How to Verify SEC Registration of Online Lending Apps in the Philippines

A practical legal guide (Philippine context)

TL;DR To legally lend to the public, a non-bank app must (1) be a corporation registered with the SEC, (2) hold a Certificate of Authority (CA) to operate as a lending or financing company, and (3) if it uses an app or website, its online lending platform (OLP) must be registered/authorized with the SEC under the same company. Anything less is illegal. Always cross-check the company, its CA status, and the specific app name against official SEC lists and advisories.

1) The Legal Framework (what the law actually requires)

Lending Company Regulation Act of 2007 (Republic Act No. 9474) Requires lending businesses to be corporations and to secure an SEC Certificate of Authority before operating. Sole proprietorships and partnerships cannot operate lending companies under this law.
Financing Company Act of 1998 (RA 8556, as amended) Covers financing companies (installment financing, factoring, leasing, etc.). They likewise need an SEC Certificate of Authority.
SEC rules on Online Lending Platforms (OLPs) SEC issued a series of memoranda (2019 onward) requiring: (a) registration/notification of OLPs used by licensed lenders/financiers; (b) clear disclosures (company name, SEC Reg. No., CA No., rates/fees); and (c) prohibitions on abusive debt collection (e.g., shaming, threats, contacting a borrower’s phone contacts).
Financial Consumer Protection Act of 2022 (RA 11765) Strengthens rules on fair treatment, transparency of costs, and complaint handling for SEC-supervised financial service providers.
Data Privacy Act of 2012 (RA 10173) Bars excessive data collection and harassment through misuse of personal information. Many OLP abuses (phone-contact scraping, public shaming) also trigger privacy violations.

Key point: “SEC-registered” incorporation is not enough. A lender/financier must have an active Certificate of Authority; the specific app/website it uses must be registered/authorized with the SEC and trace to that same company.

2) What “good” looks like (the proper compliance trail)

Corporate identity
- Exact corporate name (e.g., “ABC Lending Corporation”), principal office address, and SEC Registration No.
Authority to operate
- Certificate of Authority number (CA No.) and date of issuance (must be current and not revoked/suspended).
Online Lending Platform authorization
- The app/website name (e.g., the brand in the app store) should appear on SEC’s list of registered/authorized OLPs, mapped to the same licensed company.
Mandatory disclosures
- Prominent display of corporate name, SEC Reg. No., CA No., contact details (with a verifiable business address/landline or official email), total cost of credit (interest + fees), repayment schedule, and complaints channel.

3) Step-by-step: How to verify an online lending app

Identify the lender-of-record. In the app or app-store “Developer contact,” find the exact corporate name behind the app. Beware of generic brand names that don’t reveal a corporation.
Confirm the company has a valid SEC Certificate of Authority.
- Check the SEC’s public lists of Lending Companies with CA and Financing Companies with CA.
- Match: exact corporate name, SEC Reg. No., CA No., and status (active vs. revoked/suspended).
Confirm the specific app (OLP) is registered/authorized.
- Look up the SEC’s List of Registered/Authorized Online Lending Platforms.
- The app/brand name must appear and be linked to the same company you found in Step 2.
Screen for enforcement red flags.
- Search SEC Advisories, Cease-and-Desist Orders (CDOs), and Revocation lists for the company and the app name.
- If the company or app appears in these lists, avoid it.
Check the disclosures inside the app.
- Do they clearly show company name, SEC Reg. No., CA No., real address, and complete pricing (APR or total cost)?
- Hidden or vague pricing, or refusing to name the company, is a red flag.
Cross-check developer metadata.
- In Google Play/App Store, the developer/owner should match the SEC-licensed entity (or its disclosed affiliate). Mismatches are suspicious.
Evaluate collection and privacy practices.
- Demands for access to your contacts, photos, galleries, SMS, or threats of public shaming violate SEC/NPC rules. Treat these as illegal practices.

4) Practical red flags (treat as deal-breakers)

No CA No. (or they show a DTI certificate, business permit, or Barangay permit instead—those are not substitutes for a CA).
The app name is not on the SEC OLP list, or the listed company doesn’t match the brand you’re using.
Use of shell names or constantly changing developer identities; offshore addresses with no Philippine office.
Harassing collection (public shaming, contacting phone contacts, threats).
Up-front “processing” fees deducted from the proceeds, coupled with very short tenors and undeclared total cost.
Requests for excessive permissions (contacts, photos) or for screenshots of e-wallet/bank accounts unrelated to KYC.
Payment instructions pointing to personal e-wallets/accounts not in the licensed company’s name.

5) Common misconceptions

“They’re SEC-registered, so they’re legal.” Not necessarily. Incorporation ≠ authority to lend. You need to see an active CA, and the app must be an authorized OLP of that company.
“They showed a DTI certificate / Mayor’s permit.” These are not a legal basis to lend to the public. Lending/financing to the public requires an SEC CA.
“It’s okay if my contacts are scraped—it’s in the terms.” No. Unfair collection and privacy abuses can still be illegal even if buried in terms.
“Banks and co-ops must be on the SEC list.” Banks are supervised by the BSP (not SEC). Cooperatives lending to members are under the Cooperative Development Authority (CDA). Microfinance NGOs may be certified under a separate law. Most non-bank consumer lending apps, however, are SEC-supervised.

6) If you already used a suspect app

Do not share more data. Revoke app permissions (contacts/photos).
Document everything. Screenshots of the app page, disclosures, messages, payment receipts.
Pay carefully. If you intend to settle, pay only via official channels traceable to the licensed company (avoid personal wallets). Keep proof.
Report abuses. File a complaint with the SEC’s Enforcement and Investor Protection Department (EIPD). For privacy violations, complain to the National Privacy Commission (NPC). Threats/harassment can be raised with PNP-ACG or NBI-CCD under the Cybercrime Prevention Act (RA 10175).
Consider legal advice. Courts can strike down unconscionable interest/penalties; strategy varies case-by-case.

7) Due-diligence checklist (copy/paste)

Corporate name (exact): ______________________________
SEC Registration No.: ______________________________
Certificate of Authority (CA) No.: __________________ Date: __________
Company appears on SEC “Lending/Financing Companies with CA” list
App/brand name appears on SEC “Authorized OLPs” list, mapped to the same company
No SEC Advisory/CDO/Revocation hits for company or app name
Disclosures present in-app (company name, SEC Reg. No., CA No., address, email/landline)
Total cost of credit disclosed (interest + all fees) and repayment schedule
No excessive permissions (contacts/photos) or harassing collection language
Official payment channels are in the company’s name; receipts retained

8) Template: inquiry to an app’s support team

Subject: Request for SEC Registration & Authority Details

Please provide, for our due-diligence:

Exact corporate name and principal office address

SEC Registration No. (incorporation)

Certificate of Authority (CA) No. to operate as a lending/financing company, with date of issuance

Confirmation that the [App/Website Name] is an SEC-registered/authorized OLP of your company

A link or instructions to verify these details on the SEC’s official lists

Absent these, we will not proceed and may file a report with the SEC.

9) Final notes & cautions

The Usury Law ceilings were effectively lifted decades ago, but courts can reduce unconscionable rates/penalties. What is “unconscionable” depends on the facts.
Disclosure is non-negotiable: you should see the total cost of credit, not just a daily rate or a vague “service fee.”
Regulations evolve (especially on OLP registration and disclosures). Always re-check the SEC’s current lists and advisories before dealing with any app.

Disclaimer

This guide is general information for the Philippine setting and not a substitute for tailored legal advice. For specific issues (e.g., harassment, disputed balances, refunds), consult counsel or the relevant authorities.