How to Check a Lending Company’s SEC Registration Status in the Philippines
This practical legal guide explains how to verify—properly and defensibly—whether a Philippine “lending company” is duly registered and authorized by the Securities and Exchange Commission (SEC). It’s written for consumers, in-house teams, compliance officers, and counsel. Philippine law cited is current as of mid-2025, but always confirm if rules have changed.
1) Why this matters (the legal baseline)
You need two things, not one. Under the Lending Company Regulation Act of 2007 (Republic Act No. 9474) and its IRR, a corporation that does lending as a business must have: (a) a Certificate of Incorporation (general SEC registration), and (b) a Certificate of Authority (CA) to Operate as a Lending Company issued by the SEC. The CA—not just the incorporation—is what legally allows the company to lend to the public.
Who does not fall under “lending companies”?
- Financing companies (Republic Act No. 8556) are similar but governed by a separate law; they also need an SEC Certificate of Authority—just under the financing regime.
- Banks and quasi-banks are licensed by the Bangko Sentral ng Pilipinas (BSP), not the SEC.
- Cooperatives are registered with the Cooperative Development Authority (CDA) and may lend to members under coop rules.
- Microfinance NGOs remain corporations with SEC registration but are certified under the Microfinance NGOs Act (RA 10693) through the MNRC.
Sole proprietors and partnerships cannot be “lending companies.” RA 9474 requires the entity to be a corporation. If someone claims to be a “lending company” but gives you a DTI business-name certificate (for a sole prop) or a partnership certificate, that’s a red flag.
2) What “good standing” usually looks like
A legitimate, active lending company can typically show you, within minutes:
- Corporate name (exact SEC-registered name), and any registered business/brand names (DBAs);
- SEC Registration No. (from the Certificate of Incorporation);
- SEC Certificate of Authority No. as a Lending Company (with issuance date);
- Principal office address (must match what appears on SEC filings);
- Latest General Information Sheet (GIS) filed with SEC, naming directors/officers; and
- If operating digitally, registered Online Lending Platform (OLP) name(s) that match the app/website branding, with required disclosures (corporate name, SEC Reg. No., CA No.) visible in the app/site and marketing materials.
Tip: A CA is generally effective until suspended/revoked; there’s no “annual renewal sticker.” You verify current validity by checking for revocation/suspension orders or advisories and by matching current operations to what the SEC has on file.
3) Step-by-step: How to verify status (defensible workflow)
Step A — Gather the exact identifiers
Ask the company to write (email/letterhead) the following and attach copies:
- Exact corporate name and any DBA/trade names used in ads/apps;
- SEC Registration No. (from incorporation certificate);
- SEC Certificate of Authority No. (as a Lending Company, not “Financing” unless it truly is one);
- Principal office;
- Names of directors/officers and compliance contact;
- If digital: Official app/website name(s) and any third-party service company operating the app.
Legitimate lenders provide these routinely. Reluctance is a warning sign.
Step B — Check public SEC records (two angles)
Company existence & profile. Use the SEC’s public company lookup / document-request portal to confirm:
- The corporate name exists and the SEC Reg. No. matches;
- The company type/classification indicates “Lending Company” (or “Financing Company,” if that’s what they actually are). You can also request copies of filings (e.g., Articles, GIS, Audited FS).
Authority to operate & enforcement status.
- Look for the Certificate of Authority in their filings or request a certified copy.
- Search SEC advisories / orders for any revocation, suspension, or show-cause actions naming the company or its app/brand names.
- For online lenders, check whether the OLP/app name is disclosed by the corporation and appears in SEC postings/advisories.
Practice point: Match brand/app names to the corporate name. Many noncompliant apps hide the true corporation or misuse another company’s numbers.
Step C — Validate documents & details
- Compare numbers and dates. The CA should identify the same corporation and address as the incorporation/GIS.
- Look for SEC security features (e.g., QR or control numbers on newer certificates). When in doubt, obtain a fresh SEC certification of records.
- Cross-check the office. A lending company is required to have a physical principal office; “virtual office only” is suspect for retail lending.
Step D — Confirm OLP compliance (if there’s a mobile app/site)
- SEC rules require prominent disclosure of the corporate name, SEC Reg. No., and CA No. in the app, website, and advertisements.
- The loan agreement inside the app must identify the registered corporation as the lender. If the counterparty in the e-contract is a different entity (e.g., a service contractor or foreign company), stop—this often indicates noncompliance.
4) What to ask from the lender (documents checklist)
- Certificate of Incorporation (SEC).
- Certificate of Authority to Operate as a Lending Company (SEC).
- Latest GIS (names of directors/officers; principal office; trade names).
- Sample loan agreement / disclosure statement (to confirm correct lender name).
- If digital: Statement listing all OLP/app names used in PH, plus app store links.
- Optional but helpful: Mayor’s/Business Permit, BIR registration, and confirmation of AMLC enrollment (many lending/financing companies are AMLA “covered persons”).
Red flag: “We are licensed by the BSP” (but they’re not a bank). Non-banks doing lending to the public need an SEC CA. BSP authority does not substitute for the SEC CA.
5) Common red flags (treat as high-risk until disproved)
- Uses only a DTI Business Name (sole prop) or partnership docs but markets itself as a “lending company.”
- Cannot produce a Certificate of Authority or gives a CA that belongs to a different company.
- App name or Facebook page shows a brand that doesn’t match the corporate name disclosed in the contract.
- Hidden address (no physical office), or address that differs from SEC filings with no documented change.
- Harassing or doxxing collection practices and “access to contacts/photos” permissions—often a sign of unregistered/rogue OLPs.
- Claims that “the CA expired but we are renewing”—CAs are generally until revoked/suspended; there’s no routine “expiry.”
- Foreign platform saying Philippine regulation doesn’t apply while targeting PH borrowers.
6) Special situations & how to handle them
Financing company vs lending company If the entity is actually a financing company, it needs a CA under RA 8556. Some market to consumers like lenders—that’s fine only if their SEC records say “Financing Company” and they hold the financing CA. Verify which they are.
Cooperatives lending to the public Coops may lend primarily to members under CDA rules. If a coop is lending to the general public, seek legal advice—this may stray into activities requiring SEC/BSP oversight.
Agents or service companies Tech or collection service providers may operate the app or call center—but the lender of record in the contract must be the SEC-authorized corporation. Ask for the services agreement (redacted) if roles are unclear.
7) How to document your verification (for audit & disputes)
Create a short due-diligence memo with:
- Screenshots/PDFs of the SEC lookup result and any SEC certifications obtained;
- Copies of the CA and incorporation certificate, and the latest GIS;
- Evidence that the app/site displays the required disclosures;
- If applicable, copies of SEC advisories showing no adverse actions (or noting any and how they were resolved);
- A one-page conclusion: “As of [date], [Company] appears/does not appear to be duly registered and authorized by the SEC as a Lending Company. Basis: [list].”
This file becomes your defense if something later proves wrong.
8) If you suspect an unregistered or abusive lender
- Stop transacting. Do not pay fees or grant data permissions.
- Preserve evidence. Save screenshots, chat logs, contracts, payment slips, and caller IDs.
- Report to the SEC (Enforcement/Investor Protection) and to your LGU and/or the National Privacy Commission if there’s data harassment.
- Consider criminal/civil remedies with counsel—RA 9474 sets penalties for operating without a CA and for other violations; SEC memoranda also prohibit unfair debt collection practices (e.g., harassment, shaming).
9) Quick reference: What you should see (at a glance)
- Corporate name: “_____ Lending Corp.” (exact, not just a brand)
- SEC Registration No.: e.g., “CS20xx-xxxxx” (incorporation)
- SEC CA No.: present, labeled for Lending Company
- Address: matches filings and disclosures
- Directors/Officers: per latest GIS
- App/Website (if any): prominently shows corporate name, SEC Reg. No., CA No. and loan disclosures; the contracting party is the same corporation.
10) FAQs
Q: Is a copy of the CA enough? A: It’s necessary but not sufficient. Also check authenticity (fresh SEC certification if unsure) and current status (no SEC revocation/suspension/advisories).
Q: The lender says, “We’re only a platform; the loans are from a partner.” A: Then the partner making the loans must be the corporation with the SEC CA, and the loan contract should be between you and that corporation. Verify both entities.
Q: Do I need a lawyer? A: Basic checks are DIY. Engage counsel if the amounts are material, the structure is complex (e.g., cross-border app), or you find any red flag.
Bottom line
To be legally allowed to lend to the public in the Philippines, a corporation needs both SEC registration and an SEC Certificate of Authority as a Lending Company. Verify the corporate identity, the CA, current enforcement status, and—if digital—the OLP disclosures and contracting party. Anything less than that is a risk you don’t need to take.
If you want, I can turn this into a printable checklist or a one-page SOP with signature blocks for your team.