How to Check if an Online Lending App Is SEC-Registered in the Philippines
Online lending can be convenient—but only if you’re dealing with a lawful provider. In the Philippines, lending and financing companies must be registered with the Securities and Exchange Commission (SEC) and possess a Certificate of Authority (CA) before they can operate, whether offline or through an app or website. This article explains, in plain but precise legal terms, how to verify that status, what documents to look for, how to read them, the difference between lending vs. financing companies, common red flags, and what to do if you encounter an unregistered or abusive app.
The Legal Basics (Why Registration Matters)
Governing laws.
- Lending companies are governed by the Lending Company Regulation Act of 2007 (RA 9474) and its IRR.
- Financing companies are governed by the Financing Company Act of 1998 (RA 8556) and its IRR. Both laws require SEC registration as a corporation and a separate Certificate of Authority to operate as a lending or financing company.
Scope includes online activity. Operating “through any means”—including mobile apps, websites, social media, and online marketplaces—is covered. An app cannot legally solicit or grant loans in the Philippines without an SEC CA issued to the corporate entity behind that app.
Consequences of non-registration. The SEC may issue cease-and-desist orders, revoke registrations/authorities, recommend criminal prosecution, and impose administrative sanctions. Using an unregistered app exposes borrowers to abusive practices and unenforceable terms.
Step-by-Step: How to Verify an App’s SEC Status
1) Identify the Exact Corporate Name Behind the App
Apps often show a brand or product name that does not match the legal corporate name. Find the corporate identity by checking, within the app or its store listing/website:
- “About,” “Legal,” “Terms of Service,” or “Privacy Policy”
- Developer/Publisher name and registered office address
- Any mention of SEC Registration Number and Certificate of Authority (CA) number (Tip: a genuine company usually discloses its CA number along with the SEC Registration Number and date of issue.)
If the app refuses to disclose its corporate name, treat it as a red flag (see below).
2) Confirm Corporate Registration and the Certificate of Authority
Verification has two layers:
Corporate registration with the SEC (as a corporation).
- Evidence: SEC Certificate of Incorporation (or Amended Articles).
- Check that the corporate name you found in Step 1 matches the name on the certificate.
Certificate of Authority to Operate as Lending or Financing Company.
- Evidence: SEC Certificate of Authority (CA) stating the line of business (lending/financing), the exact corporate name, date of issue, and sometimes conditions.
- No CA = not allowed to operate as a lender, even if the entity is otherwise a duly registered corporation.
Match the names exactly. A Certificate of Authority issued to “ABC Lending Corporation” does not authorize “ABC Lending App,” “ABC Tech,” or any affiliate unless the legal corporate name is identical. Watch for misspellings, extra words, or swapped order of words.
3) Check Status: Active, Suspended, Revoked, or Expired
Even a previously licensed entity may later be suspended or revoked. Review whether the CA is:
- Active/valid (good standing).
- Suspended/Revoked (cannot operate).
- Expired (if the CA shows a validity period and it lapsed).
If an app shows only a corporate registration but no CA, or shows a revoked/expired CA, it is not authorized to lend.
4) Verify the Company’s Online Lending Platform (OLP) Disclosure
The SEC has required additional disclosures and oversight for companies using online lending platforms (OLPs). A compliant lender typically:
- Discloses its corporate name, SEC Registration Number, and CA Number prominently in the app, website, and marketing channels;
- Shows full contact details (not just an in-app chat);
- Provides clear, lawful pricing (interest, fees, penalties) and complaint channels.
If the app’s legal identity is missing or inconsistent across materials, reconsider.
5) Cross-Check for SEC Advisories or Orders
The SEC regularly issues advisories identifying entities soliciting or operating without the required registration/authority, as well as cease-and-desist or revocation orders. If the entity (or its aliases) appears in such advisories, avoid the app entirely.
(Because advisories sometimes use alternate names, also search for the brand name, trade name, previous names, and the names of directors/beneficial owners if disclosed.)
How to Read SEC Numbers and Papers You’re Shown
SEC Registration Number (corporate registration) Proves that the corporation exists under Philippine law. This alone does not permit lending.
Certificate of Authority (CA) Number Confirms permission to operate as a lending or financing company.
- Check: exact corporate name, date, and type (lending vs. financing).
- A genuine certificate bears SEC signatures/seals and is not a mere “application filed” or “for renewal” notice.
Trade Names/DBAs A lender may use a brand/trade name, but the CA remains tied to the exact corporate name. If the app’s brand differs, the app and T&Cs should still state “operated by [Exact Corporate Name], SEC Reg. No. ___, CA No. ___.”
Lending vs. Financing Companies (Why It Matters)
- Lending companies generally use their own funds to grant loans to the public (often small-ticket/consumer loans).
- Financing companies may engage in credit extension including consumer/enterprise financing (e.g., installment sales, factoring, lease-to-own), broader than typical “lending company” activity.
Either way, both must have a CA from the SEC before offering credit to the public, including via an app.
Practical Checklist Before You Borrow
- Find the company’s exact corporate name.
- Get both numbers: SEC Registration Number and CA Number.
- Confirm the CA is valid/current and issued to that exact corporate name.
- Look for clear disclosures: address, phone/email, grievance officer, and pricing.
- Review terms: interest, fees, penalties, repayment schedule, cooling-off/cancellation (if offered), and collection practices.
- Check for advisories or sanctions naming the company, its app, or its owners/directors.
- Assess data practices: Does the app ask for contact-list access, photos, geolocation without clear purpose? Risky.
- Keep evidence: screenshots of disclosures, certificates, and terms; receipts or payment confirmations.
Red Flags That Often Signal an Unregistered or Non-Compliant App
- No corporate name anywhere—only a brand or chat handle.
- No CA number disclosed; evasive when asked for it.
- Mismatch between app brand and certificate corporate name.
- Harassment/“shaming” tactics (e.g., contacting your phone contacts).
- Blank or copy-pasted privacy policy, foreign jurisdiction law/venue, or impossible contact details.
- Forced permissions (contact list, gallery) unrelated to loan underwriting.
- Unclear or shifting fees and due dates.
- Collections via personal accounts (non-corporate e-wallet/bank accounts).
- Threats of criminal cases for mere non-payment of civil debt (misrepresentation of legal remedies).
Related Compliance Signals (Helpful but Not a Substitute)
- Data Privacy Act (DPA) compliance. Reputable lenders register/process personal data in accordance with the DPA and publish a compliant privacy notice.
- Consumer protection alignment. Clear pricing, receipts, and an internal grievance process suggest better compliance culture.
- Store listing hygiene. Official listings on app stores typically show a consistent developer identity, support email, and website.
Important: These are not substitutes for an SEC CA. A polished app without a CA is still illegal to operate as a lender.
Frequently Asked Questions
Q: The app told me its “SEC registration number.” Is that enough? No. You need to see or confirm the Certificate of Authority (CA) to operate as a lending or financing company.
Q: The app’s CA shows a different corporate name from the brand. Is that okay? It can be okay only if the CA’s corporate name matches the company that actually operates the app, and the app/terms clearly state that “[Brand] is operated by [Exact Corporate Name] (SEC Reg. No. ___, CA No. ___).” If the operator’s identity is not clear, don’t proceed.
Q: The app is a “marketplace” connecting me to third-party lenders. Who needs the CA? The lender extending credit must have a CA. Depending on the model, the platform may also be subject to SEC oversight and disclosure rules. Ask the platform to identify the actual lender and verify that lender’s CA.
Q: The app says its CA is ‘under renewal/processing.’ Can it lend now? No. A pending application or renewal does not authorize lending.
Q: What if the app is run by a bank or a subsidiary of a bank? Banks are supervised by the Bangko Sentral ng Pilipinas (BSP) under separate licensing. If a non-bank entity is the lender, it still needs an SEC CA.
What to Do If You Suspect an Unregistered or Abusive App
- Stop sharing data and avoid further payments to personal accounts.
- Document everything (screenshots of the app, conversations, certificates shown, payment proofs, harassment).
- File a complaint with the SEC’s enforcement unit and, where applicable, with the National Privacy Commission (NPC) for privacy abuses and with law enforcement for threats/harassment.
- Inform your contacts if the app already accessed your phonebook to minimize the risk of “shaming” attempts.
- Consider legal counsel if you’ve suffered damages or continuing harassment.
Note on debts: Even if a lender is unregistered, that does not automatically erase the underlying civil obligation, but it does affect enforceability of illegal fees/collection practices and exposes the operator to sanctions. Get advice if large amounts are involved.
Borrower’s Mini-Script (Use This When Chatting With an App)
“Before I proceed, please confirm: (1) the exact corporate name operating this app; (2) your SEC Registration Number; (3) your SEC Certificate of Authority Number (lending or financing) and date of issuance; and (4) a link or copy of your Terms of Service and Privacy Policy showing the same corporate name. I will only continue once I can verify these.”
If they refuse or stall, that’s your answer—walk away.
Key Takeaways
- An online lending app is legitimate only if the corporate entity behind it is SEC-registered and holds a valid Certificate of Authority to operate as a lending or financing company.
- Names must match exactly; a brand/trade name must trace back to the same corporate name shown on the CA.
- No CA, no lending—regardless of how sleek the app is.
- Protect yourself by verifying documents, checking for advisories/sanctions, and keeping records.
- Report unregistered or abusive operators. Your action helps clean up the ecosystem for everyone.
This article provides general information for the Philippine context as of today and is not a substitute for tailored legal advice. Regulations evolve; always verify current requirements directly with the SEC when making borrowing decisions.