Pre-Loan “Verification Fee” Scam in the Philippines: How to Verify, Report, and Recover

This article explains how the scam works, the Philippine laws you can use, which regulators handle what, and exactly how to file complaints and try to get your money back. It’s general information—not legal advice.

What this scam looks like

Scammers pose as a financing or lending company (sometimes a bank or “government program”) and say you’re approved for a loan. Before “releasing” the funds, they demand upfront payments (often called “verification,” “processing,” “insurance,” “tax,” or “clearance” fees) via e-wallet or bank transfer to a personal account. After you pay, they ask for more—or disappear.

Key red flags

Demands any fee before loan release, especially via GCash/Maya to a personal wallet or random bank account.
Uses messaging apps only; no physical office; fake or borrowed SEC registration screenshots.
Unrealistic terms (“₱200k, 0% interest, same-day release”).
“Limited time” pressure and threats when you hesitate.

Legitimate lenders may charge processing fees, but they don’t require you to cash-in to a personal account before release and they disclose fees in writing (often netted from proceeds).

The legal backbone (what laws can apply)

Revised Penal Code (RPC): Estafa / Swindling (Art. 315) For obtaining money through deceit or false pretenses. Depending on facts, Other Deceits (Art. 318) can also apply.
Presidential Decree No. 1689 (Syndicated / Large-Scale Estafa) Heavier penalties when fraud is carried out by a syndicate or on a large scale. (Consult counsel on applicability.)
Financial Consumer Protection Act of 2022 (R.A. 11765) Sets fair treatment, disclosure, privacy, and redress standards; empowers regulators (SEC, BSP, IC) to go after abusive or fraudulent providers.
Financing Company Act (R.A. 8556) & Lending Company Regulation Act (R.A. 9474) SEC supervises financing/lending companies and can fine, suspend, revoke, and pursue criminal action for unlicensed or abusive operations.
Truth in Lending Act (R.A. 3765) Requires clear disclosure of finance charges and terms; misrepresentation is actionable.
Cybercrime Prevention Act (R.A. 10175) If fraud is committed online, it can aggravate or add cybercrime charges; affects venue and digital evidence handling.
Data Privacy Act (R.A. 10173) For doxxing/harassment or misuse of your personal data (common in rogue “lending apps”).
E-Commerce Act (R.A. 8792) & Rules on Electronic Evidence (A.M. No. 01-7-01-SC) Your screenshots, chat logs, emails, call recordings, and e-wallet receipts can be valid electronic evidence if properly preserved.

Who regulates what (so you file with the right office)

SEC – Lending/financing companies and online lending platforms (licensing, CDOs, administrative penalties; can refer for prosecution).
BSP – Banks, e-money issuers, and payment system operators (for chargebacks/disputes and abusive conduct by supervised institutions).
PNP-Anti-Cybercrime Group / NBI-Cybercrime Division – Criminal complaints for online fraud, threats, and identity theft.
National Privacy Commission (NPC) – Harassment/doxxing and unlawful processing of personal data.
Insurance Commission (IC) – If the “fee” is framed as mandatory insurance from an insurer/agent.
Local Prosecutor’s Office (DOJ) – Criminal complaint-affidavit for estafa and related offenses (leads to preliminary investigation).

Tip: If they used a bank or e-wallet to receive your money, you can dispute the transfer with your provider (BSP-supervised) in parallel with your SEC/criminal complaint.

How to check legitimacy before you pay

SEC status: A real financing/lending company must be SEC-registered and hold a Certificate of Authority to operate as a Financing Company or Lending Company (different from basic corporate registration). Names must match exactly.
No personal wallets: Legit lenders do not ask you to send fees to a personal GCash/Maya or to an account under a different individual/company name.
Written disclosure: Demand a formal offer (company letterhead) detailing loan amount, APR, fees, and net proceeds.
Office & channels: Verify business address, landline, official domain email, and customer service.
Cooperatives: If they claim to be a co-op, lending to non-members is a red flag (co-ops are generally under CDA and lend primarily to members).

Preserve evidence (critical for any case)

Screenshots/screen recordings: Full chat threads (showing names, dates, numbers), call logs, emails.
Payment proof: E-wallet reference numbers, bank deposit slips, transaction IDs, and account names/numbers.
Identity artifacts: Photos of IDs/certificates they sent, website/app captures, social media pages.
Timeline: A short chronology (who, what, when, how much).
Backups: Save to multiple drives/cloud. Keep originals; if you edit/annotate, preserve the unedited copy for authenticity.

Step-by-step: Filing complaints

1) File with the SEC (administrative + enforcement)

When: If a “lender/financer” is unregistered, has no Certificate of Authority, or uses deceptive/abusive practices.
What to submit:
- Narrative (chronology).
- Your ID (government-issued).
- Evidence (all screenshots, receipts, account names/numbers, phone numbers, links).
Outcome: SEC may Cease-and-Desist, name-and-shame, revoke licenses, fine, and refer for prosecution.

2) Open a criminal case (estafa and related)

Where: Office of the City Prosecutor where any element occurred (e.g., where you sent money, where you received deceitful messages) or via PNP-ACG/NBI-Cybercrime (they can assist and forward to prosecutors).
File: A Complaint-Affidavit with annexes (evidence). Sign before a prosecutor or notary.
Process: Preliminary investigation → subpoena to respondents → counter-affidavit → resolution. If probable cause is found, an Information is filed in court; a warrant may issue.

3) Data privacy complaint (if harassed/doxxed)

When: If they threaten to post your data, contact your phonebook, or actually harass you/your contacts.
What: File a complaint with the NPC with screenshots and numbers; you can pursue this alongside SEC/criminal actions.

4) Recover funds via your bank/e-wallet (BSP channel)

Act fast. Report the fraudulent transfer through your provider’s dispute process (bank or e-money issuer).
Provide reference numbers, timestamps, and your police blotter/SEC complaint if available.
Ask for account freezing and trace requests. Outcomes vary, but timely reports maximize recovery chances.

Civil remedies (getting your money back)

Small Claims (for amounts within the current Supreme Court threshold—verify latest): Fast, no lawyers required; sue for sum of money and damages.
Regular civil action: Rescission/annulment for fraud, unjust enrichment, and damages under the Civil Code.
Provisional relief: Consult counsel on a writ of preliminary attachment to secure assets if you can show fraud.
Multiple defendants: Include the wallet/account holder and any identifiable handlers; consider John/Jane Does if identities are concealed.

Practical playbook (do this now)

Stop paying immediately; block the numbers/accounts.
Compile evidence (see checklist above) and write a one-page timeline.
Report simultaneously to SEC, PNP-ACG/NBI-Cybercrime, and your bank/e-wallet.
Get a police blotter (often requested by banks/e-wallets).
Consider a Small Claims suit if the amount fits the latest threshold.
Protect your data: Change passwords, enable MFA, and warn contacts if scammers obtained your phonebook.

Special situations

They used a real company’s name: Note this in your complaints—impersonation is common; regulators can contact the real company and help disambiguate.
You’re an OFW / outside the city: You can usually file online/remote and authorize a representative via SPA for in-person steps.
Multiple victims: Consider a group complaint or a class suit (Rule 3, Sec. 12 Rules of Court) if requirements are met—often strengthens the case.

Templates you can copy-paste (fill the brackets)

A) SEC Complaint Cover Letter

Subject: Complaint vs. [Name used by Respondent] for Unlicensed Lending/Financing and Fraud

I am filing a complaint against [Name used / Page / App] for alleging to be a [lending/financing/bank] and demanding upfront “verification/processing” fees before loan release.

Facts (brief):
• On [date/time], I was contacted via [platform/number].
• They claimed I was approved for a loan of [amount] with [terms].
• They required me to pay [fee] to [GCash/Maya/Bank acct name & number].
• After payment, they [demanded more/blocked me/failed to release funds].

Attached are: (1) my government ID; (2) screenshots of chats/calls; (3) proof of transfers; (4) links/phone numbers; (5) timeline.

I request investigation and appropriate administrative/criminal action.

Complainant: [Full Name, Address, Contact No., Email]
Signature: ______________________  Date: ____________

B) Criminal Complaint-Affidavit (Estafa)

REPUBLIC OF THE PHILIPPINES )
CITY/PROVINCE OF _________  ) S.S.

COMPLAINT-AFFIDAVIT

I, [Full Name], Filipino, of legal age, residing at [Address], after being duly sworn, state:

1. On [date/time], respondent/s [Name/s or aliases], using [numbers/usernames/links], represented themselves as [lender/financer/bank staff] and promised a loan of [amount] under the following terms: [state terms].

2. Respondent/s deceitfully required me to pay “[verification/processing/insurance] fee” amounting to [₱____] to [account name/number, provider], on [date/time], with the assurance that the loan would be released immediately after.

3. I relied on these representations and paid the amount. Thereafter, respondent/s [demanded additional fees/failed to release funds/blocked me], causing me damage in the amount of [₱____], exclusive of other damages.

4. Annexed are true and faithful copies of chat transcripts, call logs, screenshots, and transaction proofs marked as Annexes “A” to “__”.

I execute this affidavit to file criminal charges for Estafa (Art. 315, RPC) and other applicable laws.

Affiant: [Name, Signature]
SUBSCRIBED AND SWORN before me this __ day of ______, 20__, affiant exhibiting [ID type/number].

C) Bank/E-Wallet Dispute Letter

Subject: Urgent Fraud Dispute and Freeze Request – [Reference No.]

I request reversal/investigation for a fraudulent transfer of ₱[amount] on [date/time] to [account name/number]. I was deceived by a fake financing entity demanding an upfront “verification fee.”

Attached: screenshots, transaction refs, ID, police blotter/SEC complaint (if any). Please initiate internal investigation, coordinate with the receiving institution, and freeze the recipient account per your fraud procedures.

Customer: [Name, CID/Account No., Contact]

D) NPC Complaint (Harassment/Doxxing)

Subject: Complaint for Unlawful Processing and Harassment

[Describe how the “lender” accessed/used your contacts, sent threats, or published your data.]
Attachments: Screenshots of messages/calls/posts; phone numbers; platform URLs.

Complainant: [Name, Address, Contact]

Frequently asked questions

Is an upfront “verification fee” ever legit? Not when it’s demanded before any loan is released into your control—especially to personal wallets/accounts. Reputable institutions net fees from proceeds and disclose them in writing.

What if the account name differs from the “company” name? That’s a major red flag. Include this mismatch in your complaints.

Can I get my money back? It depends on how quickly you report and whether the funds can be traced/frozen. File all avenues (SEC, criminal, bank/e-wallet) promptly to improve odds.

Will screenshots be accepted? Yes—under the Rules on Electronic Evidence, electronic documents are admissible if properly authenticated. Keep original files and metadata where possible.

What court should I go to for civil recovery? If the amount is within the current Small Claims threshold (check latest rule), that’s often the fastest. Otherwise, file a regular civil action.

Final reminders

Move fast, file parallel complaints, and don’t send more money.
Keep everything organized (timeline + annexes).
If you’re unsure about venue or strategy, a short consult with a Philippine lawyer can align criminal, administrative, and civil paths for the best recovery chance.

If you want, I can tailor the templates above using your exact timeline, amounts, screenshots list, and where you plan to file.