How to Verify if a Lending Company Is SEC-Registered in the Philippines

This practical legal guide explains how to confirm a lender’s regulatory status, what documents to ask for, how to spot red flags, and which laws and agencies are involved. It is written for borrowers, compliance teams, and counsel assessing counterparties in the Philippines.

1) Why SEC registration matters (and what “registered” really means)

Under the Lending Company Regulation Act of 2007 (LCRA; Republic Act No. 9474) and its Implementing Rules and Regulations (IRR), no corporation may engage in the business of lending (i.e., granting loans for the use or consumption of money to the public) without both:

SEC Certificate of Incorporation (corporate existence), and
SEC Certificate of Authority (CA) to Operate as a Lending Company.

Key point: A plain “SEC Registered” claim often refers only to corporate registration. It is not enough. A lawful lender must hold a separate, current Certificate of Authority specific to “lending company” activities. Financing companies are similarly regulated under a separate law, but they also require a CA.

Banks and certain other entities (e.g., rural banks, thrift banks) are supervised by the Bangko Sentral ng Pilipinas (BSP), not by the SEC, and cooperatives are supervised by the Cooperative Development Authority (CDA). Make sure you’re checking the right regulator for the entity type you’re dealing with.

2) What to collect from the lender (document checklist)

Ask the lender to provide clear copies (front and back if applicable), or to show originals, of:

SEC Certificate of Incorporation – shows corporate name, SEC Registration No., and date of incorporation.
SEC Certificate of Authority (CA) – must explicitly authorize it “to operate as a lending company.” Check name match, number, and date/validity.
Articles of Incorporation & By-Laws – verify Primary Purpose includes lending consistent with RA 9474/IRR.
Latest General Information Sheet (GIS) – confirms current directors, officers, and principal office address.
Latest Audited Financial Statements (AFS) (filed with the SEC) – helps confirm ongoing operations and compliance.
Business/Mayor’s Permit and BIR Registration – local and tax registrations for the operating address.
If lending is conducted online or via a mobile app/website: proof of SEC compliance for online lending operations and any SEC-required disclosures (e.g., app or platform names actually used in the market).

Tip: The CA should be prominently displayed at the principal place of business and in customer-facing channels. Absence of a CA or refusal to provide it is a major red flag.

3) How to verify with the SEC (step-by-step)

Confirm the exact legal name. Use the name appearing on the CA or Articles of Incorporation (spelling, punctuation, “Inc.”/“Corp.”, and “Lending Company” descriptor if used).
Check SEC public records/channels. The SEC maintains public verification facilities and contact channels where you can confirm:
- Corporate registration details (name, SEC Reg. No., date, status), and
- Whether a Certificate of Authority to Operate as a Lending Company has been issued, remains valid, or has been revoked/expired.
Cross-check principal office and officers. Match the address and officers on the GIS/CA with what the company shows customers (website, branch signage, contracts).
Check for sanctions or revocations. Determine if the SEC has revoked or suspended the company’s CA, issued cease-and-desist orders (CDOs), or named it in advisories (e.g., for unregistered lending, abusive collection practices, or misrepresentations).
If lending is done online:
- Confirm the app/website names the company uses to solicit and collect loans match what was disclosed to the SEC.
- Ensure only the verified corporate entity is behind the app/website—not a “marketing” front or unrelated third party.

4) Distinguishing lending companies, financing companies, banks, MFIs, and cooperatives

Lending Company (RA 9474): Primarily grants loans using its own funds sourced from shareholders or borrowings. Needs SEC CA.
Financing Company (separate law): Also SEC-regulated; typically finances purchases (installments, leasing). Needs SEC CA (but as a financing company, not a lending company).
Banks (BSP-supervised): Don’t rely on SEC CA for lending; verify via BSP.
Microfinance NGOs (MF-NGO): Covered by the Microfinance NGOs Act (with separate accreditation); not “lending companies.”
Cooperatives (CDA-supervised): May extend credit to members; verify with CDA, not SEC.

Mismatch example: A corporation shows an SEC Certificate of Incorporation for a trading business, but markets itself as an online lending app—without an SEC CA. That is unlawful lending.

5) Core legal standards to keep in mind

Form of organization: A lending company must be a corporation (not a sole proprietorship/partnership) to lawfully operate under RA 9474.
Minimum capitalization: The IRR prescribes minimum paid-in capital (commonly at least ₱1,000,000, higher in some cases), to be paid in at incorporation (or as required by the SEC).
Corporate name and purpose: The name and Primary Purpose clause must align with the LCRA.
Certificate of Authority: Separate from the Certificate of Incorporation; mandatory before commencing lending.
Display and disclosure: The CA and key business details must be displayed at the principal office and disclosed in customer-facing materials.
Reporting & compliance: Timely filing of GIS and AFS with the SEC; compliance with anti-money laundering (if applicable), consumer protection, data privacy, and truth-in-lending requirements.
Debt collection conduct: Abusive, harassing, or shaming collection practices can trigger SEC enforcement and Data Privacy Act (DPA) liabilities, among others.
Interest and charges: While the Usury Law ceilings are suspended, lenders must still comply with disclosure, unfair practice prohibitions, and any applicable sector-specific caps or guidance. Hidden fees and misleading APRs are red flags.

6) Red flags that a “lender” is not lawfully SEC-registered

Uses only a generic “SEC Registered” claim but cannot show a Certificate of Authority to Operate as a Lending Company.
Entity type mismatch (e.g., sole proprietorship) or corporate documents that don’t mention lending as a purpose.
Different names for the corporate entity, brand, app, and contracts, with no traceable linkage in SEC records.
Refuses to provide copies of SEC documents or claims they are “confidential.”
Revoked/expired CA or prior CDOs/advisories for the same entity or its affiliates.
Abusive collection (public shaming, threats, doxxing), excessive permissions demanded by apps, or undisclosed data sharing—often associated with illegal lending operations.
Unrealistic pricing (very high, undisclosed fees; “zero-interest” marketing with heavy penalties) and forced ancillary products.

7) Practical verification workflow (borrowers & counterparties)

Name & ID capture: Get the borrower-facing trade name(s), exact corporate name, SEC Registration No., and CA number.
Document review: Check CA + Articles (purpose) + GIS + AFS + Mayor’s Permit + BIR.
Regulator check: Confirm status with the SEC through its public verification facility or official contact channels.
Sanctions sweep: Look for revocations/CDOs/advisories.
Online operations: If an app or website is used, ensure it is the same as disclosed to the SEC and that privacy/collection practices are lawful.
Contract review: Confirm disclosures (amount financed, total finance charge, schedule, APR/nominal rates, fees, penalties, cooling-off/withdrawal rights if any).
Final risk call: If anything is inconsistent, do not proceed or proceed only with enhanced safeguards.

8) What to do if verification fails or you suspect illegal lending

Stop engaging and do not share more personal data.
Report to the SEC (Enforcement and Investor Protection Department) with copies/screenshots of ads, messages, contracts, app names, and IDs used.
If there are privacy violations (contact scraping, harassment, unauthorized disclosure), file a complaint with the National Privacy Commission (NPC).
If threats, extortion, or harassing conduct occur, consider reporting to the PNP/ NBI.
Keep evidence: screenshots, call logs, payment records, and copies of IDs they demanded.

9) Special notes on online lending and apps

Same rules, extra scrutiny. Operating online does not remove the CA requirement.
App/brand transparency. The brand or app name presented to the public should trace back to the SEC-authorized corporate entity.
Data privacy compliance. Apps must request only necessary permissions; mass contact scraping, gallery access without necessity, or broad background data collection is suspect.
Collections. Digital communications must still be lawful, proportionate, and respectful; “contact-list blasting” or public shaming is unlawful and sanctionable.
Third-party service providers. If collections or onboarding are outsourced, the lender remains responsible for compliance.

10) Sample email template to verify SEC registration

Subject: Verification of SEC Registration and Certificate of Authority

Dear [Lender’s Compliance/Legal Team],

We are conducting due diligence and would like to confirm your authorization to operate as a lending company in the Philippines. Kindly provide the following:

Copy of your SEC Certificate of Incorporation and SEC Certificate of Authority to Operate as a Lending Company;

Latest General Information Sheet (GIS) and Audited Financial Statements filed with the SEC;

Principal office address and contact person for regulatory matters;

If applicable, the list of active app/website names you use in offering loans.

Please also confirm that none of these authorizations have been revoked, suspended, or are subject to any CDO, and that you are in good standing with the SEC.

Thank you, [Your Name / Company]

11) Frequently asked questions

Q: The company shows a Certificate of Incorporation but no CA. Is that legal? A: No. Engaging in lending requires a CA from the SEC under RA 9474.

Q: The lender says it is “partnered with” a registered company. Is that enough? A: No. The entity dealing with the public must itself be properly authorized. “Piggy-backing” on someone else’s registration is non-compliant.

Q: The brand name is different from the corporate name. A: That’s allowed if properly disclosed and tied to the authorized entity, but it’s a due-diligence trigger. Make sure the brand/app is traceable to the CA-holding corporation.

Q: Are sole proprietors allowed to be lending companies? A: No. RA 9474 requires a corporation to operate as a lending company.

Q: Interest seems high. Is there a legal cap? A: Usury ceilings have been suspended, but lenders must comply with disclosure and consumer-protection rules. Excessive, undisclosed, or deceptive charges can be sanctioned.

12) Bottom line (quick checklist)

□ Corporate registration found and current
□ Certificate of Authority to Operate as a Lending Company confirmed and current
□ Primary Purpose includes lending; minimum capital satisfied
□ Sanctions check: no revocation/CDO/advisories
□ Officers/Address match GIS and business reality
□ If online: app/website names match what’s disclosed to regulators
□ Contracts show clear loan terms, full charges, and compliant collection practices

When in doubt, don’t rely on claims or marketing materials—verify the CA and the entity behind the brand.