory role, AFPI established an ethics council within the association. Through this council, AFPI has issued another regulatory instrument: an AFPI Regulation regarding Work Procedure of Ethics Council and Procedure for Examining and Imposing Sanctions on Violations of the Code of Conduct (“AFPI Regulation”). The ethics council is authorized to receive, examine, and adjudicate complaints related to peer-to-peer lending business filed by various providers, association management, and users or members of the public.

As a law firm which is familiar and expert in financial technology industry, Schinder focuses on the growth and development of P2P industry. We continuously keep our fintech clients updated with Indonesian laws and regulations in banking and financial services sector. Schinder can assist you to develop your fintech business Indonesia.

1 Part III letter B number 1) letter d) of Code of Conducts. 2Part III letter B number 1) letter e) of Code of Conducts. 3Part III letter C number 3) letter d) of Code of Conducts. 4Article 1 paragraph (2) of AFPI Regulation.

About the author:



Marsha graduated with cum laude predicate from Universitas Tarumanagara 2018 majoring in business law. During her study, she joined various committee, seminars, and workshops. She was the participant of Student Exchange Program at Malaya University.

Prior to joining Schinder Law Firm, Marsha worked at another prominent law firms in Jakarta, which emphasis in foreign direct investment, energy, financial technology, e-commerce, and various general corporate matters ranging from general to complex. In addition, she has been involved in a complex merger and acquisitions transactions.

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