In the Philippines, the rise of Financial Technology (FinTech) has brought convenience through Online Lending Applications (OLAs). However, this convenience is often overshadowed by a predatory practice: harassment before the loan’s due date.

Many borrowers find themselves targeted by "collections agents" days before a payment is even late. If you are experiencing threats, shaming, or incessant messaging despite not being in default, you have clear legal avenues for protection and redress.

1. Understanding the Violation: When is it Harassment?

Under Philippine law, lending companies and their third-party collectors are strictly prohibited from engaging in unfair collection practices. Even if you owe money, you maintain your right to privacy and dignity.

Common forms of illegal harassment include:

Premature Threats: Threatening legal action, imprisonment (which is unconstitutional for debt), or physical harm before or even after a due date.
Contacting Your Contacts: Accessing your phone’s contact list to inform your friends, family, or employers about your debt (a major violation of the Data Privacy Act).
Social Media Shaming: Posting your photo, ID, or debt details on social media platforms.
Obscene/Insulting Language: Using profanity or demeaning language during calls or via text.
Anonymous Harassment: Using unregistered numbers to send threats to hide the identity of the collector.

2. The Legal Framework

Your complaints are backed by specific Philippine laws and circulars:

SEC Memorandum Circular No. 18 (Series of 2019): This is the primary regulation against "Unfair Debt Collection Practices." It explicitly prohibits harassment, threats, and the use of insults.
Republic Act No. 10173 (Data Privacy Act of 2012): This protects your personal information. If an app accesses your contacts without a legitimate purpose or shares your debt status with third parties, they are in violation.
Republic Act No. 10175 (Cybercrime Prevention Act of 2012): Covers online libel, cyber-threats, and computer-related identity theft.
NPC Circular 20-01: Specifically addresses the processing of personal data for debt collection, prohibiting the "contacting of persons in the borrower’s contact list" other than those named as guarantors.

3. Step-by-Step Guide to Filing a Complaint

Before filing, you must gather evidence. Do not delete messages. Take screenshots of:

The threatening text messages or emails (including the sender's number/address).
Call logs showing the frequency of calls.
Screenshots of social media posts or messages sent to your contacts.
A copy of your loan agreement showing the actual due date.

Step A: Report to the Securities and Exchange Commission (SEC)

The SEC regulates financing and lending companies. If the OLA is registered, the SEC can impose fines or revoke their license. If they are unregistered, the SEC works with law enforcement to shut them down.

Action: Email the Corporate Governance and Finance Department at cgfd_directors@sec.gov.ph or flcd_queries@sec.gov.ph.
Form: Use the "Complaint Form" available on the SEC website.

Step B: Report to the National Privacy Commission (NPC)

If the harassment involves your contact list or public shaming, the NPC is the correct body.

Action: File a formal complaint via the NPC’s online portal.
Focus: Emphasize the "unauthorized processing of personal information" and "malicious disclosure."

Step C: Report to the PNP Anti-Cybercrime Group (PNP-ACG)

For direct threats to your life, safety, or cases of online libel/grave threats.

Action: Visit the nearest PNP-ACG district office or report via their official Facebook page or website. You may be required to execute an affidavit.

Step D: The Google Play Store / Apple App Store

To help prevent others from falling victim, report the app on the platform where you downloaded it for "Harassment" and "Financial Scams."

4. Summary Table of Remedies

Agency	Type of Violation	Expected Outcome
SEC	Unfair collection practices, unregistered lending	Fines, suspension, or revocation of license
NPC	Accessing contacts, social media shaming	Cease and desist orders, criminal prosecution for privacy breach
PNP-ACG	Cyber-threats, Libel, Extortion	Criminal investigation and potential arrest

5. Important Reminders for Borrowers

"No one can be imprisoned for non-payment of debt." This is a fundamental right under Article III, Section 20 of the 1987 Philippine Constitution.

If a collector claims you will go to jail for a delinquent loan (especially one that isn't even due yet), they are lying to intimidate you. Filing a complaint does not absolve you of the debt itself, but it does stop the illegal methods used to collect it. Always check the SEC List of Recorded Lending Companies before borrowing to ensure the entity is legitimate.