Online lending apps have exploded in the Philippines because they promise “fast cash, no collateral, no hassle.” But many borrowers end up paying far more than they expected due to hidden fees, confusing add-ons, or terms that are disclosed only after approval. If you believe an online lending app misled you or charged unlawful or undisclosed costs, Philippine law gives you several complaint routes and remedies. This article walks through the full landscape: what counts as a violation, which laws apply, where to complain, what evidence to gather, what outcomes to expect, and practical tips to protect yourself.

1. When Hidden Charges and Misleading Terms Become Illegal

Not every fee is illegal. What’s unlawful is non-disclosure, deception, unfairness, or usury-type abuse. Common red flags:

Undisclosed fees
- “Processing,” “service,” “membership,” “insurance,” “VAT,” “platform,” or “collection” fees that were not clearly shown before you accepted the loan.
Misleading “interest” presentation
- Advertised as “0% interest” but loaded with fees that function like interest.
- Quoting daily or weekly rates without showing the effective annual interest rate (EIR) or total cost.
Bait-and-switch approvals
- App advertises one amount/rate but the approved loan shows higher rates or shorter terms, and the borrower only learns this late in the process.
Unfair contract terms
- Automatic add-ons you didn’t consent to.
- Penalties grossly disproportionate to delay.
- Clauses allowing the lender to change rates unilaterally.
Harassment or privacy violations tied to collection
- Threats, public shaming, contacting your phonebook, or using your data beyond what you authorized.

If any of these happened, you may have grounds for complaint.

2. Key Philippine Laws and Rules That Protect Borrowers

A. Lending Company Regulation Act of 2007 (RA 9474)

This law requires lending companies to register with the SEC and follow fair lending practices. The SEC has authority to suspend or revoke licenses for abusive schemes.

B. SEC Memorandum Circular No. 18 (Series of 2019) – “Rules on Online Lending Platforms (OLPs)”

This is the main rulebook for online lending apps. It requires:

SEC registration as a lending company and OLP.
Full disclosure of pricing, including interest, fees, penalties, and the method of computation before loan consummation.
No unfair collection practices, threats, or harassment. Apps violating these can be shut down or fined.

C. Truth in Lending Act (RA 3765)

Requires lenders to clearly disclose:

Interest rate
All finance charges
The total amount to be paid
Payment schedule Hidden charges or unclear disclosures can violate RA 3765.

D. Consumer Act of the Philippines (RA 7394)

Prohibits deceptive, unfair, or unconscionable sales/credit practices. Even if the lender isn’t a bank, deceptive offers can still be actionable as consumer fraud.

E. Civil Code Provisions on Contracts

Consent must be informed and voluntary.
Contracts obtained through fraud, mistake, intimidation, or undue influence may be voidable.
Courts can strike down unconscionable terms.

F. Data Privacy Act of 2012 (RA 10173)

If the app accessed, used, or shared your personal data (contacts, photos, messages) beyond legitimate purpose or without valid consent, you can file a separate privacy complaint.

G. Cybercrime Prevention Act (RA 10175) and Revised Penal Code

Threats, libelous shaming, or extortion during collection may also be criminally punishable.

3. Step-by-Step: How to File a Complaint

Step 1: Confirm if the App Is Legitimately Registered

Before anything else, verify whether the lender is a registered lending company and OLP. Many abusive apps are unregistered “loan sharks.”

If not registered → that’s already a major violation.
If registered → still complain for hidden charges or deception.

Step 2: Gather Evidence (This Is Crucial)

Your case rises or falls on documentation. Collect:

Screenshots / screen recordings
- Advertised rates/terms
- Application flow showing what was disclosed (or not disclosed)
- Approval page and final loan terms
- Breakdown of deductions from disbursed amount
Loan documents
- Promissory note
- Disclosure statement
- In-app contract
- Payment schedule If the app doesn’t provide a copy, screenshot everything you can see.
Transaction proof
- Bank/e-wallet statement
- Receipts
- Collection notices
Communications
- Emails, SMS, chat logs
- Calls (note date/time; record only if lawful and safe to do so)
- Threats or harassment evidence
Computation summary
- Amount applied for
- Amount actually received
- Total amount demanded for repayment
- What fees you discovered and when Calculate the effective cost.

Step 3: Attempt a Written Demand / Dispute (Optional but Smart)

Send an email or in-app message:

Identify undisclosed charges
Demand explanation and refund/recalculation
Request full disclosure documents Keep the tone factual. Save their reply. Even if they ignore you, it strengthens your case because you tried to resolve it.

Step 4: File the Proper Complaint(s)

You can file multiple complaints in parallel because different agencies cover different violations.

4. Where to File Complaints

A. Securities and Exchange Commission (SEC) – Primary Venue

Best for: hidden charges, misleading terms, illegal OLPs, abusive lending practices.

SEC regulates lending companies and OLPs. You can request:

Investigation
Suspension/closure of app
Fines
Refund/repricing orders (when warranted)

What to submit:

Your evidence package
Narrative affidavit describing what happened
App/company name, URL, and any SEC registration details you find

B. Bangko Sentral ng Pilipinas (BSP) – If the Lender Is a Bank/Fintech Under BSP

Best for: BSP-supervised financial institutions (banks, licensed e-money issuers, some fintech lenders).

If the online lender is under BSP supervision, BSP’s consumer protection unit can act.

C. Department of Trade and Industry (DTI)

Best for: deceptive marketing, unfair consumer practices.

Even if the lender isn’t under BSP, DTI may assist if the app’s advertising or consumer-facing representations are deceptive.

D. National Privacy Commission (NPC)

Best for: data misuse, downloading contacts, harassment via information leaks, unauthorized sharing.

If they:

accessed contacts without necessity,
sent messages to your friends,
used your photos or info to shame you,
kept data after account deletion, file with NPC.

E. Philippine National Police – Anti-Cybercrime Group (PNP-ACG) or NBI Cybercrime Division

Best for: threats, extortion, harassment, cyberlibel, identity misuse.

If collection tactics include:

threats of harm
blackmail
defamatory posts
impersonation report to cybercrime authorities.

F. Small Claims Court / Civil Case (for Refunds or Repricing)

Best for: getting money back or challenging unconscionable terms.

If the dispute is about money owed/refund, you may file a:

Small claims case (no lawyer required for qualifying amounts), or
civil action to rescind/void unfair contract terms.

5. Writing Your Complaint: What to Say

A strong complaint is structured and specific:

Background
- Date you applied
- Amount requested
- App name/company
- Loan term advertised
What you were shown before consent
- Interest/rate claimed
- Any fee disclosure (or lack of it)
What actually happened
- Amount received net of deductions
- Fees discovered later
- Total repayment demanded
- Any change from advertised terms
Why it’s illegal/unfair
- Non-disclosure (Truth in Lending + SEC OLP rules)
- Deceptive presentation (Consumer Act)
- Unconscionable charges (Civil Code)
- Any harassment/data misuse (SEC/NPC/Cybercrime laws)
Relief requested
- Investigation/sanctions
- Refund or recomputation
- Order to stop illegal practices
- Data deletion and collection restraint, if relevant

Attach all evidence in labeled files.

6. What Outcomes to Expect

SEC / NPC administrative actions
- fines
- license suspension/revocation
- app takedown
- orders to change practices These don’t always automatically refund you, but they pressure lenders and create a strong record.
Refund / recalculation
- possible via settlement, SEC mediation, or court order.
Criminal investigation
- if threats/extortion/privacy crimes are present.
Debt still exists, but may be reduced Hidden or unlawful charges can be nullified even if the core loan remains valid.

7. Practical Tips While Your Case Is Ongoing

Don’t delete the app or messages yet. Preserve evidence first.
Stop giving extra permissions. Revoke contact/photo/location permissions in your phone settings.
Pay only what is clearly due (if safe and you can). If you can identify the legitimate principal plus disclosed interest, keep records of any partial payments.
Do not be bullied into paying bogus add-ons. Harassment is itself a violation; document it.
Avoid negotiating by phone only. Get everything in writing.

8. Defenses Lenders Commonly Raise (and How to Counter)

“You agreed to the terms.” Counter: Consent must be informed. If fees were hidden or disclosed only after approval, consent is defective.
“Fees are not interest.” Counter: If fees function as finance charges not clearly disclosed, they fall under Truth in Lending disclosure requirements.
“You clicked ‘accept.’” Counter: Clickwrap is valid only if terms were clearly presented and not deceptive or unconscionable.
“Late fees are standard.” Counter: Penalties must be reasonable; excessive penalties are unconscionable.

9. Prevention for the Future

Borrow only from SEC-registered lenders.
Demand the disclosure statement before accepting.
Compute net proceeds and total repayment.
Avoid apps asking for contact list access.
Screenshot everything from the start.

10. Quick Checklist

Verify SEC registration
Screenshot ads, terms, approval, deductions
Save contracts, receipts, messages
Compute effective cost
Send written dispute (optional)
File with SEC (primary)
File with NPC if data abuse
File with PNP/NBI if threats/extortion
Consider small claims/civil case for refund

Bottom Line

In the Philippines, online lending apps must fully disclose all charges upfront and avoid deceptive marketing and abusive collection. Hidden fees and misleading terms are not just “annoying business practices”—they can violate SEC OLP rules, Truth in Lending law, consumer protection statutes, and privacy/cybercrime laws. The most powerful move you can make is to document everything and file with the SEC first, then add NPC or cybercrime complaints if privacy abuse or threats are involved.

If you want, I can draft a complaint affidavit template tailored to your facts (you can anonymize names/amounts).