Comparative Analysis Of Consumer Protection Regulations In Peer To Peer Lending Platforms In Indonesia And The United States

Abstract

The development of P2P Lending has enhanced financial inclusion comprehensively in Indonesia, yet it has also generated significant risks of violations against consumer and data protection. This study compares the regulatory frameworks in Indonesia and the United States by using a normative‑juridical method. Indonesia applies a centralized system administered by the Financial Services Authority (OJK), whereas in the United States, regulation is carried out through a multi‑agency approach based on principles. Consumer protection in Indonesia emphasizes transparency, but it remains weak in relation to debt collection and data protection. In contrast, the United States provides more comprehensive protection through mandatory disclosures, class action mechanisms and robust supervision.