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Legal Brief
Towards National Financial Inclusion and
Credit Growth: Regulatory Framework of
the Credit Bureau Agency
A H R P L e g a l B r i e f
Purpose of LPIP Establishment
To encourage the growth of credit and national financial inclusion,
support from credit information management institutions is needed to
produce diverse, comprehensive credit information with added value.
Therefore, it is necessary to manage and develop credit
information by expanding the scope of credit or financing data
and other data from both financial and non-financial institutions.
The establishment of LPIP aims to manage and develop credit
information effectively, enabling sustainable business operations
through institutional structuring, good governance implementation,
strengthening stakeholder protection, enhancing compliance with
regulations, and upholding universally applicable ethical values in
operational activities.
History of LPIP Regulation
Credit Bureau Agency (Lembaga Pengelola Informasi
Perkreditan or “LPIP”) is the credit rating agency that gathers and
processes credit or financing data and other data to produce
credit information.
Art. 1 (1) OJK Reg. 5/2022
LPIP in Indonesia
There are three LPIP licensed by the Financial Services Authority
(Otoritas Jasa Keuangan or “OJK”), as follows:
a. Collecting and processing Credit or Financing Data and/or Other
Data;
b. Providing rating services for Debtors or Customers based on
Credit or Financing Data and/or Other Data; and
c. Generating Credit Information that possesses added value
based on Credit or Financing Data and/or Other Data and which
encompasses the following: credit scores, fraud rankings, profile
mapping of debtors and customers, and the monitoring and
evaluation of debtors and customers.
Business Activities of LPIP
If LPIP undertake any activities other than those outlined above,
then they will be subject to the imposition of administrative
sanctions in the form of written reprimands.
Art. 2 (1) OJK Reg. 5/2022
Principles of Governance
LPIP is required to implement good governance in all of its
business activities at all levels or organizational levels, which must
at least be manifested in the following forms:
a. Implementation of the duties and responsibilities of the board of
directors;
b. Implementation of the duties and responsibilities of the board of
commissioners;
c. Handling conflicts of interest;
d. Implementation of risk management, compliance, internal audit,
external audit functions, and operational guidelines related to
cooperation with LPIP members;
e. Annual business plan of LPIP; and
f. Transparency of financial and non-financial conditions through
publication.
Art. 8 (1) and (2) OJK Reg. 5/2022
Art. 2 (2) and (3) OJK Reg. 5/2022
LPIP is required to submit a governance implementation report
as part of its annual report. Further provisions regarding the
implementation of governance and the scope of the governance
implementation report shall be determined by OJK.
Art. 8 (3) and (4) OJK Reg. 5/2022
Central Bank of Indonesia
Regulation Number
15/1/PBI/2013
(“BI Reg. 15/2013”)
OJK Regulation Number 42/POJK.03/2019 OJK Regulation Number 5/POJK.03/2022
This regulation is a conversion of BI Reg.
15/2013 which adjusts several provisions such
as (i) changing phrases, terminology, and article
constructions; (ii) adjusting definitions; (iii)
aligning dual positions for members of board of
directors and/or members of the board of
commissioners; and (iv) adjusting the
mechanism for revoking LPIP business
licenses.
This regulation revokes OJK Reg. 42/2019 as a
form of adjustment to current conditions, as
needed for significant improvements. This OJK
Regulation is established as an effort to
enhance overall credit growth.
PT Kredit Biro
Indonesia
PT PEFINDO Biro
Kredit
PT CRIF Lembaga Informasi
Keuangan
a
b
c
d
e
f
a
b
c
BACKGROUND
The paid-up capital for establishing LPIP is determined to be at least Rp50.000.000.000,00 (fifty billion Indonesian rupiah).
The funding source for the ownership of LPIP must not originate from:
a. Loans or financing facilities from banks and/or other parties; and/or
b. Money laundering.
Furthermore, LPIP is required to allocate a portion of the company's profits for the enhancement of technology, infrastructure, and human
resources.
The Provision of Minimum Paid-up Capital
Previous Provisions on Minimum Paid-up Capital of LPIP
The Provisions of Credit Information
The paid-up capital for establishing LPIP is determined to be at least Rp200.000.000.000,00 (two hundred billion Indonesian rupiah).
The funding source for the ownership of LPIP must not originate from:
a. Loans or financing facilities from banks and/or other parties; and/or
b. The proceeds of crime and for the purposes of money laundering, terrorism financing, as well as the financing of the proliferation
of weapons of mass destruction.
The funding source for increasing the paid-up capital of LPIP may consist of cash or other assets that can be utilized as supporting
infrastructure for LPIP.
Art. 5 OJK Reg. 5/2022
Art. 6 OJK Reg. 42/2019
Current Provisions on Minimum Paid-up Capital of LPIP
LPIP is obligated to generate credit information derived from the collection and/or processing of credit or financing data and/or other data by
LPIP, excluding standard information. There are several provisions concerning changes in credit information between OJK Reg. 42/2019 and
OJK Reg. 5/2022, as follows:
No. Credit Information OJK Reg. 42/2019 OJK Reg. 5/2022
1. End data owner's identity n/a required
2. Identity of the manager of the end data owner in the form of a business entity n/a required
3. Financial profile of the end data owner n/a required
4. Funding provision facilities required optional
5. Collateral and/or guarantor required optional
6. Creditor's identity required optional
7. Records of borrower information users required optional
8. Financial report required n/a
9. Information on ongoing complaints related to borrower information required optional
Credit Information Comparison between OJK Reg. 42/2019
and OJK Reg. 5/2022
Art. 61 OJK Reg. 5/2022 jo. Art. 48 OJK Reg. 42/2019
KEY CHANGES IN OJK REG. 5/2022
A H R P L e g a l B r i e f
Each party who wants to conduct LPIP must establish a Limited
Liability Company or Perseroan Terbatas.
Form of Business Entity
Art. 4 (1) OJK Reg. 5/2022
The minimum paid-up capital to establish LPIP is set at
Rp200.000.000.000,00 (two hundred billion Rupiah).
Art. 5 (1) OJK Reg. 5/2022
Governance Implementation
a) LPIP shall implement good governance in all its business
activities at all levels or stage of organization.
b) The implementation of good governance as referred to in
paragraph a) must at least be manifested in the form of:
1) implementation of the duties and responsibilities of the
board of directors;
2) implementation of duties and responsibilities of the board
of commissioners;
3) handling conflict of interest;
4) risk management, compliance, internal audit, external
audit functions, and operational guidelines
implementation which relate to cooperation with LPIP
members;
5) annual business plan of LPIP; and
6) transparency of financial and non-financial conditions via
publications.
c) LPIP shall submit a governance implementation report as part
of the annual report.
d) Further provisions regarding the implementation of
governance as referred to in paragraph b) and the scope of
governance implementation reports as referred to in paragraph
c) are determined by the OJK.
Fit and Proper Test for Key Persons
Art. 8 OJK Reg. 5/2022
a) The prospective of key persons shall obtain from OJK before
carrying out actions, duties, and functions as Key Person.
b) Key Person as referred to in paragraph a) consist of:
1) Controlling key person; and
2) Managing key person.
c) To grant approval as key persons, the OJK assesses the
capabilities and suitability of prospective main parties.
d) The assessment of capabilities and suitability is conducted to
ascertain that prospective key persons as referred to in
paragraph b) fulfil the following requirements:
1) integrity and financial eligibility for prospective
Controlling Key Person; and
2) integrity, financial reputation, and competence for
prospective Managing Key Person.
e) Further provisions regarding the procedures for assessing
capabilities and suitability as referred to in paragraph c) and
d) are determined by the OJK.
Art. 9 OJK Reg. 5/2022
a) LPIP’s shareholders must be in the form of legal entity.
b) Business entity as referred to in paragraph a) must in
accordance with the prevailing laws and regulations.
.
c) Legal entity as referred to in paragraph a) owns by:
1) Indonesian legal entity; or
2) Indonesian legal entity that cooperates with foreign legal
entity.
d) In the event that legal entity holding shares of LPIP is a Public
Limited Liability Company and trading its shares on the public
exchange, provisions as referred to in paragraph c) do not
apply.
e) Foreign legal must have minimum of 3 (three) years of
experience in the credit information management industry.
a) The maximum shares ownership of LPIP by each
shareholders is 51% (fifty one percent) from paid-up capital.
b) The maximum limit on share ownership also applies to
ownership based on relationship between shareholders.
c) In the event a shareholders of LPIP also holds shares in
another LPIP, the maximum total share ownership in all LPIP
is 51% (fifty one percent).
d) In the event legal entity holding LPIP shares is partially
owned by foreign parties, the following provisions apply:
1) total ownership by 1 (one) or more foreign parties in 1
(one) LPIP is limited to a maximum of 20% (twenty
percent); and
2) total ownership by 1 (one) foreign party in more than 1
(one) LPIP is limited to a maximum of 20% (twenty
percent).
e) Further provisions regarding LPIP ownership shall be
determined by OJK.
Art. 14 OJK Reg. 5/2022 Art. 15 OJK Reg. 5/2022
Shareholding Provisions
INSTITUTIONAL ASPECTS OF LPIP (1/2)
Capital Requirement
A H R P L e g a l B r i e f
a) LPIP shall have a board of directors consisting of at least 3 (three) members.
b) The member of board of directors as referred to in paragraph a) shall at least 50% (fifty-percent) be Indonesian citizens.
c) At least 1 (one) member of the board of directors as referred to in paragraph a) must have knowledge and/or experience in the credit
information management industry.
d) Members of the board of directors may only hold positions as directors, members of the board of commissioners, or executive officers of
non-profit companies, organizations, or institutions.
Art. 16 OJK Reg. 5/2022
Art. 17 OJK Reg. 5/2022
a) LPIP shall have a board of commissioners with a minimum of 2 (two) members and a maximum equal to the number of members in the
board of the directors.
b) The member of board of directors as referred to in paragraph a ) shall at least 50% (fifty-percent) be Indonesian citizens.
a) LPIP may utilize foreign workers for positions, such as
members of the board of directors, members of the board of
commissioners, executive officers, experts, or consultants.
b) Foreign workers as referred to in paragraph a) must fulfill the
following requirements:
1) fulfill the expertise qualification;
2) do not hold positions in Financial Institution domiciled in
Indonesia and/or outside territory of Indonesia; and
3) possess knowledge of the Indonesian economy,
language, and Indonesian’s culture.
c) Prohibition to utilize foreign workers in the following areas of
responsibility:
1) managing human resources; and
2) the implementation of compliance.
d) The utilization of foreign workers shall obtain approval from
OJK.
Art. 19 OJK Reg. 5/2022
a) In utilizing foreign workers as executive officers, experts,
or consultant, LPIP must conduct of the following:
1) before using foreign workers to such position above,
shall consider the availability of local experts or
consultant for the required fields and expertise;
2) provide 2 (two) local assistant for each foreign
workers; and
3) observe the provisions of labor laws and regulations.
b) Foreign workers serving as members of the board of
directors and/or board of commissioners, in addition to
meeting the requirements, foreign workers are subject to
the requirements and provisions applicable to members of
the board directors and/or board of commissioners under
OJK Reg 5/2021.
Art. 20 OJK Reg. 5/2022
a) LPIP that fails to comply with the provisions on (i) director; (ii) commissioner; (iii) utilization of foreign workers shall be subjected to
administrative sanctions in the form of written warnings.
b) If LPIP has been imposed to administrative sanctions in the form of written warning and has not yet complied with the provision on: (i)
director; (ii) commissioner; (iii) utilization of foreign workers, may also be subjected to administrative sanctions in the form of:
1) temporary suspension of certain business activities;
2) suspension of the provision of Credit or Financing Data from the OJK; and/or
3) inclusion of management in the list of parties prohibited from becoming Key Persons.
Art. 22 OJK Reg. 5/2022
INSTITUTIONAL ASPECTS OF LPIP (2/2)
Provisions on Directors
Provisions on Commissioners
Administrative Sanction
Provisions on Utilization of Foreign Workers
A H R P L e g a l B r i e f
In order to conduct the business activities, LPIP requires to obtain the following licenses:
Principal Approval
o Principal approval shall remain valid
for a period of 12 months from the
issuance
o Principal approval serves as a
prerequisite for obtaining business
licensing
o Principal approval may not be
transferred to other parties.
Business Licensing
The first-time implementation of business
activities must be reported to OJK by the
director of LPIP within a maximum of 10 working
days after the date of implementation of the
business activities
Application for a
principal approval is
accompanied by
administrative
documents to OJK
Administrative
examination by OJK on
the administrative
documents
Submission of
additional documents
(if needed)
OJK conducts technical
examination of the
submitted application
after completed
Presentation from
applicants to OJK on
the plan and
development strategic
of LPIP
Principal Approval
Business Licensing
Announcement from
OJK either approval or
rejection from the
application
The request from OJK for additional
documents must be submitted within 20
working days after the announcement
Art. 23 b OJK Reg. 5/2022
Art. 28 – Art. 30 OJK Reg. 5/2022
1
2
3
4
5
6
* at the latest 60 working days
from the date of receipt of the
complete application documents.
* at the latest 40 working days
from the date of receipt of the
complete application documents
and supporting infrastructure is
available to supporting the
operational of LPIP.
Art. 24 – Art. 27 OJK Reg. 5/2022
Art. 23 a OJK Reg. 5/2022
PROCEDURE TO OBTAIN PRINCIPAL
APPROVAL AND BUSSINESS LICENSE OF LPIP
A H R P L e g a l B r i e f
Application for a
business license is
accompanied by
administrative
documents to OJK
OJK conducts technical
examination of the
submitted application
after the documents
are complete
Announcement from
OJK either approval or
rejection from the
application
The applicant shall
commence business
activities within a
maximum of 20 working
days from the date the
business license is issued
1 2 3 4
Additional paid-up capital in LPIP must obtain approval from OJK by fulfill the following requirements:
a. Must comply with the provisions regarding the limitation of share ownership as referred to in Article 15 OJK Reg 5/2022; and
b. Must be submitted in writing, accompanied by a letter of statement from LPIP shareholders that the increase in paid-up capital:
1) Does not originate from loans or financing facilities from banks and/or other parties; and
2) Does not originate from proceeds of criminal activities and for the purposes of money laundering, terrorism financing, or funding proliferation
of weapons of mass destruction.
Approval or rejection of the application shall be granted by OJK later than 30 (thirty) working days after the complete submission of the application
documents.
Art. 32 OJK Reg. 5/2022
Changes in Shareholders Changes in Board Members
Changes to the ownership composition of LPIP must obtain approval
from OJK by submitting a written application, accompanied by ownership
data such as a list of prospective shareholders with details of each share
ownership.
Art. 33 (1) and (2) OJK Reg. 5/2022
Art. 38 OJK Reg. 5/2022
Change the Composition of Board Members
In the event that LPIP intends to change the composition of its board of
directors and/or board of commissioners, prospective board members
must first obtain approval from OJK.
Art. 34 (1) OJK Reg. 5/2022
The approval or rejection will be provided by OJK within 30 (thirty)
working days after receiving the complete application documents. The
approval from OJK is valid for a maximum of 60 (sixty) working days
from the date of approval.
Art. 33 (3) and (4) OJK Reg. 5/2022
In the event that LPIP intends to merge, consolidate, or acquire another
LPIP, each LPIP must obtain approval from OJK and approval from
general meeting of shareholders.
The application for such approval must be submitted in writing by LPIP to
OJK, accompanied by the plan data for the merger, consolidation, or
acquisition.
Art. 37 OJK Reg. 5/2022
LPIP is required to submit reports to OJK regarding the following
matters:
Increase in paid-up capital within 10 (ten) working days after the
completion date of the paid-up capital increase process.
Change in ownership composition within 10 (ten) working days
after the date of the general meeting of shareholders where the
change was approved by the Financial Services Authority.
Change in the group's structure up to the ultimate owner and
controller within 10 (ten) working days after the effective date of the
change.
Appointment of board members (directors and/or commissioners)
within 10 (ten) working days after the general meeting of
shareholders where the appointment was approved by the Financial
Services Authority.
Implementation of merger, consolidation, or acquisition within 10
(ten) working days after the effective date of the merger,
consolidation, or acquisition.
a
b
c
d
e
Board Members who have not Obtained Approval from OJK
The approval or rejection of the application for prospective board
members shall be granted by OJK within 30 (thirty) working days after
receiving the complete application documents. The approval from the OJK
is valid for a maximum of 60 (sixty) working days from the date of
approval.
The application for approval must be submitted by LPIP to OJK and
must be accompanied by a list of the proposed board members of the
board of directors and board of commissioners and must comply with the
requirements as stipulated by the regulations.
Art. 34 (2) and (3) OJK Reg. 5/2022
Art. 34 (4) and (5) OJK Reg. 5/2022
Prospective members of the board of directors and/or board of
commissioners who have not obtained approval from OJK are
prohibited from performing duties and functions as board members
and/or commissioners, even if they have obtained approval from the
general meeting of shareholders.
Art. 35 OJK Reg. 5/2022
The Termination and/or Resignation of Members of the Board
In the event that there is a member of the board of directors and/or board
of commissioners who will be terminated and/or resigning, LPIP must
ensure that the requirements as stipulated in Article 16 and Article 17 are
still fulfilled.
The termination and/or resignation of board members must be reported in
writing by LPIP to OJK no later than 10 (ten) working days from the
effective date of the termination and/or resignation.
Art. 36 OJK Reg. 5/2022
Additional Paid-up Capital Provisions
PROCEDURE TO CHANGE LPIP’S DATA
A H R P L e g a l B r i e f
MANAGEMENT OF CREDIT AND FINANCING
DATA BY LPIP
a. The management of credit or financing data and other data by LPIP shall involve at least the following activities:
1) data collection;
2) data processing; and
3) data distribution.
b. The management of data as referred to in point (a) shall be carried out in accordance with the provisions of the applicable laws and regulations.
c. In managing data as referred to in point (a), LPIP must take security measures to maintain the accuracy, validity, currency, security, and
confidentiality of the data.
Art. 56 OJK Reg. 5/2022
In managing Credit or Financing Data and Other Data LPIP is prohibited from:
1) intentionally altering credit or financing data and/or other data obtained by LPIP from financial information service system, financial institutions,
and/or non-financial institutions;
2) transferring and/or copying credit or financing data and/or data to third parties, within or outside the territory of the Republic of Indonesia; and/or
3) making credit or financing data and/or other data accessible to third parties, within or outside the territory of the Republic of Indonesia.
Art. 57 (1) OJK Reg. 5/2022
In conducting activities to collect and
process data, LPIP obtains credit or
financing data from the financial
information service system. Obtainment
of Credit or Financing Data by LPIP from
the financial information service system
is subjected to data obtainment fees.
OJK determines the scope of
credit or financing data provided
to LPIP.
In generating Credit Information that adds value, LPIP
conducts data processing development by adding
credit or financing data obtained from the financial
information service system with the following scope:
1) information and/or data from non-reporting
financial institutions of the financial information
service system; and
2) other information and/or data from non-financial
Institution.
The business activities of LPIP involving the expansion of
information coverage regarding: (i) information and/or data
from non-reporting financial institutions providing financial
information service systems are required to comply with
licensing requirements no later than 6 months after LPIP
conducts its business activities and (ii) other information
and/or data from non-financial institutions are required to
comply with licensing requirements no later than 12 months
after LPIP conducts its business activities.
1 3
Art. 49 (1) jo. 53 (1) OJK Reg. 5/2022
Art. 49 (2) OJK Reg. 5/2022
2
Art. 50 (1) OJK Reg. 5/2022
Art. 51 (1) and (2) OJK Reg. 5/2022
4
Source of Data Flow
A H R P L e g a l B r i e f
Data Management
SHARING OF CREDIT INFORMATION
Financial Institutions that are
members of LPIP
Non-financial institutions that
serve as data sources for the
relevant LPIP
Debtors or Customers
Law enforcement and public
agencies
The credit information may
only be used for:
o Supporting the smooth
process of providing
Funding Facilities;
o Implementing credit or
financing risk
management;
o Identifying the quality of
Borrowers to fulfill the
provisions of the Financial
Services Authority or
other authorized parties;
o Human resource
management at Financial
Institutions; and/or
o Verification for
collaboration between
Financial Institutions and
third parties.
The credit information may
only be used for:
o Supporting the
operational activities of
non-financial institutions
related to customer
integrity identification from
a credit risk perspective;
o Selection of prospective
employees, contractors,
agents, merchants; and/or
o Vendors of non-financial
institutions; and/or
compliance with legal
regulations.
Notes:
The provision of credit
information by LPIP to Debtors
or Customers is limited to credit
information pertaining to the
respective Debtor or Customer.
Notes:
o law enforcement and public
agencies may obtain credit
information to implement the
role and function as
embedded in laws and
regulation.
o The request for credit
information must be
submitted in writing,
specifying the purpose and
objective of the request, as
well as the name of the
authorized official.
Art. 66 OJK Reg. 5/2022
Art. 66 OJK Reg. 5/2022
Art. 66 OJK Reg. 5/2022
Art. 66 OJK Reg. 5/2022
Art. 69 OJK Reg. 5/2022 Art. 70 OJK Reg. 5/2022 Art. 71 OJK Reg. 5/2022 Art. 72 OJK Reg. 5/2022
If, based on OJK's examination, a violation of the provision
regarding the sharing of credit information is found, the LPIP will
be subject to administrative sanctions in the form of a written
warning and a fine of Rp50.000.000 for each of credit
information with a maximum fine of Rp5.000.000.000.
Administrative Sanction
Art. 74 (3) OJK Reg. 5/2022
LPIP may apply charges for providing credit information to the
aforementioned parties, except in the following cases:
a. For verifying complaints from debtors or customers
regarding data inaccuracies in corrected credit information.
b. To comply with court orders.
c. Requests from law enforcement or public agencies.
d. One-time free request per year for debtors or customers.
Charge for Credit Information Request
Art. 73 OJK Reg. 5/2022
A H R P L e g a l B r i e f
Sharing of credit information
The Common Practice of Credit Analysis Procedure
Five aspects of assessment that will be evaluated regarding the debtor based
on best practices:
1 Character: Refers to the integrity, reputation, and credibility of the debtor in
meeting their financial obligations. This involves analyzing their payment history,
compliance with agreements, and overall financial responsibility.
2 Capacity: Represents the debtor's ability to repay the credit. This involves an
analysis of income, cash flow, and overall financial health.
3 Capital: Refers to the wealth and assets owned by the debtor. This can be used
as additional collateral or as an indicator of the borrower's financial stability.
4 Collateral: Represents assets used as collateral for the credit. This collateral
may include property, vehicles, or other assets that can be sold if the debtor fails
to repay the credit.
5 Condition: Refers to external factors that may affect the debtor’s ability to repay
the credit. This includes economic conditions, industry factors, and other factors
that may affect the debtor's financial stability.
Credit analysis is the process of mitigating credit risk or
potential losses due to debtors or customers' inability to repay
credits on time. Consequently, credits applications undergo
assessment and analysis regarding the debtors or customers
financial standing.
Credit analysis aims to ensure the safety and timely
repayment of loans, which is crucial for banks or non-bank
institutions to avoid the risks of bad debt or non-performing
loans and maintain a healthy credit to Deposit Ratio.
Definition of Credit Analysis
Purpose of Credit Analysis
Financial institutions collect information
about potential debtor, including but not
limited to personal details, credit history,
income, assets, liabilities, and the
purpose of the credit.
Information Gathering
The gathered information is evaluated to
determine if the potential debtor meets
the eligibility criteria for the credit. This
includes assessing their ability to repay
the credit.
Feasibility Evaluation
Financial institutions conduct a more in-
depth credit analysis, including examining
the credit history of potential debtors, the
amount of debt they hold, and whether
there are any records of late or missed
payments.
Credit Analysis
Credit risk is evaluated based on the
information gathered. This includes
default risk (the debtor's inability to repay
the credit) and other risks such as market
or industry risks.
Risk Assessment
Based on the risk analysis, financial
institutions determine the terms and
conditions for granting the credit,
including the credit amount, interest rate,
credit term, and the type of collateral
required.
Terms and Conditions Determination
Based on the results of the credit
analysis, financial institutions make a
decision on whether to grant the credit to
the potential debtor. This decision can be
full approval, conditional approval, or
rejection.
Credit Approval Decision
1 2 3
4
5
6
In practice, every financial institution has internal regulations that regulate the procedure of credit analysis
Through assessment of these five aspects, financial institutions can make better
decisions in lending and effectively manage credit risk.
A H R P L e g a l B r i e f
OVERVIEW OF CREDIT ANALYSIS
Jamalddin Fitriani, Mitigasi Resiko Kredit Perbankan.
Thomas Suyatno, Dasar-Dasar Perkreditan
Jopie Jusuf, Analisis Kredit untuk Credit
Relevance of Credit Analysis to LPIP
Credit analysis is an integral activity of LPIP since one of its
business activities involves providing credit rating services to
debtors and/or customers based on credit data; with credit
analysis, it supports LPIP in evaluating credit risks and
making decisions related to credit.
Art. 2 (1) b OJK Reg. 5/2022
PT Bank OCBC NISP, Mengenal Prinsip 5c Dalam Pemberian Kredit Agar Disetujui
We will continue to follow the developments on this topic and provide additional information as it
becomes available. If you have any questions on this topic, please contact:
Ahmad Arif
arif@ahrplaw.com
Hanif Julianto Firman
hanif@ahrplaw.com
Hany Areta Athayalia
hany@ahrplaw.com
This publication has been prepared by AHRP for educational and informational purposes only. The information contained in this publication is not
intended and should not be construed as legal advice. Due to the rapidly changing nature of law, AHRP makes no warranty or guarantee
concerning the accuracy or completeness of this content. You should consult with an attorney to review the current status of the law and how it
applies to your circumstances before deciding to take any action.
World Capital Tower 19th floor
Jl. Mega Kuningan Barat No.3, Kuningan
Jakarta 12950 Indonesia
P: +6221 50917915
+6221 50917916
E: office@ahrplaw.com
www.ahrplaw.com

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Towards National Financial Inclusion and Credit Growth: Regulatory Framework of the Credit Bureau Agency

  • 1. Legal Brief Towards National Financial Inclusion and Credit Growth: Regulatory Framework of the Credit Bureau Agency
  • 2. A H R P L e g a l B r i e f Purpose of LPIP Establishment To encourage the growth of credit and national financial inclusion, support from credit information management institutions is needed to produce diverse, comprehensive credit information with added value. Therefore, it is necessary to manage and develop credit information by expanding the scope of credit or financing data and other data from both financial and non-financial institutions. The establishment of LPIP aims to manage and develop credit information effectively, enabling sustainable business operations through institutional structuring, good governance implementation, strengthening stakeholder protection, enhancing compliance with regulations, and upholding universally applicable ethical values in operational activities. History of LPIP Regulation Credit Bureau Agency (Lembaga Pengelola Informasi Perkreditan or “LPIP”) is the credit rating agency that gathers and processes credit or financing data and other data to produce credit information. Art. 1 (1) OJK Reg. 5/2022 LPIP in Indonesia There are three LPIP licensed by the Financial Services Authority (Otoritas Jasa Keuangan or “OJK”), as follows: a. Collecting and processing Credit or Financing Data and/or Other Data; b. Providing rating services for Debtors or Customers based on Credit or Financing Data and/or Other Data; and c. Generating Credit Information that possesses added value based on Credit or Financing Data and/or Other Data and which encompasses the following: credit scores, fraud rankings, profile mapping of debtors and customers, and the monitoring and evaluation of debtors and customers. Business Activities of LPIP If LPIP undertake any activities other than those outlined above, then they will be subject to the imposition of administrative sanctions in the form of written reprimands. Art. 2 (1) OJK Reg. 5/2022 Principles of Governance LPIP is required to implement good governance in all of its business activities at all levels or organizational levels, which must at least be manifested in the following forms: a. Implementation of the duties and responsibilities of the board of directors; b. Implementation of the duties and responsibilities of the board of commissioners; c. Handling conflicts of interest; d. Implementation of risk management, compliance, internal audit, external audit functions, and operational guidelines related to cooperation with LPIP members; e. Annual business plan of LPIP; and f. Transparency of financial and non-financial conditions through publication. Art. 8 (1) and (2) OJK Reg. 5/2022 Art. 2 (2) and (3) OJK Reg. 5/2022 LPIP is required to submit a governance implementation report as part of its annual report. Further provisions regarding the implementation of governance and the scope of the governance implementation report shall be determined by OJK. Art. 8 (3) and (4) OJK Reg. 5/2022 Central Bank of Indonesia Regulation Number 15/1/PBI/2013 (“BI Reg. 15/2013”) OJK Regulation Number 42/POJK.03/2019 OJK Regulation Number 5/POJK.03/2022 This regulation is a conversion of BI Reg. 15/2013 which adjusts several provisions such as (i) changing phrases, terminology, and article constructions; (ii) adjusting definitions; (iii) aligning dual positions for members of board of directors and/or members of the board of commissioners; and (iv) adjusting the mechanism for revoking LPIP business licenses. This regulation revokes OJK Reg. 42/2019 as a form of adjustment to current conditions, as needed for significant improvements. This OJK Regulation is established as an effort to enhance overall credit growth. PT Kredit Biro Indonesia PT PEFINDO Biro Kredit PT CRIF Lembaga Informasi Keuangan a b c d e f a b c BACKGROUND
  • 3. The paid-up capital for establishing LPIP is determined to be at least Rp50.000.000.000,00 (fifty billion Indonesian rupiah). The funding source for the ownership of LPIP must not originate from: a. Loans or financing facilities from banks and/or other parties; and/or b. Money laundering. Furthermore, LPIP is required to allocate a portion of the company's profits for the enhancement of technology, infrastructure, and human resources. The Provision of Minimum Paid-up Capital Previous Provisions on Minimum Paid-up Capital of LPIP The Provisions of Credit Information The paid-up capital for establishing LPIP is determined to be at least Rp200.000.000.000,00 (two hundred billion Indonesian rupiah). The funding source for the ownership of LPIP must not originate from: a. Loans or financing facilities from banks and/or other parties; and/or b. The proceeds of crime and for the purposes of money laundering, terrorism financing, as well as the financing of the proliferation of weapons of mass destruction. The funding source for increasing the paid-up capital of LPIP may consist of cash or other assets that can be utilized as supporting infrastructure for LPIP. Art. 5 OJK Reg. 5/2022 Art. 6 OJK Reg. 42/2019 Current Provisions on Minimum Paid-up Capital of LPIP LPIP is obligated to generate credit information derived from the collection and/or processing of credit or financing data and/or other data by LPIP, excluding standard information. There are several provisions concerning changes in credit information between OJK Reg. 42/2019 and OJK Reg. 5/2022, as follows: No. Credit Information OJK Reg. 42/2019 OJK Reg. 5/2022 1. End data owner's identity n/a required 2. Identity of the manager of the end data owner in the form of a business entity n/a required 3. Financial profile of the end data owner n/a required 4. Funding provision facilities required optional 5. Collateral and/or guarantor required optional 6. Creditor's identity required optional 7. Records of borrower information users required optional 8. Financial report required n/a 9. Information on ongoing complaints related to borrower information required optional Credit Information Comparison between OJK Reg. 42/2019 and OJK Reg. 5/2022 Art. 61 OJK Reg. 5/2022 jo. Art. 48 OJK Reg. 42/2019 KEY CHANGES IN OJK REG. 5/2022 A H R P L e g a l B r i e f
  • 4. Each party who wants to conduct LPIP must establish a Limited Liability Company or Perseroan Terbatas. Form of Business Entity Art. 4 (1) OJK Reg. 5/2022 The minimum paid-up capital to establish LPIP is set at Rp200.000.000.000,00 (two hundred billion Rupiah). Art. 5 (1) OJK Reg. 5/2022 Governance Implementation a) LPIP shall implement good governance in all its business activities at all levels or stage of organization. b) The implementation of good governance as referred to in paragraph a) must at least be manifested in the form of: 1) implementation of the duties and responsibilities of the board of directors; 2) implementation of duties and responsibilities of the board of commissioners; 3) handling conflict of interest; 4) risk management, compliance, internal audit, external audit functions, and operational guidelines implementation which relate to cooperation with LPIP members; 5) annual business plan of LPIP; and 6) transparency of financial and non-financial conditions via publications. c) LPIP shall submit a governance implementation report as part of the annual report. d) Further provisions regarding the implementation of governance as referred to in paragraph b) and the scope of governance implementation reports as referred to in paragraph c) are determined by the OJK. Fit and Proper Test for Key Persons Art. 8 OJK Reg. 5/2022 a) The prospective of key persons shall obtain from OJK before carrying out actions, duties, and functions as Key Person. b) Key Person as referred to in paragraph a) consist of: 1) Controlling key person; and 2) Managing key person. c) To grant approval as key persons, the OJK assesses the capabilities and suitability of prospective main parties. d) The assessment of capabilities and suitability is conducted to ascertain that prospective key persons as referred to in paragraph b) fulfil the following requirements: 1) integrity and financial eligibility for prospective Controlling Key Person; and 2) integrity, financial reputation, and competence for prospective Managing Key Person. e) Further provisions regarding the procedures for assessing capabilities and suitability as referred to in paragraph c) and d) are determined by the OJK. Art. 9 OJK Reg. 5/2022 a) LPIP’s shareholders must be in the form of legal entity. b) Business entity as referred to in paragraph a) must in accordance with the prevailing laws and regulations. . c) Legal entity as referred to in paragraph a) owns by: 1) Indonesian legal entity; or 2) Indonesian legal entity that cooperates with foreign legal entity. d) In the event that legal entity holding shares of LPIP is a Public Limited Liability Company and trading its shares on the public exchange, provisions as referred to in paragraph c) do not apply. e) Foreign legal must have minimum of 3 (three) years of experience in the credit information management industry. a) The maximum shares ownership of LPIP by each shareholders is 51% (fifty one percent) from paid-up capital. b) The maximum limit on share ownership also applies to ownership based on relationship between shareholders. c) In the event a shareholders of LPIP also holds shares in another LPIP, the maximum total share ownership in all LPIP is 51% (fifty one percent). d) In the event legal entity holding LPIP shares is partially owned by foreign parties, the following provisions apply: 1) total ownership by 1 (one) or more foreign parties in 1 (one) LPIP is limited to a maximum of 20% (twenty percent); and 2) total ownership by 1 (one) foreign party in more than 1 (one) LPIP is limited to a maximum of 20% (twenty percent). e) Further provisions regarding LPIP ownership shall be determined by OJK. Art. 14 OJK Reg. 5/2022 Art. 15 OJK Reg. 5/2022 Shareholding Provisions INSTITUTIONAL ASPECTS OF LPIP (1/2) Capital Requirement A H R P L e g a l B r i e f
  • 5. a) LPIP shall have a board of directors consisting of at least 3 (three) members. b) The member of board of directors as referred to in paragraph a) shall at least 50% (fifty-percent) be Indonesian citizens. c) At least 1 (one) member of the board of directors as referred to in paragraph a) must have knowledge and/or experience in the credit information management industry. d) Members of the board of directors may only hold positions as directors, members of the board of commissioners, or executive officers of non-profit companies, organizations, or institutions. Art. 16 OJK Reg. 5/2022 Art. 17 OJK Reg. 5/2022 a) LPIP shall have a board of commissioners with a minimum of 2 (two) members and a maximum equal to the number of members in the board of the directors. b) The member of board of directors as referred to in paragraph a ) shall at least 50% (fifty-percent) be Indonesian citizens. a) LPIP may utilize foreign workers for positions, such as members of the board of directors, members of the board of commissioners, executive officers, experts, or consultants. b) Foreign workers as referred to in paragraph a) must fulfill the following requirements: 1) fulfill the expertise qualification; 2) do not hold positions in Financial Institution domiciled in Indonesia and/or outside territory of Indonesia; and 3) possess knowledge of the Indonesian economy, language, and Indonesian’s culture. c) Prohibition to utilize foreign workers in the following areas of responsibility: 1) managing human resources; and 2) the implementation of compliance. d) The utilization of foreign workers shall obtain approval from OJK. Art. 19 OJK Reg. 5/2022 a) In utilizing foreign workers as executive officers, experts, or consultant, LPIP must conduct of the following: 1) before using foreign workers to such position above, shall consider the availability of local experts or consultant for the required fields and expertise; 2) provide 2 (two) local assistant for each foreign workers; and 3) observe the provisions of labor laws and regulations. b) Foreign workers serving as members of the board of directors and/or board of commissioners, in addition to meeting the requirements, foreign workers are subject to the requirements and provisions applicable to members of the board directors and/or board of commissioners under OJK Reg 5/2021. Art. 20 OJK Reg. 5/2022 a) LPIP that fails to comply with the provisions on (i) director; (ii) commissioner; (iii) utilization of foreign workers shall be subjected to administrative sanctions in the form of written warnings. b) If LPIP has been imposed to administrative sanctions in the form of written warning and has not yet complied with the provision on: (i) director; (ii) commissioner; (iii) utilization of foreign workers, may also be subjected to administrative sanctions in the form of: 1) temporary suspension of certain business activities; 2) suspension of the provision of Credit or Financing Data from the OJK; and/or 3) inclusion of management in the list of parties prohibited from becoming Key Persons. Art. 22 OJK Reg. 5/2022 INSTITUTIONAL ASPECTS OF LPIP (2/2) Provisions on Directors Provisions on Commissioners Administrative Sanction Provisions on Utilization of Foreign Workers A H R P L e g a l B r i e f
  • 6. In order to conduct the business activities, LPIP requires to obtain the following licenses: Principal Approval o Principal approval shall remain valid for a period of 12 months from the issuance o Principal approval serves as a prerequisite for obtaining business licensing o Principal approval may not be transferred to other parties. Business Licensing The first-time implementation of business activities must be reported to OJK by the director of LPIP within a maximum of 10 working days after the date of implementation of the business activities Application for a principal approval is accompanied by administrative documents to OJK Administrative examination by OJK on the administrative documents Submission of additional documents (if needed) OJK conducts technical examination of the submitted application after completed Presentation from applicants to OJK on the plan and development strategic of LPIP Principal Approval Business Licensing Announcement from OJK either approval or rejection from the application The request from OJK for additional documents must be submitted within 20 working days after the announcement Art. 23 b OJK Reg. 5/2022 Art. 28 – Art. 30 OJK Reg. 5/2022 1 2 3 4 5 6 * at the latest 60 working days from the date of receipt of the complete application documents. * at the latest 40 working days from the date of receipt of the complete application documents and supporting infrastructure is available to supporting the operational of LPIP. Art. 24 – Art. 27 OJK Reg. 5/2022 Art. 23 a OJK Reg. 5/2022 PROCEDURE TO OBTAIN PRINCIPAL APPROVAL AND BUSSINESS LICENSE OF LPIP A H R P L e g a l B r i e f Application for a business license is accompanied by administrative documents to OJK OJK conducts technical examination of the submitted application after the documents are complete Announcement from OJK either approval or rejection from the application The applicant shall commence business activities within a maximum of 20 working days from the date the business license is issued 1 2 3 4
  • 7. Additional paid-up capital in LPIP must obtain approval from OJK by fulfill the following requirements: a. Must comply with the provisions regarding the limitation of share ownership as referred to in Article 15 OJK Reg 5/2022; and b. Must be submitted in writing, accompanied by a letter of statement from LPIP shareholders that the increase in paid-up capital: 1) Does not originate from loans or financing facilities from banks and/or other parties; and 2) Does not originate from proceeds of criminal activities and for the purposes of money laundering, terrorism financing, or funding proliferation of weapons of mass destruction. Approval or rejection of the application shall be granted by OJK later than 30 (thirty) working days after the complete submission of the application documents. Art. 32 OJK Reg. 5/2022 Changes in Shareholders Changes in Board Members Changes to the ownership composition of LPIP must obtain approval from OJK by submitting a written application, accompanied by ownership data such as a list of prospective shareholders with details of each share ownership. Art. 33 (1) and (2) OJK Reg. 5/2022 Art. 38 OJK Reg. 5/2022 Change the Composition of Board Members In the event that LPIP intends to change the composition of its board of directors and/or board of commissioners, prospective board members must first obtain approval from OJK. Art. 34 (1) OJK Reg. 5/2022 The approval or rejection will be provided by OJK within 30 (thirty) working days after receiving the complete application documents. The approval from OJK is valid for a maximum of 60 (sixty) working days from the date of approval. Art. 33 (3) and (4) OJK Reg. 5/2022 In the event that LPIP intends to merge, consolidate, or acquire another LPIP, each LPIP must obtain approval from OJK and approval from general meeting of shareholders. The application for such approval must be submitted in writing by LPIP to OJK, accompanied by the plan data for the merger, consolidation, or acquisition. Art. 37 OJK Reg. 5/2022 LPIP is required to submit reports to OJK regarding the following matters: Increase in paid-up capital within 10 (ten) working days after the completion date of the paid-up capital increase process. Change in ownership composition within 10 (ten) working days after the date of the general meeting of shareholders where the change was approved by the Financial Services Authority. Change in the group's structure up to the ultimate owner and controller within 10 (ten) working days after the effective date of the change. Appointment of board members (directors and/or commissioners) within 10 (ten) working days after the general meeting of shareholders where the appointment was approved by the Financial Services Authority. Implementation of merger, consolidation, or acquisition within 10 (ten) working days after the effective date of the merger, consolidation, or acquisition. a b c d e Board Members who have not Obtained Approval from OJK The approval or rejection of the application for prospective board members shall be granted by OJK within 30 (thirty) working days after receiving the complete application documents. The approval from the OJK is valid for a maximum of 60 (sixty) working days from the date of approval. The application for approval must be submitted by LPIP to OJK and must be accompanied by a list of the proposed board members of the board of directors and board of commissioners and must comply with the requirements as stipulated by the regulations. Art. 34 (2) and (3) OJK Reg. 5/2022 Art. 34 (4) and (5) OJK Reg. 5/2022 Prospective members of the board of directors and/or board of commissioners who have not obtained approval from OJK are prohibited from performing duties and functions as board members and/or commissioners, even if they have obtained approval from the general meeting of shareholders. Art. 35 OJK Reg. 5/2022 The Termination and/or Resignation of Members of the Board In the event that there is a member of the board of directors and/or board of commissioners who will be terminated and/or resigning, LPIP must ensure that the requirements as stipulated in Article 16 and Article 17 are still fulfilled. The termination and/or resignation of board members must be reported in writing by LPIP to OJK no later than 10 (ten) working days from the effective date of the termination and/or resignation. Art. 36 OJK Reg. 5/2022 Additional Paid-up Capital Provisions PROCEDURE TO CHANGE LPIP’S DATA A H R P L e g a l B r i e f
  • 8. MANAGEMENT OF CREDIT AND FINANCING DATA BY LPIP a. The management of credit or financing data and other data by LPIP shall involve at least the following activities: 1) data collection; 2) data processing; and 3) data distribution. b. The management of data as referred to in point (a) shall be carried out in accordance with the provisions of the applicable laws and regulations. c. In managing data as referred to in point (a), LPIP must take security measures to maintain the accuracy, validity, currency, security, and confidentiality of the data. Art. 56 OJK Reg. 5/2022 In managing Credit or Financing Data and Other Data LPIP is prohibited from: 1) intentionally altering credit or financing data and/or other data obtained by LPIP from financial information service system, financial institutions, and/or non-financial institutions; 2) transferring and/or copying credit or financing data and/or data to third parties, within or outside the territory of the Republic of Indonesia; and/or 3) making credit or financing data and/or other data accessible to third parties, within or outside the territory of the Republic of Indonesia. Art. 57 (1) OJK Reg. 5/2022 In conducting activities to collect and process data, LPIP obtains credit or financing data from the financial information service system. Obtainment of Credit or Financing Data by LPIP from the financial information service system is subjected to data obtainment fees. OJK determines the scope of credit or financing data provided to LPIP. In generating Credit Information that adds value, LPIP conducts data processing development by adding credit or financing data obtained from the financial information service system with the following scope: 1) information and/or data from non-reporting financial institutions of the financial information service system; and 2) other information and/or data from non-financial Institution. The business activities of LPIP involving the expansion of information coverage regarding: (i) information and/or data from non-reporting financial institutions providing financial information service systems are required to comply with licensing requirements no later than 6 months after LPIP conducts its business activities and (ii) other information and/or data from non-financial institutions are required to comply with licensing requirements no later than 12 months after LPIP conducts its business activities. 1 3 Art. 49 (1) jo. 53 (1) OJK Reg. 5/2022 Art. 49 (2) OJK Reg. 5/2022 2 Art. 50 (1) OJK Reg. 5/2022 Art. 51 (1) and (2) OJK Reg. 5/2022 4 Source of Data Flow A H R P L e g a l B r i e f Data Management
  • 9. SHARING OF CREDIT INFORMATION Financial Institutions that are members of LPIP Non-financial institutions that serve as data sources for the relevant LPIP Debtors or Customers Law enforcement and public agencies The credit information may only be used for: o Supporting the smooth process of providing Funding Facilities; o Implementing credit or financing risk management; o Identifying the quality of Borrowers to fulfill the provisions of the Financial Services Authority or other authorized parties; o Human resource management at Financial Institutions; and/or o Verification for collaboration between Financial Institutions and third parties. The credit information may only be used for: o Supporting the operational activities of non-financial institutions related to customer integrity identification from a credit risk perspective; o Selection of prospective employees, contractors, agents, merchants; and/or o Vendors of non-financial institutions; and/or compliance with legal regulations. Notes: The provision of credit information by LPIP to Debtors or Customers is limited to credit information pertaining to the respective Debtor or Customer. Notes: o law enforcement and public agencies may obtain credit information to implement the role and function as embedded in laws and regulation. o The request for credit information must be submitted in writing, specifying the purpose and objective of the request, as well as the name of the authorized official. Art. 66 OJK Reg. 5/2022 Art. 66 OJK Reg. 5/2022 Art. 66 OJK Reg. 5/2022 Art. 66 OJK Reg. 5/2022 Art. 69 OJK Reg. 5/2022 Art. 70 OJK Reg. 5/2022 Art. 71 OJK Reg. 5/2022 Art. 72 OJK Reg. 5/2022 If, based on OJK's examination, a violation of the provision regarding the sharing of credit information is found, the LPIP will be subject to administrative sanctions in the form of a written warning and a fine of Rp50.000.000 for each of credit information with a maximum fine of Rp5.000.000.000. Administrative Sanction Art. 74 (3) OJK Reg. 5/2022 LPIP may apply charges for providing credit information to the aforementioned parties, except in the following cases: a. For verifying complaints from debtors or customers regarding data inaccuracies in corrected credit information. b. To comply with court orders. c. Requests from law enforcement or public agencies. d. One-time free request per year for debtors or customers. Charge for Credit Information Request Art. 73 OJK Reg. 5/2022 A H R P L e g a l B r i e f Sharing of credit information
  • 10. The Common Practice of Credit Analysis Procedure Five aspects of assessment that will be evaluated regarding the debtor based on best practices: 1 Character: Refers to the integrity, reputation, and credibility of the debtor in meeting their financial obligations. This involves analyzing their payment history, compliance with agreements, and overall financial responsibility. 2 Capacity: Represents the debtor's ability to repay the credit. This involves an analysis of income, cash flow, and overall financial health. 3 Capital: Refers to the wealth and assets owned by the debtor. This can be used as additional collateral or as an indicator of the borrower's financial stability. 4 Collateral: Represents assets used as collateral for the credit. This collateral may include property, vehicles, or other assets that can be sold if the debtor fails to repay the credit. 5 Condition: Refers to external factors that may affect the debtor’s ability to repay the credit. This includes economic conditions, industry factors, and other factors that may affect the debtor's financial stability. Credit analysis is the process of mitigating credit risk or potential losses due to debtors or customers' inability to repay credits on time. Consequently, credits applications undergo assessment and analysis regarding the debtors or customers financial standing. Credit analysis aims to ensure the safety and timely repayment of loans, which is crucial for banks or non-bank institutions to avoid the risks of bad debt or non-performing loans and maintain a healthy credit to Deposit Ratio. Definition of Credit Analysis Purpose of Credit Analysis Financial institutions collect information about potential debtor, including but not limited to personal details, credit history, income, assets, liabilities, and the purpose of the credit. Information Gathering The gathered information is evaluated to determine if the potential debtor meets the eligibility criteria for the credit. This includes assessing their ability to repay the credit. Feasibility Evaluation Financial institutions conduct a more in- depth credit analysis, including examining the credit history of potential debtors, the amount of debt they hold, and whether there are any records of late or missed payments. Credit Analysis Credit risk is evaluated based on the information gathered. This includes default risk (the debtor's inability to repay the credit) and other risks such as market or industry risks. Risk Assessment Based on the risk analysis, financial institutions determine the terms and conditions for granting the credit, including the credit amount, interest rate, credit term, and the type of collateral required. Terms and Conditions Determination Based on the results of the credit analysis, financial institutions make a decision on whether to grant the credit to the potential debtor. This decision can be full approval, conditional approval, or rejection. Credit Approval Decision 1 2 3 4 5 6 In practice, every financial institution has internal regulations that regulate the procedure of credit analysis Through assessment of these five aspects, financial institutions can make better decisions in lending and effectively manage credit risk. A H R P L e g a l B r i e f OVERVIEW OF CREDIT ANALYSIS Jamalddin Fitriani, Mitigasi Resiko Kredit Perbankan. Thomas Suyatno, Dasar-Dasar Perkreditan Jopie Jusuf, Analisis Kredit untuk Credit Relevance of Credit Analysis to LPIP Credit analysis is an integral activity of LPIP since one of its business activities involves providing credit rating services to debtors and/or customers based on credit data; with credit analysis, it supports LPIP in evaluating credit risks and making decisions related to credit. Art. 2 (1) b OJK Reg. 5/2022 PT Bank OCBC NISP, Mengenal Prinsip 5c Dalam Pemberian Kredit Agar Disetujui
  • 11. We will continue to follow the developments on this topic and provide additional information as it becomes available. If you have any questions on this topic, please contact: Ahmad Arif arif@ahrplaw.com Hanif Julianto Firman hanif@ahrplaw.com Hany Areta Athayalia hany@ahrplaw.com This publication has been prepared by AHRP for educational and informational purposes only. The information contained in this publication is not intended and should not be construed as legal advice. Due to the rapidly changing nature of law, AHRP makes no warranty or guarantee concerning the accuracy or completeness of this content. You should consult with an attorney to review the current status of the law and how it applies to your circumstances before deciding to take any action. World Capital Tower 19th floor Jl. Mega Kuningan Barat No.3, Kuningan Jakarta 12950 Indonesia P: +6221 50917915 +6221 50917916 E: office@ahrplaw.com www.ahrplaw.com