Indonesia: Bank Century Emergency Liquidity Program, 2008

On October 30, 2008, Bank Century, a relatively small Indonesian bank, defaulted on an IDR 59.8 billion loan payment, and the largest depositors at the bank pulled their funding. A Bank Indonesia deputy governor said that Bank Century could have paid the loan if its interbank funding had functioned properly, but banks did not want to lend to Bank Century as a result of “liquidity jitters” (R. A. Witular 2008). The same day, Bank Indonesia passed Bank Indonesia Regulation No. 10/26/PBI/2008, creating the SFF. Bank Indonesia said it created the facility in order to maintain public confidence in the banking system and to anticipate liquidity risks surfacing in the context of the GFC (BI 2008c).

On November 13, Bank Century could not clear payments on the Indonesian real-time gross settlement (RTGS) system because it could not provide IDR 50 billion in cash to prefund its Bank Indonesia clearing account before the RTGS opened—it did not have sufficient liquidity and could not obtain an interbank loan to provide it (BI 2008h; DIC 2011). The following day (November 14), Bank Indonesia (a) passed Regulation No. 10/30/PBI/2008, amending the SFF regulations by lowering the CAR threshold from 8% to above 0%; (b) approved Bank Century for access to the SFF; and (c) disbursed IDR 356.8 billion to Bank Century through the SFF (BI 2008d; ICW 2009). At the time, Bank Century had assets equivalent to just 0.9% of the Indonesian banking system (Kurniasari 2012; Silka and Suhartono 2008).

In an ex post Q&A press release, Bank Indonesia said that its decision to revise the legislation on November 14 was not targeted specifically at Bank Century:

Bank Indonesia said that the November 14 revisions to the SFF regulations were in response to urgently deteriorating instability in the Indonesian banking system, evidenced by systemic deposit outflows and disruptions to the government securities markets, resulting in illiquidity in repurchase agreement (repo) markets (BI 2009a). Later, however, Indonesian courts found that Bank Indonesia created the SFF with the intent of specifically supporting Bank Century and that Bank Indonesia’s deputy governor took a bribe resulting in the extension of the SFF liquidity (see Summary Evaluation).

Bank Indonesia said that its rescue of Bank Century should be viewed in the context of its efforts to save the financial system and economy as a whole (Wibowo 2009). Then–Bank Indonesia Governor Boediono said that “if one bank collapsed and Century Bank could be the one, a bank run certainly would have occurred like in 1998” (Natalia 2014a). In their decision to grant Bank Century SFF access, the Board of Governors of Bank Indonesia considered the risk that a Bank Century failure would affect other banks (Natalia 2014a).

Later, on November 21 (after the disbursement of SFF funds), the FSSC made the determination that Bank Century was a failed bank with a systemic impact, allowing for the takeover of the bank by the DIC (Santosa 2010). Bank Indonesia said at that time that the decision was taken because Bank Century could have been successfully rescued, therefore maintaining confidence in the national banking system (BI 2008j). In 2009, Bank Indonesia (but not the Ministry of Finance) issued a press release called “Q&A: Systemic Impact of Bank Century,” describing its rationale for designating Bank Century as a failed bank with systemic impact. Bank Indonesia said that Bank Century’s failure occurred in the context of a dramatic rise in banking sector risk, and that while it did not consider Bank Century economically significant in terms of size, it concluded that its failure could have had broad contagion effects (BI 2009b).

However, at the time, the Capital Markets Supervisory Agency (then Indonesia’s capital markets regulator) and the Fiscal Policy Agency (an internal think tank at the Ministry of Finance) said in a closed-door meeting that Bank Indonesia’s systemic risk analysis conclusions were not supported by adequate data and that Bank Century did not pose a systemic risk (Widiati 2016). An economist at a Jakarta-based economic research outfit said that Bank Century was “not systemic” and “a stand-alone [case]” (Ismar and Silka 2008).

In its ex post investigation, the Supreme Audit Agency (SAA) said that Bank Indonesia had supervisory information showing that Bank Century had a negative capital adequacy ratio when it disbursed SFF funds (see Key Design Decision No. 5, Governance). Bank Indonesia disputed that claim, saying that it was not able to obtain accurate or timely CAR data (see Key Design Decision No. 3, Legal Authority). Three months after the systemic failure determination was made, then–Minister of Finance Sri Mulyani requested that the decision to categorize Bank Century as a failed bank with a systemic impact be reviewed (R. Witular 2014). She said:

The day before the FSSC decision, Bank Indonesia’s director of bank research and regulation said that Bank Century did not pose a systemic threat, but the Bank Indonesia Board of Governors decided not to present his findings at the FSSC meeting because they were concerned that the findings would hamper their efforts to get FSSC approval of a systemic failure determination. The Bank Indonesia board then directed Bank Indonesia’s banking supervision group to support its systemic risk determination (R. Witular 2014). Our research did not uncover a public statement from Bank Indonesia on Bank Century’s solvency when it first provided SFF funding.

In addition to the SFF, Bank Indonesia had one other facility (the Intraday Liquidity Facility for Commercial Banks, created the same day as the first Bank Century SFF fund disbursement) on the day it granted Bank Century access to the SFF. Four days after it released SFF funds to Bank Century, Bank Indonesia also created a special Emergency Funding Facility for Commercial Banks (EFF). Governor Boediono said that Bank Indonesia extended emergency credit under the SFF instead of the EFF because the EFF was not yet operational (but was previously authorized, on October 15, to operate as the main emergency funding facility for commercial banks; see Key Design Decision No. 3, Legal Authority) (Natalia 2014a). All facilities were de jure broad based (BI 2008c; BI 2008d; BI 2008e; BI 2008f; BI 2013). In its 2008 annual report, Bank Indonesia said that the SFF was used only by “one national private bank” but did not include information on the usage of the other two facilities (BI 2009c, 27–28). Figure 2 shows the range of liquidity facilities available to commercial banks in Indonesia in October–November 2008.

On November 17, Indonesian Sinar Mas Group said it would pay roughly IDR 982 billion to acquire up to a 70% stake in Bank Century (Silka and Suhartono 2008). The Jakarta Post reported that Bank Indonesia had ordered Sinar Mas Group to purchase Bank Century (R. A. Witular 2008). In any case, Sinar Mas Group later rescinded its offer to purchase the bank (DIC 2011).

Before its takeover by the DIC on November 21, 2008, Bank Indonesia placed Bank Century under intensive supervision and special surveillance on November 6, and requested that Bank Century (a) sell liquid assets, (b) raise capital, and (c) try to find strategic investors (BI 2008j). Per Bank Indonesia regulations, a bank must be placed under special surveillance when its CAR falls below 8% (or when its statutory reserves fall below the minimum reserve requirement). Bank Indonesia also prohibited withdrawals of all types of deposits from Bank Century (BBC News Indonesia 2014). Placing a bank under special surveillance allows Bank Indonesia to order a capital restoration plan; implement mandatory supervisory actions; and order bank shareholders to take numerous actions, including but not limited to the sale of liabilities, suspension of business activities, and the sale of the bank. Had it not designated Bank Century on November 6, Bank Indonesia would have been required by regulation to designate Bank Century as a Bank Under Special Surveillance when it used SFF funds (BI 2004; BI 2008a; Kurniasari 2012).

On Friday, November 21, when the DIC took over Bank Century, Bank Indonesia prohibited Robert Tantular and seven other Bank Century executives from leaving the country (the first time Bank Indonesia had done so since the 1997 Asian Financial Crisis) (R. A. Witular 2008).

For coverage of the DIC-administered capital injections and the later sale and acquisition of Bank Century, see the Appendix.

On October 15, the president of Indonesia issued Government Regulation in Lieu of Law (Perpu) No. 4/2008, which established the FSSC, defined a failing bank with systemic impact, and defined the intended route through which to handle systemic crises through the EFF and DIC. Perpu No. 4/2008 defined (though was not the regulatory basis for) the EFF and said it should be used by Bank Indonesia for banks experiencing liquidity challenges with systemic impact. Perpu No. 4/2008 made no mention of the SFF (President RoI 2008).

The Bank Indonesia Act authorizes Bank Indonesia to provide emergency lending to banks experiencing short-term liquidity (“mismatch”) challenges (a) for a period of no more than 90 days; (b) collateralized at least 100% (but up to 150%) by high-quality, liquid collateral;^FNHaircuts varied based on the composition of collateral. In subsequent investigations, the SAA clarified that the applicable collateralization requirement on Bank Century’s borrowing was 150% (SAA 2014). According to Bank Indonesia regulations, the only way SFF collateral would be required by Bank Indonesia to be 150% was if the collateral were entirely composed of credit assets (BI 2008c). (c) consistent with Bank Indonesia regulations; and (d) based on Syariah Principles^FNSyariah laws, part of the Islamic tradition, prohibit the payment of interest on loans. The Bank Indonesia Act defines financing based on Syariah (often transliterated as Sharia or Shari’ah) Principles to be “a provision of money or any claim which is similar as such based on an agreement between Bank Indonesia and a Bank which requires such Bank to repay the money or such claim after a certain period with a fee or production sharing” (President RoI 1999, ch. 1, art. 1).  (President RoI 1999). 

Bank Century collateralized its borrowing from the SFF by only 83% (see Key Design Decision No. 5, Governance).

On October 30, Bank Indonesia passed Regulation No. 10/26/PBI/2008, which authorized and governed the SFF (BI 2008c).

On November 14, Bank Indonesia passed Regulation No. 10/30/PBI/2008, amending Regulation No. 10/26/PBI/2008 (BI 2008d). In doing so, it reduced the capital adequacy requirement (CAR) from ≥ 8% to > 0%, reduced the collateral requirement for credit assets from those collateralized 110% to simply collateralized credit assets, and introduced an article pursuant to which Bank Indonesia would designate any bank using the SFF as a “Bank under Special Surveillance” (BI 2008c; BI 2008d).

Bank Indonesia Regulation No. 10/30/PBI/2008 required that any bank borrowing from the SFF have a positive CAR; however, Bank Indonesia later disclosed that, as of October 31, 2008, Bank Century had a CAR of –3.35%, and Bank Indonesia relied upon September figures to assess that Bank Century had a positive CAR (BI 2008d; ICW 2009; SAA 2014). In a 2009 press release, Bank Indonesia said that it had to rely on September data because Bank Century managers were unable to fulfill a request for CAR data from Bank Indonesia supervisors (BI 2009a).

In 2014, in the context of the trial of former Bank Indonesia Deputy Governor Budi Mulya (for alleged corruption connected with the government’s response to the Bank Century crisis in 2008), a prosecutor asked then-Governor Boediono if the disbursement of the SFF funds was illegal since the funds were disbursed before documentation for SFF access was completed; Boediono said he did not know. When asked whether it was permissible to ignore the regulations on proper documentation before extending SFF credit, Boediono said:

Legal challenges associated with Bank Indonesia’s and the DIC’s handling of the Bank Century case arising from a Bank Century customer’s being unable to access her savings eventually reached the Court, the nation’s final arbiter on constitutional law. In its decision, the Court said that Bank Indonesia had issued Regulation Nos. 10/26/PBI/2008 and 10/30/PBI/2008 (concerning the SFF) solely to provide a legal justification for giving Bank Century access to a “bailout” (Constitutional Court 2010, paras. 3.9–3.11). Further, the Court said that the FSSC lacked measurable criteria against which to determine whether Bank Century was a “failing bank with a systemic impact” (Constitutional Court 2010, para. 3.14). The Court ruled that Perpu No. 4/2008—which created the FSSC and authorized the EFF—was illegal and no longer had legal force (Constitutional Court 2010).

The Court also said there was wrongdoing in the DIC’s handling of Bank Century; for more on the capital injections, see the Appendix.

Within Bank Indonesia, three deputies oversaw the SFF: the deputy for monetary management, the deputy for credit, and the deputy for bank supervision (Natalia 2014a).

To obtain SFF financing, Bank Century had to submit a written application to Bank Indonesia along with supporting documentation comprising: a bank statement showing a liquidity challenge, documents supporting the size of liquidity needed, a list of collateral-eligible assets with their own supporting documents, a letter representing that all listed collateral assets were unencumbered, and a letter describing the bank’s ability to pay all obligations resulting from SFF use. Bank Indonesia could approve or deny any application for SFF use. Bank Indonesia’s decision to grant or deny SFF access was contingent on: the applicant bank meeting all SFF requirements, providing all necessary supporting documentation, and Bank Indonesia’s determination that the applicant bank would be unable to meet its reserve requirements based on forecasted 14-day cash flows in the absence of SFF funding (BI 2008c).

Once approved, the applicant bank and Bank Indonesia would sign an SFF agreement containing approval and an attached collateral agreement. All transactions associated with the SFF would be processed through the borrowing bank’s rupiah-denominated account at Bank Indonesia. When the SFF credit line matured, Bank Indonesia debited the borrowing bank’s (rupiah-denominated) account at Bank Indonesia the amount of the SFF lending plus interest (BI 2008c).

The Board of Governors of Bank Indonesia authorized the use of the SFF (Natalia 2014a). The BI Board consists of a governor, a senior deputy governor, and between four and seven deputy governors (President RoI 1999).

The House of Representatives (also known as the People's Representative Council)—Indonesia’s lower house of Parliament—ordered numerous audits by the SAA of the handling of Bank Century by Bank Indonesia, the FSSC, and the DIC (see Figure 1, Timeline). With respect to SFF liquidity, the SAA said that Bank Indonesia (a) had granted Bank Century access to the SFF in breach of applicable regulations; (b) had intentionally changed the CAR requirement in its SFF regulations from at least 8% to above 0% with the intention of specifically allowing Bank Century to access the facility; (c) used inappropriate CAR data (specifically, relying on outdated September data showing a CAR of 2.44% instead of October data showing a CAR of –3.35%) to allow Bank Century to access the (already amended) SFF; and (d) granted liquidity support to Bank Century while being secured by collateral representing only 83% of the lent SFF funds, whereas the regulations called for 150% collateralization (SAA 2011; SAA 2014).

Further, with respect to the determination of Bank Century as a failed bank with a systemic impact, the SAA said that the FSSC had predetermined to designate Bank Century as a failed bank with a systemic impact and made its determination without relying on accurate and complete data from Bank Indonesia on the true condition of the bank (SAA 2011; SAA 2014).

Bank Indonesia disclosed the use of the SFF by one private bank in its 2008 annual report but did not name Bank Century (BI 2009c). Bank Indonesia disclosed the regulations governing the SFF to the public through its website and issued a press release when it amended the SFF regulations (BI 2008c; BI 2008d; BI 2008i). Bank Indonesia issued two press releases—on November 13 and 14—about stresses in the banking system and said that Bank Century had experienced issues with clearing activities due to “a technical problem” (Nov. 13), later (Nov. 14) saying “a technical factor related to tardiness in prefund credit”—but did not disclose that it had provided SFF funding to Bank Century (BI 2008g; BI 2008h).

Bank Century said in a public statement on November 14 that its failure to participate in payments clearing on November 13 was a result of a technical delay in allocating prefund cash (Suharmoko 2008). Bank Century disclosed the short-term funding liquidity from Bank Indonesia through its monthly financial statements, 2008 annual report, and 2008 audited financial statements. Our research was unable to uncover press releases or other public communications from Bank Century with respect to SFF access (before its takeover by the DIC).

Bank Indonesia made numerous mentions of unfounded rumors and misinformation about Bank Century. In a November 13 press release, Bank Indonesia said, “it is hoped that the wider community will remain wise in responding to news whose sources are unclear” (BI 2008g). On November 14, Bank Indonesia issued a press release saying that rumors were spreading about the safety of the banking system and that such rumors were false:

In the same press release, Bank Indonesia said it would always be completely prepared to provide cash to banks all over the country and that it had activated the SFF in order to provide liquidity support to banks (BI 2008h).

Bank Indonesia disclosed the DIC takeover of Bank Century via a press release on November 21 (BI 2008k). Bank Indonesia included an attachment to that press release that disclosed that Bank Indonesia had provided Bank Century with access to the SFF; the press release also disclosed that the DIC intended to provide capital to Bank Century (BI 2008j). On the same day, the FSSC issued a press release communicating the FSSC’s determination that Bank Century was a failed bank with systemic impact (FSSC 2008). That day (November 21), Bank Indonesia and the DIC also issued a joint press release describing the DIC takeover (BI and DIC 2008). For more on the DIC’s capital injections, see the Appendix.

The maximum size of the SFF credit line was as much as the borrowing bank needed to fulfill its reserve requirement regulatory minimum (BI 2013). However, use of the SFF required posting collateral worth 150% of the loan value (see Key Design Decision No. 10, Balance Sheet Protection). Bank Century posted collateral covering only 83% of the loan value (see Key Design Decision No. 10, Balance Sheet Protection).

At the time, the primary reserve requirement^FNThere was also a supplementary secondary reserve requirement, which required an additional 2.5% coverage for third-party funds in the form of government securities (instead of the Bank Indonesia reserves required by the primary reserve requirement) (BI 2008b). for commercial banks in Indonesia was 5%, meaning that any commercial bank was required to hold a current account balance at Bank Indonesia equal to at least 5% of its liabilities (BI 2008b). Although day-to-day data was not publicly available, one independent scholarly estimate using a monthly banking report from October 2008 shows that Bank Century’s reserve ratio was 1.7%, leaving a roughly IDR 356.7 billion shortfall for the bank to reach the minimum 5% primary reserve ratio. By November, after drawing from the SFF facility, Bank Century’s reserve ratio rose to 5.4% (Kurniasari 2012).

During the course of its access to the SFF, Bank Century drew a total of IDR 689.4 billion in multiple tranches (see Figure 1, Timeline) (ICW 2009). The SFF lending was funded through Bank Indonesia’s balance sheet, where it showed the SFF Bank Century lending as an asset (claim on banks) (BI 2009c).

The SFF’s interest rate was the BI Rate^FNThe BI Rate was Bank Indonesia’s primary policy (or reference) rate at the time; Bank Indonesia replaced this rate with the BI 7-Day Reverse Repo Rate on August 19, 2016 (BI n.d.).  plus 100 basis points (bps) (BI 2008c, art. 14). Bank Indonesia charged interest only on the amount of the total facility drawn (used) by the borrowing bank (BI 2008c).

On November 14, when Bank Century first accessed the facility, the BI Rate was 9.5% (BIS 2023). Then, Bank Indonesia lowered the policy rate three times by 25 bps to 9.25% in December 2008, 50 bps to 8.75% in January 2009, and 50 bps to 8.25% in February 2009 (BIS 2023). Since the SFF rate was the BI Rate plus 100 bps, the rates on Bank Century’s SFF access ranged between 9.25% and 10.5%.

The SFF’s duration was 14 calendar days, renewable for no longer than 90 calendar days (from the signing of the agreement, not the disbursement of funds) (BI 2013). For the facility to be eligible for extension or renewal, (a) interest on maturing SFF funds had to be paid, (b) the borrowing bank had to be unable to meet its reserve requirement based on forecasted 14-day cash flows, and (c) the collateral had to remain sufficient (BI 2008c).

Bank Century rolled the facility from November 14, 2008, until February 11, 2009, or 90 days from the initial date, which was the maximum rollover period allowed by the regulation. The DIC paid off the SFF borrowing on February 11, 2009, after Bank Century received capital from the DIC’s Temporary Investment Facility (BI 2009c; ICW 2009).

By November 21, 2008, liquidity pressures had intensified on Bank Century, and customer perceptions of the bank had deteriorated (BI 2008j). On Friday, November 21, 2008, the FSSC declared Bank Century a failed bank with a systemic impact, and the DIC took over its operations (BI 2008k; FSSC 2008). Bank runs continued, and the DIC injected liquidity (later evaluated to be its capital injection or temporary equity participation) into Bank Century to maintain the bank’s operations in the face of depositor withdrawals. Of the IDR 6.8 trillion (roughly equivalent to Bank Century’s negative equity on November 20, 2008) injected by the DIC in 2008–2009, 59% (IDR 4 trillion) was used to backstop depositor withdrawals (DIC 2011). (See the Appendix for a description of the DIC’s special administration of Bank Century.)

On February 11, 2009, the DIC paid off all of Bank Century’s SFF obligations (BI 2009c). In 2013, at the request of Bank Indonesia, the DIC injected another IDR 1.2 trillion into the bank. In 2014, the DIC sold its shares of Bank Century (then named Bank Mutiara) to J Trust Co., Ltd. for IDR 4.4 trillion (a recovery rate of 55%) (DIC 2015).

Four days after it released SFF funds to Bank Century, Bank Indonesia also created a special Emergency Funding Facility for Commercial Banks (BI 2008f). Governor Boediono said that Bank Indonesia extended emergency credit under the SFF instead of the EFF because the EFF was not yet operational (but was previously authorized—on October 15—to operate as the main emergency funding facility for commercial banks; see Key Design Decision No. 3, Legal Authority) (Natalia 2014a).

Borrowing banks were required by regulation to provide collateral against SFF lending in the form of securities or credit assets. Eligible securities included (a) government securities or, in the event that the borrowing bank did not have adequate government securities, (b) actively traded investment-grade corporate securities with a duration of at least 90 days.

Collateral-eligible credit assets included those that satisfied the following conditions:

• Had liquidity for the past three months,
• Was not a consumption loan (with the exception of mortgage loans),
• Was not a loan related to parties of the borrowing bank,
• Was collateralized,
• Outstanding loan did not exceed loan ceiling and maximum loan extension on the time of disbursement, and
• Had a legally binding collateral and loan agreement. (BI 2008c)

Bank Indonesia applied haircuts for the SFF collateral. The collateral valuation was calculated as follows: 100% for Bank Indonesia certificates or Bank Indonesia Syariah certificates; 105% for government securities or state Syariah securities; 120% for eligible corporate securities; and 150% for credit assets (BI 2008c).

The SAA later found that Bank Indonesia granted liquidity support to Bank Century while being secured by collateral representing only 83% of the lent SFF funds, whereas the regulations called for 150% collateralization (SAA 2011; SAA 2014). According to Bank Indonesia regulations, the only way SFF collateral would be required by Bank Indonesia to be 150% was if the collateral were entirely composed of credit assets (BI 2008c).

Bank Indonesia disputed the allegation that posted collateral represented only 83% of the loan. In a 2009 press release, Bank Indonesia responded to that claim in a section titled, “Is it true that the value of collateral put forward by Century Bank upon receiving the [SFF] was only 83% of the ceiling and, therefore, insufficient to fulfill the requirement of 150%?” (BI 2009a). Bank Indonesia said that the IDR 689.4 billion loan was collateralized 150% by IDR 9.9 billion of government securities and IDR 1 trillion of credit assets (BI 2009a). Bank Indonesia said that the SAA’s 83% calculation was flawed because its calculation of credit assets used a methodology from a Bank Indonesia memorandum that itself was incorrect in the definition of credit assets eligible as SFF collateral (BI 2009a).

Bank Indonesia required that all collateral posted for the SFF was unencumbered at the time of pledging and that any borrowing bank could not trade or repledge the posted collateral. Bank Indonesia also required SFF borrower banks to periodically appraise posted collateral. In the event of a decrease in the value or liquidity of pledged collateral, SFF borrower banks were required by Bank Indonesia to add or replace collateral (BI 2008d).

In the event that the borrowing bank’s account at Bank Indonesia was insufficient to cover the debt from the SFF credit line, Bank Indonesia could seize the posted collateral and would continue to charge interest until the execution of collateral was complete. If the seized collateral’s value were less than the amount owed to Bank Indonesia for the SFF credit line, the borrowing bank would incur a liability against Bank Indonesia (and if the value were greater than the SFF debt, Bank Indonesia would pay back the difference) (BI 2008c).

The SAA later found that Bank Century had posted collateral worth only 83% of SFF funds, in contrast to the 150% required by regulation (SAA 2014).

Our research did not uncover any impact of the SFF lending to Bank Century on monetary policy transmission.

While using the SFF, Bank Century could not place funds at Bank Indonesia (BI 2013). Within five days of the disbursement of SFF funds, Bank Century was required to submit to Bank Indonesia a remedial action plan to overcome its liquidity challenges. Bank Indonesia required Bank Century to submit a report on its use of SFF funds and its liquidity position at the end of every business day (BI 2008c).

As a result of Bank Century’s use of SFF funds, Bank Indonesia had the authority to conduct an examination of Bank Century to supervise the use of the SFF funds. Any and all costs incurred by Bank Indonesia in providing SFF funding (including costs related to collateral execution) would be borne by Bank Century. If Bank Century (a) did not repay the SFF, (b) violated Bank Indonesia regulations governing the SFF, or (c) failed a Bank Indonesia examination of its use of SFF funds, then Bank Indonesia could impose sanctions on the bank including suspension of eligibility to the SFF for a prescribed period of time, a written warning, prohibition of rights to participate in clearing activities, suspension of some business activities, or dismissal of its management (BI 2008c).

Further, Bank Indonesia could impose sanctions on Bank Century’s management team if it failed to ensure compliance with SFF regulations or failed to provide required documentation to Bank Indonesia (BI 2008c).