Filing a Complaint Against an Online Lending App in the Philippines

A 2025 Comprehensive Legal Guide

Scope of this article

Focuses on consumer‐level “quick-cash” or “salary” loan apps offered by lending or financing companies (not banks).

Relies on Philippine statutes, SEC/NPC/BSP circulars, Supreme Court and DOJ issuances in force up to May 2025.

Procedures occasionally change; always check the latest forms or e-mail addresses before filing.

1. Why People Complain

Typical Abuse	Typical Law/Rule Violated
Harassment, threats, public shaming via text, calls or social-media blasts	SEC MC 18-2019 (Unfair Debt Collection Practices); RPC Arts. 282, 287; Cybercrime Prevention Act (RA 10175)
Contact-list scraping, disclosure of debts to friends, illegal camera/mic access	Data Privacy Act of 2012 (RA 10173) & NPC Circulars
Excessive interest, penalties or hidden “processing fees”	SEC MC 3-2022 (cap: 0.15 % per day interest & 5 % per month penalty for loans ≤ ₱10 000, ≤ 4 months)
Operating without a Certificate of Authority or with an unregistered app	Lending Company Regulation Act (RA 9474), Financing Company Act (RA 8556), SEC MC 10-2021 (OLP registration)
False claims (“BSP accredited”, “0 % interest”)	DTI Consumer Act (RA 7394) – deceptive sales

2. Know the Key Regulators

Regulator	Jurisdiction	What it can do	Where to complain
Securities and Exchange Commission (SEC)	All lending & financing companies; their Online Lending Platforms (OLPs)	Revoke license; issue Cease-and-Desist or Show-Cause Orders; impose fines; refer criminal cases to DOJ	✔ SEC Enforcement and Investor Protection Department (EIPD)
✔ CGFD‐FLC Division
📧 olp@sec.gov.ph
National Privacy Commission (NPC)	Data-privacy breaches by any entity	Investigate, summon, fine, order stoppage of processing, require damages	📧 complaints@privacy.gov.ph or NPC Portal
Bangko Sentral ng Pilipinas (BSP)	FinTech lenders that are banks, e-money issuers or “Buy-Now-Pay-Later” supervised firms	Direct refunds, fines, suspension; include lender in Negative File	BSP Consumer Assistance Management System (CAMS)
DTI Fair Trade Enforcement Bureau (FTEB)	Misleading ads, hidden charges for consumer loans	Admin fines; closure	FTEB Consumer Care Hotline
PNP Anti-Cybercrime Group / NBI CCD	Criminal harassment, libel, threats	Arrest, file criminal charges	Camp Crame / NBI Taft

3. Step-by-Step: How to File With the SEC

Gather Evidence
- Loan agreement, screenshots of the app page in Google Play, SEC registration screen, in-app chat, SMS, call logs, screen-recordings of harassment, bank receipts or e-wallet records.
- Print or export to PDF; label each file.
Prepare a Verified Complaint-Affidavit
- State facts chronologically (who, what, when, where, amounts).
- Allegations must be under oath (notarized or e-signed using Philippine digital-signing providers).
Attach Supporting Documents
- Valid government ID (front & back).
- Proof of authority if filing for a minor or relative.
- Screenshots & audio transcripts.
Send to SEC
- E-mail the PDF bundle to olp@sec.gov.ph (subject: “Complaint vs [App Name]”).
- Or file in person at the SEC Main Office (Philippine International Convention Center, Pasay) or any SEC Extension Office.
- No filing fee.
Track the Case
- SEC issues a Case Number within ~10 banking days.
- Watch for a Show-Cause Order sent to the app operator; you may be asked to appear via Zoom for clarifications.
- Typical timeline to decision: 30–90 days for straightforward violations; longer if contested.
Possible Outcomes
- Cease-and-Desist Order (CDO) – the app disappears from the Play Store.
- Revocation of Certificate of Authority – the company may no longer lend.
- Administrative Fines – ₱10 000 to ₱1 million per violation plus ₱2 000/day of continuing offense.
- Criminal referral to DOJ (imprisonment &/or fine under RA 9474).
- Restitution or refund of illegal charges (requires separate civil action if contested).

4. Filing a Data-Privacy Complaint With the NPC

Write to the App’s Data Protection Officer (DPO) first and demand deletion or correction of your data.
- The DPO must respond within 15 days.
If ignored or dissatisfied, file with NPC:
- NPC Complaint-Affidavit Form (download from npc.gov.ph).
- Attach proof of DPO notice & non-action, screenshots of privacy violation, ID, and location sketch (barangay clearance suffices).
Send via e-mail (≤ 10 MB) or NPC Portal; larger files by USB at NPC office (Privacy Hub, Diliman, QC).
NPC Mediation & Investigation
- Mediation conference within 30 days of docketing.
- If unresolved, formal investigation; possible Cease-Processing Order, fines up to ₱5 million per violation plus damages.

5. If the Lender Is a BSP-Supervised Entity

File online through BSP CAMS (sp.bsp.gov.ph).
Expect a reply within 7 working days; BSP may direct refunds or issue sanctions.
If still unresolved, elevate to BSP Consumer Protection & Market Conduct Sub-Sector for adjudication.

6. Criminal & Civil Remedies

Offense	Where to file	Prescriptive period	Penal range (typical)
Grave Threats, Unjust Vexation, Coercion	Office of the City/Provincial Prosecutor	1 year (for vexation), 10 years (for threats)	Arresto menor to prisión mayor; fines
Libel (public shaming)	Prosecutor, then RTC	1 year (from posting)	Prisión correccional &/or fine ≤ ₱1 000 000
Violation of RA 9474 (unlicensed lending)	SEC then DOJ	5 years	6 mos–10 yrs prison &/or ₱10 000–₱50 000 fine
Data Privacy crimes	DOJ (upon NPC referral)	3 years	up to 6 yrs &/or ₱5 million
Small Claims for refund ≤ ₱400 000	MTC/MeTC (Rule SC)	4 years	Purely monetary judgment, no lawyers needed

7. Template: SEC Complaint-Affidavit (short form)

REPUBLIC OF THE PHILIPPINES) PROVINCE/CITY OF ______) [Name], Complainant, v. [Lender Corp. / App Name], Respondent.

I, [Name], Filipino, of legal age, residing at ______, under oath depose:

On [date] I downloaded [App], owned by [Company], with SEC Reg. No. ____ (if any).

The app required intrusive permissions and subsequently sent 87 SMS and 43 calls between 6 March and 8 March 2025, threatening to broadcast my debt to contacts.

Respondent imposed interest of ₱500 on a ₱2 000 7-day loan (effective rate > 0.15 %/day) contrary to SEC MC 3-2022.

Respondent is liable for violations of RA 9474 and SEC MC 18-2019. PRAYER: Issue a Cease-and-Desist Order, revoke Respondent’s Certificate of Authority, and impose fines. IN WITNESS WHEREOF, I hereunto set my hand this 25 May 2025, Pasig City.

[Name] SUBSCRIBED & SWORN before me…

8. Practical Tips & FAQs

Question	Answer
Q: Can I stop paying while the case is pending?	The obligation still exists unless a court/SEC voids the contract. You may negotiate but document everything.
Q: The app is gone from Play Store—does that erase my debt?	Not automatically. Confirm if SEC ordered rescission; otherwise the underlying loan may still be collectible-–but penalties charged during the illegal period can be disputed.
Q: Can I sue for moral damages due to anxiety and humiliation?	Yes, in a civil action (Regular RTC) or as actual/temperate/moral damages annexed to a criminal case.
Q: How long does the NPC process take?	Mediation usually 30-45 days; full decision 3-9 months.
Q: My contacts were spammed—can they also complain?	Yes. Any data subject whose information was processed without lawful basis has standing before the NPC.

9. Checklist Before Hitting “Send”

✅ Written, notarized, chronological narrative
✅ Screenshots labeled with date/time stamps
✅ Audio/video transcripts (with consent to record)
✅ Government ID & proof of residence
✅ For NPC: Proof you contacted the DPO first
✅ For BSP: Reference/transaction numbers and Statement of Account
✅ All files in one zipped folder ≤ 10 MB or cloud link (set to View-only)

10. Final Words

The Philippine regulators have radically tightened oversight of online lending since 2019. While abuses persist, borrowers now have swift administrative avenues—backed by real enforcement teeth—to stop harassment, claw back illegal charges, and even send rogue operators to jail. Assert your rights, document every interaction, and escalate promptly. If in doubt, consult the Integrated Bar of the Philippines (IBP) for free legal aid or approach your local Public Attorney’s Office.

This article is for general guidance and does not constitute legal advice. For situations involving large sums, complex fraud or cross-border lenders, engage a lawyer experienced in fintech regulation and litigation.