The proliferation of online lending applications in the Philippines has provided quick access to credit for millions of Filipinos, but it has also spawned a parallel industry of predatory, unregistered, and outright illegal lending platforms. These entities routinely charge usurious interest rates (often exceeding 30–50% per month), impose hidden fees that balloon the effective cost to hundreds of percent annually, and employ debt-collection tactics that include public shaming, threats of violence, dissemination of morphed obscene images, and harassment of borrowers’ family members, employers, and contacts.

Such practices violate multiple Philippine laws, including the Lending Company Regulation Act (RA 9474), the Truth in Lending Act (RA 3765), the Cybercrime Prevention Act (RA 10175), the Data Privacy Act (RA 10173), the Financial Products and Services Consumer Protection Act (RA 11765), the Revised Penal Code provisions on grave threats, slander by deed, unjust vexation, and light coercion, and the Anti-Violence Against Women and Their Children Act (RA 9262) when gender-based psychological violence is involved.

This article comprehensively explains how to identify illegal lending apps, document violations, and file effective complaints with the proper government agencies. Following the correct procedures dramatically increases the chances of having the app blocked, the operators investigated, and, in many cases, obtaining personal relief such as cease-and-desist orders or criminal prosecution of collectors.

Identifying an Illegal Online Lending App

An online lending platform is illegal if any of the following is true:

It is not registered with the Securities and Exchange Commission (SEC) as a lending company or financing company.
It is not supervised by the Bangko Sentral ng Pilipinas (BSP) as a bank or quasi-bank offering digital loans.
It operates solely through mobile apps or websites without a disclosed physical office address and SEC registration number.
It charges interest rates, penalties, and fees that, when combined, exceed the disclosure requirements of the Truth in Lending Act or result in effective rates deemed usurious under jurisprudence (Indemnity Assurance Co. v. CA, 1997; Medel v. CA, 1998).
It requires access to the borrower’s contacts, gallery, SMS, or camera without legitimate purpose, or uses such access for harassment.

The SEC maintains an updated public list of registered lending and financing companies at https://www.sec.gov.ph/lending-companies-and-financing-companies-2/. Any app not on that list is operating illegally.

Common Illegal and Abusive Practices

Charging 10–50% interest per month plus processing fees of 10–20% upfront.
Automatic deduction of fees leaving the borrower with only 60–80% of the approved amount.
Imposing daily penalties of 1–5% on overdue amounts.
Threatening to file fabricated estafa cases.
Sending morphed pornographic images of the borrower to contacts.
Posting defamatory statements on social media.
Calling the borrower’s employer to cause termination.
Continuous calls and messages at odd hours (prohibited under SEC MC No. 18, s. 2019 and RA 11765).

All the above constitute unfair debt collection practices under Section 8 of RA 11765 and are criminally punishable.

Step-by-Step Guide to Reporting Illegal Lending Apps

1. Gather Evidence (Essential for All Complaints)

Screenshots of the app’s Google Play/Apple App Store page, loan offer, contract, payment demands, and harassment messages.
Copy of the loan agreement or terms and conditions.
Proof of payments made (GCash receipts, bank transfers).
Screenshots showing the app’s access permissions and any shaming posts.
Record of threatening calls (call logs + recordings if possible).

2. File with the Securities and Exchange Commission (SEC) – Primary Agency for Illegal Lending

The SEC has jurisdiction over all unregistered lending and financing companies.

Modes of filing:

Online: https://www.sec.gov.ph/online-submission-of-reports-complaints/ (choose “Complaint against Lending/Financing Company”)
Email: lcfrd_complaints@sec.gov.ph
Hotline: (02) 8818-6337
Walk-in: SEC Headquarters, Secretariat Bldg., PICC Complex, Pasay City

Required attachments:

Formal complaint letter (state facts, attach evidence)
Valid ID
Proof of loan and harassment

Outcome: The SEC can issue Cease and Desist Orders (CDO), block the app’s website, coordinate with Google/Apple for removal, and endorse to the NBI/DOJ for criminal prosecution.

3. File with the Bangko Sentral ng Pilipinas (BSP) – If the App Claims to be Bank-Affiliated

Even if the app is unregistered, file with BSP if it uses a bank’s name or if collections are made through bank channels.

Online: https://www.bsp.gov.ph/Pages/ConsumerAssistance.aspx → Consumer Assistance → File a Complaint
Email: consumeraffairs@bsp.gov.ph
Hotline: (02) 8708-7087

4. File with the National Privacy Commission (NPC) – For Data Privacy Violations

Illegal apps almost always violate the Data Privacy Act by:

Collecting excessive data (contacts, gallery)
Sharing personal data without consent for shaming

Online complaint: https://privacy.gov.ph/complaint/
Email: complaints@privacy.gov.ph
Hotline: (02) 8234-2228

The NPC can impose fines up to ₱5,000,000 per violation and order data deletion.

How to Report Harassing Debt Collectors

1. National Bureau of Investigation (NBI) Cybercrime Division – Most Effective for Criminal Harassment

The NBI treats online lending harassment as a priority crime.

File at:

NBI Cybercrime Division, Taft Ave., Manila
Any NBI regional office
Online: https://nbi.gov.ph/online-services/ → Cybercrime Complaint

Crimes usually charged:

Violation of RA 10175 (Cybercrime Prevention Act) – Online libel, threats, identity theft
Grave threats / light threats (Art. 282, 285 RPC)
Unjust vexation (Art. 287 RPC)
Slander by deed (Art. 359 RPC)
Violation of RA 10173 (Data Privacy Act)
Violation of RA 9262 (if psychological violence against women)

Bring all evidence. The NBI can immediately issue subpoenas to obtain subscriber information from telcos and social media platforms.

2. Philippine National Police Anti-Cybercrime Group (PNP-ACG)

File online: https://pcacg.pnp.gov.ph/e-complaint/
Hotline: 8723-0401 loc. 7491

3. Department of Justice (DOJ) – For Preliminary Investigation

After filing with NBI/PNP, cases are endorsed to DOJ prosecutors. You may also directly file a complaint-affidavit at the city/provincial prosecutor’s office.

4. Civil Action for Damages and Injunction

File a civil case for:

Damages under Articles 19, 20, 21, 26, 32, 33 of the Civil Code
Temporary Protection Order (if RA 9262 applies)
Injunction against further harassment

Venue: Regional Trial Court of your residence.

Additional Remedies and Protective Measures

Send a Formal Demand Letter to the lender/app operator (via email and registered mail) stating that the loan is void for being usurious or unregistered, and demanding cessation of collection and deletion of data.
File a Petition for Writ of Amparo or Habeas Data if there is threat to life, liberty, or security due to harassment (Rules on the Writ of Amparo, A.M. No. 07-9-12-SC).
Report the app to Google Play or Apple App Store for policy violation (harassment, privacy breach). Use the “Report” function and attach evidence.
Inform your telco (Globe/Smart) to block harassing numbers. They are required to act under NTC regulations.
If collectors contact your employer or family, have those persons execute affidavits; this strengthens the criminal case for alarming and scandalous acts.

Current Government Initiatives (as of November 2025)

The SEC, BSP, NPC, NBI, PNP, and DICT continue to implement the Inter-Agency Task Force against Illegal Online Lending.
Over 1,200 illegal lending apps have been blocked or removed since 2021.
Google and Apple now require Philippine lending apps to submit SEC registration before publication (policy implemented 2023–2024).
RA 11765 (2022) explicitly prohibits public shaming, use of obscene/vulgar language, contacting third parties without written consent, and collection calls outside 8:00 a.m.–7:00 p.m.

Final Recommendations

Act immediately. The longer you wait, the more difficult it becomes to preserve evidence.

Never pay another cent to an illegal lender once you discover its unregistered status; payments to unregistered entities are not legally required and may be recovered.

Keep copies of all complaints and reference numbers.

If you cannot afford a lawyer, approach the Public Attorney’s Office (PAO), Integrated Bar of the Philippines (IBP) Legal Aid, or the Commission on Human Rights for free assistance.

By systematically reporting through the channels above, borrowers have successfully obtained app removals, criminal convictions of collectors, and even monetary awards for moral and exemplary damages. The government’s enforcement machinery is now stronger than ever; use it.