The rise of Online Lending Applications (OLAs) and non-traditional financing has led to a surge in predatory lending practices and the operation of unlicensed entities in the Philippines. Filing a complaint against these "illegal" lenders requires a systematic approach, targeting specific government agencies based on the nature of the violation.

1. Defining "Illegal" Lending Entities

In the Philippines, lending and financing companies must be incorporated and obtain a Certificate of Authority (CA) to operate from the Securities and Exchange Commission (SEC). An entity is considered illegal if:

It operates without SEC registration.
It operates without a Certificate of Authority.
It engages in Unfair Debt Collection Practices, even if registered.

2. Grounds for Filing a Complaint

Complaints are generally categorized into three types of violations:

Regulatory Violations: Failure to disclose the true cost of the loan (Effective Interest Rate), lack of a CA, or operating under a different name than what is registered.
Unfair Debt Collection Practices: Harassment, shaming, threatening physical harm, or using profane language (per SEC Memorandum Circular No. 18, s. 2019).
Data Privacy Violations: Accessing phone contacts or galleries without consent and messaging people on the contact list to shame the borrower (per Republic Act No. 10173).

3. The Complaint Process: Step-by-Step

Step 1: Evidence Gathering

Before approaching any agency, document all interactions. This serves as the foundation of your legal claim.

Screenshots: Threatening text messages, emails, or social media posts.
Loan Documents: Disclosure statements, receipts, and the terms of service.
Transaction Logs: Dates and times of persistent calls or visits.

Step 2: Identification of the Appropriate Agency

Depending on the violation, you must file with the corresponding regulator.

Agency	Scope of Jurisdiction
SEC (CGFD)	Licensing, unauthorized lending, and unfair collection practices.
National Privacy Commission (NPC)	Unauthorized access to contacts, data breaches, and social media shaming.
Bangko Sentral ng Pilipinas (BSP)	Complaints against banks, pawnshops, and BSP-supervised financial institutions.
PNP-ACG / NBI-CCD	Cyber-harassment, identity theft, and grave threats.

Step 3: Filing with the SEC

For most OLAs and lending companies, the Corporate Governance and Finance Department (CGFD) of the SEC is the primary authority.

Check Registration: Verify if the company is listed on the SEC website’s list of registered lending/financing companies.
Submit a Formal Complaint: Use the SEC's online complaint portal or email cgfd_enforcement@sec.gov.ph.
Affidavit of Complaint: For formal prosecution, you may be required to submit a verified complaint or an affidavit detailing the violations of Republic Act No. 9474 (Lending Company Regulation Act) or Republic Act No. 8556 (Financing Company Act).

Step 4: Filing with the National Privacy Commission (NPC)

If the lender accessed your phone's contact list to harass your friends and family:

File a "Request for Mediation" or a formal complaint via the NPC website.
Reference NPC Circular No. 20-01, which specifically prohibits OLAs from accessing contact lists or galleries for debt collection.

Step 5: Criminal Complaints (PNP and NBI)

If there are death threats, hacking, or serious defamation:

Visit the Philippine National Police Anti-Cybercrime Group (PNP-ACG) or the National Bureau of Investigation - Cybercrime Division (NBI-CCD).
File a report for violation of the Cybercrime Prevention Act of 2012 (R.A. 10175).

4. Relevant Laws and Regulations

SEC Memorandum Circular No. 18 (Series of 2019)

This is the most critical regulation regarding debt collection. It prohibits:

The use or threat of use of violence or other criminal means to harm the physical person, reputation, or property of any person.
The use of obscenity or profane language.
Disclosure of the borrower’s name as a "delinquent" in public.
Contacting persons in the borrower's contact list (other than the designated guarantors).

Republic Act No. 3765 (Truth in Lending Act)

Lenders are required to provide a Disclosure Statement before the consummation of the loan. This must include the cash price, down payment, finance charges, and the effective annual interest rate. Failure to provide this is a punishable offense.

5. Summary of Contact Information

SEC CGFD: Email cgfd_enforcement@sec.gov.ph or visit the SEC Secretariat Building, PICC Complex.
NPC: Visit privacy.gov.ph for the complaints portal.
BSP Consumer Protection: Email consumeraffairs@bsp.gov.ph or message their "BOB" chatbot on Facebook.