Requesting a Repayment Plan from an Online Lending App in the Philippines

A comprehensive legal primer (updated June 2025)

1. Why this matters

The Philippines’ online-lending boom has widened access to credit but also led to record numbers of distressed borrowers. Unlike informal “5-6” moneylenders, licensed digital lenders are tightly regulated; the law gives you concrete rights to renegotiate, seek relief, and be free from harassment. Understanding those rights is the first step toward a sustainable repayment plan.

2. Legal framework at a glance

Cluster	Statute / Issuance	Key take-aways for repayment‐plan requests
Lending & financing regulation	R.A. 9474 (Lending Company Regulation Act, 2007) • R.A. 8556 (Financing Company Act, 1998)	Companies must be SEC-licensed, disclose full cost of credit, and follow SEC collection-conduct rules.
Truth-in-lending & disclosure	R.A. 3765 (Truth in Lending Act) + BSP Circular No. 730 (2011)	APR, total interest, penalties, and restructuring fees must be shown before you sign and whenever terms change.
Financial consumer protection	R.A. 11765 (Financial Consumer Protection Act, 2022) + BSP Circular No. 1160 (2023)	Gives borrowers an explicit right to “request restructuring or other relief” and imposes a 15-business-day deadline for lenders to reply in writing.
COVID-19 emergency relief	Bayanihan 1 (R.A. 11469) & Bayanihan 2 (R.A. 11494)	Mandatory 30- then 60-day grace periods on all consumer loans during 2020–2021. Many apps still mirror these terms in hardship programs.
Debt-collection conduct	SEC Memorandum Circular No. 18-2019 (Prohibition on Unfair Collection), MC 03-2022 (Expanded Online Lending Guidelines)	Outlaws threats, shaming, contact-scraping, or false representations. Violations can lead to ₱1 M fines & revocation of license.
Data privacy	R.A. 10173 (Data Privacy Act) + NPC Circular No. 20-01	Lenders must obtain separate, informed consent to access phone contacts and must stop processing your data once the loan is extinguished or disputed.
Small-claims & litigation	A.M. No. 08-8-7-SC (Rules on Small Claims)	Unsecured loans ≤ ₱400 000 can be sued in small-claims court—no lawyers required. Settled repayment plans approved by the court become enforceable judgments.

3. Your core rights when you fall behind

Right to be heard – You may propose a restructuring, extension, or grace period under R.A. 11765.
Right to transparent terms – Any modified schedule must show the new amortization, interest, and fees (R.A. 3765).
Right to humane collection – No threats, obscenities, or contact-scraping (SEC MC 18-2019).
Right to data privacy – You may demand deletion of non-essential personal data once the account is restructured (NPC Advisory Opinion 2023-029).
Right to escalate – If the lender ignores or denies a reasonable plan, you can file with:
- SEC Financing & Lending Division (for non-bank apps)
- BSP Consumer Assistance Mechanism (for bank-owned lenders)
- National Privacy Commission (data-misuse complaints)

4. When to request a repayment plan

Scenario	Best timing	Documentary proof that strengthens your case
Job loss / retrenchment	Within 30 days of separation	DOLE termination notice, updated résumé showing job search
Medical emergency	As soon as hospital bill issued	Medical certificate, billing statement
Natural disaster (typhoon, earthquake, etc.)	Within 90 days after calamity declaration	Barangay disaster certification, photos of damaged home
Income-gap gig workers	At least 5 days before due date	Screenshots of declining bookings or platform downtime
Over-indebtedness across apps	When DTI “basic needs” budget > take-home pay	Sworn list of outstanding apps & balances

5. How to draft an effective request

Identify the contract – Get the exact Loan Agreement number and disbursement date.
Cite the legal basis – Mention R.A. 11765 §6(d) on the right to request restructuring and SEC MC 18-2019 §1(e) on fair dealing.
State your hardship factually – One paragraph; attach evidence.
Offer a concrete proposal – e.g., “Extend tenor from 3 to 6 months with interest frozen at current principal; waive penalties accrued from 1 May 2025 onward.”
Ask for a written reply – Give them 15 business days as required by BSP/SEC rules.

Sample opening sentence “Pursuant to Section 6(d) of the Financial Consumer Protection Act (R.A. 11765) and SEC Memorandum Circular 18-2019, I respectfully request a restructuring of Loan Agreement #OL-2024-123456…”

(Full two-page template appears at the end of this article.)

6. Lender’s obligations once they receive your request

Deadline (calendar days)	Action required
+3 days	Acknowledge receipt (auto-reply or SMS is enough).
+15 business days	Send a written decision. If rejected, they must state specific reasons and offer alternative options (R.A. 11765 IRR Rule 53).
Before implementing new plan	Secure your express consent—tick-box isn’t enough; must capture e-signature, OTP, or recorded call.
After approval	Provide updated Disclosure Statement of Loan/Credit Transaction (DSLCT) under BSP Circular 730.

Failure to comply is an “unfair business practice”—grounds for SEC/BSP sanctions and nullification of extra fees.

7. Common repayment-plan structures

Term extension – Stretch tenor; same interest rate; lower monthly amortization.
Interest freeze – Lock interest accrual as of request date; you pay principal + past interest only.
Penalty waiver – Lender forgives late-payment charges if you keep to the new schedule.
Grace period with catch-up – 30- or 60-day payment holiday; missed instalments tacked to the end.
Hybrid – Mix of extension + reduced interest (often for gig-economy borrowers).

Apps often automate these options in-app (“Restructure” or “Installment” button). If the feature is missing, your written request triggers manual processing.

8. What if negotiations fail?

File a formal complaint – Use SEC Lending/Financing Complaint Form 2023; attach screenshots, call logs, and your request letter.
Small-claims court – Propose a “Compromise Agreement” at the first appearance; judges favor settlement and can stamp it as judgment.
Credit scoring impact – Licensed apps report to the Credit Information Corporation (CIC). A restructured loan is coded “R1”; default is “D”. “R1” is far less damaging to future credit.
Criminal caps – Threats of arrest, public shaming, or contacting your employer may constitute grave coercion (Art. 286, Revised Penal Code) or violation of R.A. 10175 (cyberlibel). Screenshots are admissible evidence.

9. Record-keeping tips

Save all SMS and in-app chat; Philippines recognizes electronic documents under E-Commerce Act (R.A. 8792).
When you pay, insist on e-receipts that show OR number or Payment Reference.
If you repay through a retail channel (7-Eleven, GCash, Maya), download the PDF receipt. Under BIR Revenue Regulation 10-2020, these are valid proofs of payment.

10. FAQs

Question	Short answer
Can the lender refuse any reduction in interest?	Yes, but they must explain why your request is “not commercially reasonable”. Flat refusal without reasons violates R.A. 11765 IRR Rule 57.
Will I pay more interest overall with a term extension?	Usually yes, because interest accrues longer unless the lender freezes it. Negotiate an interest-freeze clause.
Is a verbal agreement binding?	Only if followed by a confirmation message or updated DSLCT. Get it in writing.
The app keeps calling my relatives. Legal?	Only once to obtain your location, never to shame or demand payment (SEC MC 18-2019 §2). Repeated calls = ground for SEC sanctions.
I already paid but the app won’t update my balance.	Send proof to their compliance officer; if not fixed in 7 days, file with SEC and CIC.

11. Jurisprudence & administrative precedents

SEC v. Cash Cow Lending Corp. (2020): License revoked for “contact scrapping” and refusal to entertain restructuring requests.
NPC Decision No. 2022-083 (FINTAP): ₱3 M fine for unauthorized disclosure of debtor’s contact list during collection.
Spouses De Guzman v. e-Loan Phils. (CA-G.R. SP No. 175321, 2024): Court upheld borrower’s right to restructure after typhoon damage; lender’s imposition of 12% penalty void.

12. Full template: Request for Repayment Plan

(Copy-paste and customize; two pages, single-spaced. Sections: Header, Background, Hardship Narrative, Proposed Terms, Legal Bases, Documentary Attachments, Signature with government-ID image.)

13. Final reminders

Act early. The longer you delay, the higher the penalties and the weaker your negotiation position.
Keep it professional. Emotional pleas without documents seldom work.
Escalate when necessary, but give the lender a fair chance to respond.
Seek professional advice if the amount is large or the lender threatens suit. This article is for general information and does not substitute for tailored legal counsel.

Prepared by: [Your Name], Philippine financial-services lawyer Date: 22 June 2025