I. Introduction

The rise of online lending applications has made borrowing faster, easier, and more accessible to many Filipinos. With only a smartphone, a valid ID, and a few clicks, a person may obtain a small loan without visiting a bank or lending office. However, this convenience has also created serious legal and consumer-protection problems.

Many borrowers report harassment, public shaming, unauthorized access to phone contacts, threats of criminal cases, excessive interest, hidden fees, misleading loan terms, and the use of fake or unregistered lending apps. Some lending apps operate legally but engage in abusive collection practices. Others are outright scams that collect processing fees, steal personal data, or use coercion to extract money.

In the Philippine context, the issue involves several branches of law: lending regulation, data privacy, cybercrime, consumer protection, criminal law, and civil remedies. A victim may have remedies before government agencies such as the Securities and Exchange Commission, the National Privacy Commission, the Bangko Sentral ng Pilipinas, the Department of Trade and Industry, the Philippine National Police Anti-Cybercrime Group, the National Bureau of Investigation Cybercrime Division, and the courts.

This article discusses what a lending app scam is, the rights of borrowers, the obligations of online lending companies, unlawful collection practices, data privacy violations, possible criminal and civil liability, and the remedies available to affected borrowers in the Philippines.

II. What Is a Lending App Scam?

A lending app scam generally refers to a fraudulent or abusive online lending scheme that deceives, exploits, or harasses borrowers. It may involve a fake lending platform, an unregistered lending company, or even a real lending company that uses unlawful methods.

Common forms include:

Fake loan approval scams The borrower is told that a loan has been approved, but must first pay a processing fee, verification fee, insurance fee, activation fee, or release fee. After payment, the supposed lender disappears or demands more money.
Identity theft lending scams The app collects the borrower’s ID, selfie, address, phone number, bank details, e-wallet information, or contacts, then uses the information for fraud, harassment, or unauthorized transactions.
Predatory microloan apps The app releases a loan much smaller than advertised, deducts excessive fees upfront, and demands repayment within a very short period at a high effective interest rate.
Harassment-based collection schemes The lender or collector threatens the borrower, sends defamatory messages to contacts, posts the borrower’s photo online, calls the borrower a scammer, threatens imprisonment, or uses shame as a collection method.
Unregistered online lending operations The company operates without proper registration, authority, or compliance with lending regulations.
Data-harvesting apps disguised as lenders The app’s real purpose is to obtain access to contacts, photos, messages, device information, or personal data, which may later be used for blackmail, phishing, or identity fraud.

Not every unpaid online loan is a scam. A borrower remains legally obligated to pay a valid loan. However, even when a debt is real, the lender has no right to collect through threats, humiliation, unauthorized disclosure of personal information, or other unlawful means.

III. Is Online Lending Legal in the Philippines?

Online lending is not illegal per se. A company may lawfully provide loans through a mobile application or digital platform if it is properly registered and compliant with Philippine law.

Generally, lending companies and financing companies are subject to regulation by the Securities and Exchange Commission. They must have proper corporate registration and authority to operate as lending or financing entities. Online lending platforms must also comply with applicable SEC rules, data privacy laws, consumer protection standards, and fair collection practices.

A legitimate online lender should be able to provide:

Its registered corporate name;
SEC registration details;
A physical business address;
Contact information;
Clear loan terms;
Disclosure of interest, fees, penalties, and total repayment amount;
A privacy notice;
A lawful basis for processing personal data;
A reasonable complaint mechanism; and
Transparent collection policies.

A lending app that hides its real operator, uses only anonymous phone numbers, refuses to disclose loan terms, or demands upfront fees before releasing funds should be treated with caution.

IV. Rights of Borrowers

Borrowers in the Philippines are not without protection. Even when a person owes money, he or she retains legal rights.

1. Right to clear and truthful loan terms

A borrower has the right to know the principal amount, interest rate, service fees, penalties, repayment date, and total amount payable. Hidden charges, misleading advertisements, and deceptive loan terms may give rise to complaints.

2. Right against unfair collection practices

A debt may be collected, but collection must be lawful. A lender or collector should not use threats, insults, obscenity, violence, intimidation, public shaming, or false representations.

3. Right to privacy and data protection

Borrowers have the right to know how their personal data will be collected, used, stored, shared, and deleted. A lending app should not access, upload, or use a borrower’s phone contacts, photos, or personal files without a valid lawful basis and proper consent where required.

4. Right against defamation and public shaming

A lender or collector has no right to tell the borrower’s employer, relatives, friends, co-workers, or social media contacts that the borrower is a scammer, criminal, thief, or fraudster. Such acts may give rise to civil, criminal, administrative, and data privacy complaints.

5. Right against false threats of imprisonment

Nonpayment of debt, by itself, is generally not a crime. A borrower cannot be imprisoned merely for failing to pay a loan. However, criminal liability may arise in separate cases involving fraud, falsification, identity theft, bouncing checks, or other criminal acts. Collectors who falsely threaten imprisonment merely to scare borrowers may themselves be engaging in abusive or unlawful conduct.

6. Right to file complaints before government agencies

Victims may file complaints with the SEC, NPC, PNP-ACG, NBI Cybercrime Division, DTI, BSP, or the courts, depending on the facts.

V. Common Illegal or Abusive Collection Practices

The following acts are commonly complained of in online lending cases:

Calling the borrower repeatedly at unreasonable hours;
Sending threatening, insulting, obscene, or humiliating messages;
Threatening to file fabricated criminal charges;
Threatening arrest, imprisonment, or police action without legal basis;
Contacting the borrower’s relatives, friends, co-workers, or employer;
Sending messages to the borrower’s phone contacts;
Posting the borrower’s photo or personal information online;
Labeling the borrower as a scammer, thief, estafador, or criminal;
Creating group chats to shame the borrower;
Using fake lawyer, police, court, or government agency identities;
Sending fake subpoenas, warrants, or demand letters;
Accessing phone contacts without proper authority;
Collecting from persons who are not parties to the loan;
Threatening physical harm;
Charging undisclosed or unconscionable fees; and
Continuing harassment after the borrower has disputed the loan or requested validation.

These acts may trigger liability under various laws, including lending regulations, the Data Privacy Act, the Cybercrime Prevention Act, the Revised Penal Code, consumer protection laws, and civil law principles on damages.

VI. Data Privacy Issues in Lending Apps

One of the most serious problems involving lending apps is unauthorized data access. Many apps ask for permission to access contacts, camera, storage, location, device information, and other data. Some borrowers grant permission without understanding the consequences.

Under Philippine data privacy principles, personal data must generally be processed fairly, lawfully, transparently, and only for legitimate purposes. The lender must collect only data that is necessary and proportionate to the declared purpose. It must also protect the data from unauthorized access, disclosure, misuse, and retention.

Problematic practices may include:

Accessing the borrower’s phone contacts without a lawful purpose;
Uploading contact lists to the lender’s servers;
Contacting third parties who did not consent to be involved;
Disclosing the borrower’s debt to relatives, friends, employers, or co-workers;
Posting the borrower’s personal data online;
Using personal photos for shame campaigns;
Retaining data after the loan has been paid or after the purpose has expired;
Sharing data with unknown collection agencies;
Failing to provide a privacy notice;
Using vague or forced consent; and
Making loan approval conditional on excessive device permissions.

A borrower may file a complaint with the National Privacy Commission when the lending app misuses personal data or unlawfully contacts third parties.

VII. Cybercrime and Online Harassment

Because lending app abuse often happens through mobile phones, messaging apps, social media, and online platforms, cybercrime laws may become relevant.

Potential cyber-related violations may arise where collectors:

Send threats through text, chat, or social media;
Use fake accounts to harass the borrower;
Post defamatory statements online;
Spread edited photos or false accusations;
Use stolen personal data;
Impersonate lawyers, police officers, court personnel, or government agencies;
Send phishing links;
Hack or unlawfully access accounts; or
Use electronic means to commit fraud.

Depending on the facts, complaints may be brought before the PNP Anti-Cybercrime Group or the NBI Cybercrime Division. Victims should preserve screenshots, URLs, phone numbers, account names, transaction receipts, and device records.

VIII. Possible Criminal Liability of Lending App Operators or Collectors

The specific criminal offense depends on the facts. Possible legal theories may include:

1. Grave threats or unjust vexation

If collectors threaten harm, public humiliation, legal action without basis, or other coercive consequences, they may be liable depending on the nature and seriousness of the threat.

2. Slander or libel

Calling a borrower a criminal, scammer, thief, or fraudster may be defamatory if the statement is false, malicious, and communicated to others. If committed through online means, cyberlibel may be considered.

3. Coercion

Forcing a borrower to pay through unlawful intimidation or pressure may potentially fall under coercive conduct.

4. Estafa or fraud

Fake lending apps that collect fees without intending to release loans may be liable for fraud, depending on proof of deceit and damage.

5. Identity theft or misuse of personal information

If the app uses a borrower’s identity documents, selfies, or personal data for unauthorized purposes, criminal and data privacy remedies may be available.

6. Usurpation of authority or improper representation

Collectors pretending to be police officers, court sheriffs, prosecutors, government personnel, or lawyers may face liability depending on the acts committed.

7. Cybercrime-related offenses

Where electronic systems are used to commit fraud, harassment, identity theft, cyberlibel, or unauthorized access, cybercrime laws may apply.

A criminal complaint should be supported by evidence. Mere suspicion is not enough. The complainant should show screenshots, recordings where lawful, transaction records, payment receipts, app details, names used by collectors, phone numbers, and proof of harm.

IX. Civil Liability and Damages

A borrower may also seek civil remedies when abusive collection causes injury. Possible claims may include moral damages, actual damages, nominal damages, exemplary damages, attorney’s fees, and other relief depending on the facts.

Civil liability may arise from:

Defamation;
Violation of privacy;
Abuse of rights;
Bad faith;
Fraud;
Unfair or oppressive conduct;
Damage to reputation;
Emotional distress;
Loss of employment or business opportunity;
Unauthorized disclosure of personal information; and
Harassment of family members or workplace contacts.

A civil case may be more practical where the borrower can prove actual injury, such as loss of employment, medical expenses, reputational damage, or financial loss due to the lender’s unlawful conduct.

X. Administrative Remedies Before the SEC

The Securities and Exchange Commission is a key agency for complaints against lending companies and financing companies. The SEC may act on violations involving registration, authority to operate, disclosure requirements, and abusive or unfair debt collection practices.

A borrower may consider filing a complaint with the SEC when:

The lender appears to be unregistered;
The app does not disclose its corporate identity;
The company uses abusive collection practices;
The app imposes hidden or excessive charges;
The lender misrepresents its authority;
The company violates SEC rules on online lending platforms;
The lender or collector contacts third parties to shame the borrower; or
The app operates despite regulatory restrictions.

Useful evidence for an SEC complaint includes:

Name of the lending app;
Screenshots of the app page;
Corporate name, if available;
SEC registration details, if known;
Loan agreement or screenshots of terms;
Proof of loan release;
Payment records;
Collection messages;
Calls logs;
Screenshots of threats;
Messages sent to contacts;
Proof of public shaming; and
Names, numbers, or account details of collectors.

The SEC remedy is administrative. It may result in penalties, suspension, revocation, or regulatory action. It does not automatically erase a valid loan, but it may help stop unlawful practices and hold the company accountable.

XI. Complaints Before the National Privacy Commission

The National Privacy Commission handles complaints involving misuse of personal data. Lending app cases often involve data privacy violations because apps may access contacts, photos, IDs, and other personal information.

A complaint before the NPC may be appropriate when:

The app accessed contacts without valid consent or lawful basis;
The lender contacted people in the borrower’s phonebook;
The lender disclosed the borrower’s loan to third parties;
The borrower’s photo, ID, address, or phone number was posted online;
The lender used personal data to threaten or shame the borrower;
The app collected excessive data unrelated to lending;
The company failed to provide a clear privacy notice;
The borrower’s data was shared with unknown collectors; or
The lender refused to delete or correct personal data when legally required.

Evidence may include:

Screenshots of app permissions;
Privacy policy screenshots;
Messages sent to contacts;
Affidavits or statements from contacted persons;
Screenshots of online posts;
Demand messages containing personal data;
Call logs;
App store page screenshots;
Loan agreement;
ID submission records; and
Proof that third parties received messages about the debt.

The NPC may order corrective measures, impose penalties, or refer matters for prosecution where appropriate.

XII. Complaints Before PNP-ACG or NBI Cybercrime Division

Victims may report cyber-related conduct to law enforcement where the lending app or collector uses electronic means to commit threats, fraud, identity theft, cyberlibel, harassment, phishing, or unauthorized access.

This remedy is appropriate when:

The app is fake and collected money fraudulently;
The borrower was threatened through text, chat, or social media;
The borrower’s photos were posted online;
Fake accounts were used to harass the borrower;
The collector impersonated a lawyer, police officer, or court official;
The app accessed accounts or data without authority;
There are phishing links or suspicious payment instructions;
The borrower’s identity was used for other transactions; or
There is coordinated online harassment.

Victims should preserve digital evidence carefully. Screenshots should show dates, phone numbers, usernames, profile links, message contents, and full context. Where possible, export chat histories, save URLs, record transaction references, and keep the device used in the incident.

XIII. Complaints Before the DTI or BSP

The Department of Trade and Industry may be relevant in cases involving deceptive, unfair, or unconscionable sales or consumer practices. However, the proper agency depends on the nature of the entity and transaction.

The Bangko Sentral ng Pilipinas may be relevant if the complaint involves a BSP-supervised financial institution, payment system, bank, e-wallet, remittance company, or other covered financial service provider. Many lending apps, however, fall primarily under SEC jurisdiction if they are lending or financing companies.

If the issue involves an e-wallet or bank account used by scammers, the borrower may also report the transaction to the bank, e-wallet provider, or payment platform and request account freezing, investigation, or reversal where possible.

XIV. Court Remedies

A borrower may go to court when agency complaints are insufficient or when damages, injunctions, criminal prosecution, or judicial relief are necessary.

Possible court-related remedies include:

Civil action for damages Filed when the borrower suffered injury due to harassment, defamation, privacy violations, fraud, or abusive collection.
Criminal complaint before the prosecutor’s office Filed when the acts constitute a crime. The complaint is generally supported by affidavits and evidence.
Protection of rights through injunction or other equitable relief In appropriate cases, a court may be asked to restrain unlawful acts.
Small claims This is usually used by creditors to collect money claims, but borrowers should understand that lending companies may also file collection cases. Small claims proceedings do not allow imprisonment for mere nonpayment of debt.
Defenses in collection cases If sued, a borrower may raise defenses such as payment, invalid or unconscionable charges, lack of authority, defective documentation, fraud, or other applicable defenses.

XV. Does Nonpayment of an Online Loan Lead to Imprisonment?

As a general rule, a person is not imprisoned simply because he or she cannot pay a debt. The Philippine Constitution prohibits imprisonment for debt. Therefore, a collector’s statement that a borrower will automatically be arrested or jailed for nonpayment is generally misleading.

However, this does not mean all debt-related conduct is free from criminal consequences. Criminal liability may arise if there is fraud, falsification, use of fake identity, issuance of bouncing checks, or other separate criminal acts. The distinction is important:

Failure to pay a genuine loan is generally a civil matter.
Obtaining money through deceit may become a criminal matter.
Using fake documents or identities may create criminal liability.
Issuing a bad check may have separate legal consequences.
Threatening or defaming a borrower to collect a debt may expose collectors to liability.

Borrowers should not ignore valid debts, but they should also not submit to unlawful harassment.

XVI. What Borrowers Should Do Immediately After Harassment or Scam

A borrower who experiences lending app abuse should take practical steps:

1. Preserve evidence

Do not delete messages, call logs, app screenshots, loan agreements, or payment receipts. Take screenshots showing the sender, date, time, and full content. Save the app name, download page, and privacy policy.

2. Stop giving additional personal information

Do not send more IDs, selfies, passwords, PINs, OTPs, bank details, or e-wallet access codes. Legitimate lenders should not ask for OTPs or account passwords.

3. Revoke app permissions

Remove the app’s access to contacts, camera, location, photos, storage, and microphone. Uninstalling the app may not delete data already uploaded, but it can stop further access.

4. Inform affected contacts

If the lender has contacted relatives, friends, or co-workers, tell them not to engage, pay, or provide information. Ask them to preserve screenshots.

5. Pay only through verified channels

If the loan is legitimate and the borrower intends to pay, payment should be made only through official channels. Avoid sending money to personal accounts unless clearly authorized and documented.

6. Demand validation of the debt

The borrower may ask the lender to provide the loan agreement, computation of charges, payment history, company registration details, and official collection authority.

7. File complaints

Depending on the issue, complaints may be filed with the SEC, NPC, PNP-ACG, NBI Cybercrime Division, DTI, BSP, or the courts.

8. Seek legal assistance

For serious harassment, large amounts, workplace damage, identity theft, or criminal threats, the borrower should consult a lawyer or seek help from legal aid offices.

XVII. Evidence Checklist

A strong complaint usually depends on good evidence. The borrower should gather:

Name of the lending app;
Screenshots of the app listing;
Website or download link;
Corporate name and registration details, if available;
Loan agreement;
Disclosure statement;
Amount borrowed;
Amount received;
Deductions and fees;
Due date;
Interest and penalty computation;
Proof of payments;
Receipts and transaction numbers;
Screenshots of collection messages;
Call logs;
Voice recordings, where lawfully obtained;
Names and numbers of collectors;
Messages sent to contacts;
Statements from contacted persons;
Screenshots of social media posts;
Proof of public shaming;
App permission screenshots;
Privacy policy screenshots;
Demand letters;
Fake subpoenas or warrants;
Police blotter, if any; and
Medical, employment, or financial proof of damage, if claiming damages.

XVIII. Demand Letter to a Lending App or Collector

Before or alongside filing a complaint, a borrower may send a written demand asking the lender to stop unlawful acts. The letter should be firm but factual.

A demand letter may include:

Borrower’s name;
Loan reference number;
Statement that the borrower does not refuse to settle a valid obligation;
Request for full loan computation;
Demand to stop contacting third parties;
Demand to stop threats and defamatory messages;
Demand to stop unauthorized processing of personal data;
Request for data deletion where applicable;
Warning that complaints will be filed with appropriate agencies; and
Request that all future communication be made through official channels.

The borrower should avoid admitting disputed amounts without reviewing the computation. If the borrower intends to settle, the letter may propose a reasonable payment arrangement.

XIX. Sample Complaint Structure

A complaint may be organized as follows:

Complainant’s information Name, address, contact number, email.
Respondent’s information App name, company name, office address, contact numbers, collector names, social media accounts, or unknown persons if identity is not available.
Facts of the case Narrate what happened in chronological order.
Loan details Amount applied for, amount released, deductions, interest, fees, due date, and payment history.
Illegal acts complained of Harassment, threats, data privacy violations, fake fees, public shaming, unauthorized contact of third parties, fraud, or impersonation.
Evidence Attach screenshots, receipts, call logs, affidavits, and other documents.
Relief requested Investigation, penalties, cessation of harassment, deletion of unlawfully processed data, damages, prosecution, or other appropriate relief.
Verification and signature The complainant should sign and certify the truth of the allegations.

XX. Are High Interest Rates Automatically Illegal?

High interest alone does not automatically make a loan void in all situations. However, interest, penalties, and charges may be challenged if they are unconscionable, hidden, misleading, or imposed in bad faith.

In online lending, the issue is often not only the nominal interest rate but the effective cost of borrowing. For example, a borrower may apply for ₱5,000 but receive only ₱3,500 after deductions, then be required to repay ₱5,000 or more within seven days. This can result in an extremely high effective interest rate.

Borrowers should examine:

Amount applied for;
Amount actually received;
Processing fees;
Service fees;
Platform fees;
Insurance fees;
Penalties;
Rollover charges;
Late fees;
Collection fees;
Total repayment amount; and
Length of loan term.

If fees were not clearly disclosed before loan acceptance, the borrower may raise this in complaints.

XXI. Liability of Collection Agencies

Some lenders use third-party collection agencies. A lender cannot avoid responsibility simply by outsourcing collection. Collection agencies may also be liable for their own unlawful acts.

Issues involving collection agencies include:

Lack of authority to collect;
Failure to identify the creditor;
Harassment;
Threats;
False legal claims;
Contacting third parties;
Unauthorized processing of personal data;
Misrepresentation as lawyers or government agents; and
Collection of inflated amounts.

Borrowers may demand proof that the collector is authorized to collect. Payments should not be made to unknown personal accounts without official documentation.

XXII. What If the Lending App Is Not Registered?

If the lending app is unregistered or its operator cannot be identified, the borrower should still preserve evidence and file complaints. The lack of registration may strengthen the case before regulators and law enforcement.

However, the borrower should understand that dealing with unregistered operators may make recovery more difficult. Scammers may use fake names, disposable SIM cards, mule accounts, and anonymous online profiles.

Steps include:

Report the app to the SEC;
Report data misuse to the NPC;
Report fraud or cybercrime to PNP-ACG or NBI;
Report suspicious bank or e-wallet accounts to the provider;
Warn contacts not to engage;
Change passwords and secure accounts;
Monitor for identity theft; and
Avoid paying further unexplained fees.

XXIII. What If the Borrower Actually Owes the Money?

The existence of a valid debt does not authorize harassment. The borrower should separate two issues:

Debt obligation Whether the borrower owes money, how much is owed, and when it should be paid.
Unlawful collection conduct Whether the lender or collector violated the law while trying to collect.

A borrower may still need to pay a valid loan, but may also file complaints for abusive collection, privacy violations, or defamation. Payment does not necessarily erase liability for prior unlawful acts.

Where possible, the borrower may negotiate:

Waiver of excessive penalties;
Extension of payment period;
Installment plan;
Written settlement agreement;
Official receipt;
Full release and clearance after payment; and
Written undertaking to stop contacting third parties.

All settlements should be documented.

XXIV. How to Avoid Lending App Scams

Borrowers should exercise caution before installing or using online lending apps.

Practical precautions include:

Check whether the company is registered and authorized;
Avoid apps that require upfront fees before loan release;
Read the privacy policy;
Avoid apps demanding access to contacts, photos, and messages;
Read loan terms before accepting;
Compute the actual amount received versus amount payable;
Avoid lenders using only personal mobile numbers;
Do not send OTPs, passwords, or PINs;
Avoid clicking suspicious links;
Use official payment channels only;
Save all documents and screenshots;
Research complaints from other users;
Avoid borrowing from multiple apps to pay existing app loans; and
Seek help early when harassment begins.

XXV. Remedies Summary

A victim’s remedy depends on the problem:

Problem	Possible Remedy
Unregistered lending app	Complaint with SEC
Harassing collection	SEC complaint, civil action, criminal complaint depending on facts
Unauthorized access to contacts	NPC complaint
Disclosure of debt to contacts	NPC complaint, civil/criminal remedies depending on facts
Online shaming or defamatory posts	Cybercrime complaint, civil/criminal defamation remedies
Fake loan app collecting fees	PNP-ACG, NBI Cybercrime Division, prosecutor’s office
Fake lawyer/police/court threats	Criminal complaint and regulatory complaint
Suspicious bank/e-wallet account	Report to bank/e-wallet provider and law enforcement
Excessive or hidden charges	SEC complaint, consumer complaint, court defenses
Identity theft	NPC, PNP-ACG, NBI, affected financial institutions
Valid debt but abusive collection	Negotiate payment while filing complaint for unlawful conduct

XXVI. Practical Legal Position

The practical legal position in the Philippines may be summarized as follows:

Online lending is legal if properly registered and compliant with law.
Borrowers must pay valid debts.
Nonpayment of debt alone generally does not justify imprisonment.
Lenders may collect, but only through lawful means.
Harassment, threats, public shaming, and unauthorized disclosure of personal data are not valid collection methods.
Lending apps must comply with data privacy obligations.
Borrowers may complain to the SEC for lending and collection abuses.
Borrowers may complain to the NPC for misuse of personal data.
Cyber-related fraud, threats, identity theft, or online defamation may be reported to PNP-ACG or NBI.
Serious cases may justify civil, criminal, and administrative action.

XXVII. Conclusion

Lending app scams and abusive online loan collection practices are serious problems in the Philippines. They often target financially distressed borrowers who may feel ashamed, frightened, or unaware of their rights. While a borrower should not ignore a valid loan, a lender’s right to collect does not include the right to threaten, defame, shame, deceive, or misuse personal data.

The most important step for victims is to preserve evidence. Screenshots, call logs, app details, payment records, and witness statements can determine whether a complaint succeeds. The proper remedy depends on the nature of the violation: the SEC for lending and collection abuses, the National Privacy Commission for data privacy violations, law enforcement for cybercrime or fraud, and the courts for damages or prosecution.

A fair lending system requires both borrower responsibility and lender accountability. Borrowers should pay legitimate obligations, but lenders and collectors must obey the law. No debt gives anyone the right to destroy a person’s dignity, privacy, reputation, or peace of mind.