The rise of Financial Technology (FinTech) in the Philippines has facilitated easier access to credit. However, it has also birthed a predatory ecosystem of unlicensed or non-compliant Online Lending Applications (OLAs). These entities often employ "shaming" tactics, threats, and unauthorized data processing to coerce repayment.

Under Philippine law, these actions are not merely unethical; they are criminal.

1. The Legal Framework

Victims of OLA harassment are protected by a suite of laws and administrative issuances designed to curb abusive collection practices and protect data privacy.

SEC Memorandum Circular No. 18 (Series of 2019): This is the primary regulation prohibiting unfair debt collection practices. It explicitly forbids the use of insults, profanity, violent threats, and the disclosure of a borrower’s debt to third parties (except under specific legal conditions).
Republic Act No. 10173 (Data Privacy Act of 2012): Most OLAs commit violations by accessing a borrower's contact list and gallery without a legitimate purpose, or by "contact-shaming" persons who did not consent to be co-makers or references.
Republic Act No. 10175 (Cybercrime Prevention Act of 2012): Threats, online libel, and "cyber-squatting" or identity theft fall under this jurisdiction.
Revised Penal Code: Harassment may escalate to Grave Coercion, Unjust Vexation, or Threats, all of which are punishable by imprisonment.

2. Defining "Unfair Collection Practices"

The Securities and Exchange Commission (SEC) identifies the following as prohibited acts:

Use of Threat or Violence: Any suggestion of physical harm to the debtor or their family.
Profanity and Insults: Using obscene or humiliating language to shame the borrower.
Disclosure of Information: Contacting people in the borrower’s phone book who are not co-makers to inform them of the debt.
False Representation: Claiming to be a lawyer, a court official, or a police officer to intimidate the borrower with "arrest warrants" (which are not issued for simple non-payment of debt).
Contacting at Unreasonable Hours: Sending messages or calling between 10:00 PM and 6:00 AM, unless the borrower gave prior consent.

3. Step-by-Step Action Plan for Victims

Step A: Document Everything

Do not delete the messages. Take screenshots of:

The threatening texts or chats (ensure the mobile number/sender ID is visible).
Call logs showing the frequency and timing of calls.
The OLA’s profile on the App Store or Google Play Store.
Proof of any unauthorized posts made on social media regarding your debt.

Step B: Assert Your Rights

Send a formal (written) notice to the OLA via their official email address. State that their collection methods violate SEC MC No. 18 and the Data Privacy Act. Demand that they cease contacting third parties who are not part of the loan contract.

Step C: File a Complaint with the SEC

The SEC’s Corporate Governance and Finance Department (CGFD) handles complaints against lending companies.

Check if the OLA is registered. If they are not on the SEC’s List of Licensed Lending/Financing Companies, they are operating illegally.
Submit a formal complaint via the SEC website or through their dedicated email for OLA complaints (cgfd_complaints@sec.gov.ph).

Step D: File a Complaint with the NPC

If the OLA accessed your contacts or photos and used them to harass you, file a "Statement of Concern" or a formal complaint with the National Privacy Commission (NPC). The NPC has the power to order the shutdown of apps that violate privacy laws.

Step E: Report to the PNP Anti-Cybercrime Group (PNP-ACG)

If you receive death threats or are a victim of online libel (e.g., they posted your photo on Facebook labeling you a "scammer"), visit the nearest PNP-ACG office to file a criminal complaint for violations of the Cybercrime Prevention Act.

4. Debunking Common OLA Threats

OLAs often use "legal-sounding" threats that have no basis in Philippine law:

"We will file an Estafa case": In the Philippines, no one can be imprisoned for non-payment of a debt (Article III, Section 20 of the Constitution). Estafa requires "deceit" or "fraud" at the inception of the loan. Simple inability to pay due to financial hardship is a civil, not criminal, matter.
"A Sheriff is coming to your house to seize property": Only a court can issue a Writ of Execution after a full trial. A private lending company cannot unilaterally seize your belongings.
"You are Blacklisted from the DFA/NBI": OLAs do not have the authority to block your passport issuance or NBI clearance.

5. Summary of Key Agencies

Agency	Focus Area
Securities and Exchange Commission (SEC)	Licensing, interest rate violations, and unfair collection tactics.
National Privacy Commission (NPC)	Unauthorized access to contacts, photos, and "social shaming."
PNP Anti-Cybercrime Group	Grave threats, online libel, and identity theft.
Google/Apple Support	Reporting the app for "Predatory Lending" to have it removed from the store.

Note on Interest Rates: While the Philippines currently does not have a strict "Usury Law" cap on all loans, the Bangko Sentral ng Pilipinas (BSP) has imposed ceilings on interest rates and penalties for small-value, short-term loans (Circular No. 1133). If your OLA charges exorbitant daily interest, this may also be a ground for a complaint.