Updated for Philippine context and practice; for general information only and not a substitute for tailored legal advice.

1) Short answer

No. When the Securities and Exchange Commission (SEC) revokes a lending company’s Certificate of Authority (CA), the firm may not engage in the business of lending or hold itself out to the public as a lender. Continuing to issue new loans, advertise lending services, or service new borrowers after revocation constitutes illegal operation and exposes the company and its officers to administrative, civil, and criminal liability.

What a revoked lender may still do is wind down: e.g., keep books, preserve records, and lawfully collect on existing, valid loans (subject to consumer-protection and collection rules). It cannot book new loans or relaunch lending activities unless its authority is reinstated (which is rare and requires full regulatory cure).

2) The legal framework (who regulates what)

Lending companies are corporations that make loans from their own capital to the public, regulated by the SEC under the Lending Company Regulation Act of 2007 (LCRA / Republic Act No. 9474) and its rules.
Financing companies (RA 8556), banks and quasi-banks (BSP-regulated), pawnshops (BSP), and microfinance NGOs (RA 10693) are different categories with different regulators and rules. Make sure the entity you’re dealing with is truly a lending company; the consequences of revocation differ by category.
The Financial Products and Services Consumer Protection Act (RA 11765) empowers the SEC (and BSP/IC for their sectors) to enforce market conduct, stop abusive practices, and penalize violators.
The Data Privacy Act (RA 10173) governs the handling of borrower data; harassment or doxxing via contact-list “scraping,” unauthorized disclosure, or threats can trigger separate liability.

3) What exactly is “revocation” and how it differs from “suspension”

Suspension: a temporary halt of lending operations pending compliance (e.g., failure to file reports). No new loans during suspension; reinstatement is possible upon cure.
Revocation: the termination of the CA. After revocation, the entity no longer has legal authority to carry on a lending business. Reinstatement requires a new grant of authority and satisfaction of all regulatory requirements; in practice, revocation often precedes permanent exit.

Common grounds for revocation include: operating unregistered online lending apps; unfair or abusive collection practices; misrepresentation; failure to file audited financial statements/general information sheets; refusal to allow SEC examination; and other serious violations of RA 9474 and SEC issuances.

4) After revocation: what’s prohibited vs allowed

Prohibited

Issuing new loans or rolling over old ones as “new” credit.
Advertising or holding out to the public as a lender (websites, social media, signages, apps).
Deploying or re-launching digital lending apps (Android/iOS/web) to solicit the public.
Using agents/third parties to continue lending “indirectly.” You cannot do through a contractor what you cannot lawfully do yourself.

Allowed (wind-down only)

Record-keeping and audit functions.
Lawful collection on existing, valid loans made while the CA was effective, provided:
- No unfair, harassing, or deceptive collection practices.
- All communications comply with consumer-protection and privacy laws.
- No misrepresentation of regulatory status (e.g., saying “licensed” when the CA is revoked).

Key practical point: Philippine law generally enforces lawful loan obligations even if the lender later loses its CA. However, loans granted while the lender had no CA (or after revocation) expose the lender and its officers to penalties and can impair the enforceability of interest/charges, with courts often striking unconscionable interest and abusive fees. Borrowers remain liable at least for principal actually received, subject to valid defenses (illegality, lack of consideration, fraud, vitiated consent, etc.).

5) Consequences of operating after revocation

Administrative: SEC cease-and-desist orders, fines, permanent blacklisting of apps/brands, and disqualification of directors/officers.
Criminal: RA 9474 provides penal sanctions for acting as a lending company without a CA and for willful violations of the Act/IRR; corporate officers and responsible employees can be prosecuted.
Civil: Exposure to damages for unfair collection, misrepresentation, privacy breaches, and abusive contract terms. Courts may void usurious or unconscionable interest/penalty rates and enforce only the principal (plus reasonable interest, if any).
Data privacy: Complaints with the National Privacy Commission for illegal data processing or harassment via contact harvesting and public shaming.
Cyber/other laws: Threats, defamation, and technology-facilitated harassment can trigger anti-cybercrime and related liabilities.

6) Collection rules that still bind revoked lenders

Even during wind-down, a revoked lender (and its third-party collectors) must strictly observe:

Fair debt collection standards (no threats of violence, profane language, public shaming, contacting your employer/contacts to humiliate, disclosing debt to third parties without lawful basis or consent, calling outside reasonable hours, misrepresenting as law enforcement, etc.).
Truthful communications about the account status, amount due, and consequences of nonpayment (no “fake court orders,” “warrants,” or fabricated criminal cases; non-payment of a pure civil loan is not a criminal offense absent bouncing checks, estafa, or separate crimes).
Data minimization and security under the Data Privacy Act; use only data you’re permitted to process, for the declared purpose, with adequate safeguards.
Proper notices: demand letters, SOAs, and lawful dunning practices. If they assign or sell receivables to a third party, you’re entitled to notice of assignment and to pay only the lawful assignee.

7) Borrower rights and practical steps

If you discover your lender’s CA has been revoked:

Verify the company’s corporate name and CA status (as listed in its receipts, loan agreement, or app).
Ask in writing whether they are still licensed to operate as a lending company and, if not, to confirm you will be dealing only with a wind-down/collections channel that complies with law.
Keep paying legitimate obligations through official channels you can document (official receipts, bank proof). Avoid cash to field agents unless identity and authority are clear.
Contest unlawful charges (e.g., excessive penalties, layered “processing” fees, hidden app fees). Philippine courts have repeatedly voided unconscionable interest and penalties; if rates are oppressive, you may negotiate or seek legal relief.
Document harassment (screenshots/recordings of calls and messages) and file complaints with the SEC (for market conduct), NPC (privacy), and—where threats/defamation exist—the NBI/PNP (cybercrime).
Do not sign novations that disguise new lending after revocation; a “restructure” that is actually a new loan may be unlawful.

8) Corporate officers’ exposure

Revocation does not shield directors, officers, and compliance personnel. If they consent to or tolerate post-revocation lending, false advertising, or abusive collection, they risk personal administrative and criminal liability. Individuals who sign off on non-compliant online lending apps, unfair scripts, or data-harvesting practices may face joint liability.

9) Digital/online lending apps

A revoked lending company must take down or disable public-facing apps and landing pages that solicit new loans. Keeping the app live to accept applications or to “auto-approve” repeat loans is continued illegal operation.
If the app remains available purely for viewing statements and paying existing accounts, it must be re-branded and messaged to reflect wind-down only—no “Apply Now,” no marketing, no lead capture.
Third-party processors and collectors integrated into the app must likewise comply with consumer-protection and privacy requirements. They cannot launder illegal lending through “platform” excuses.

10) Frequently asked borrower questions

Q: Do I still owe the loan if the company’s CA has been revoked? A: If the loan was validly granted when the CA was active, the debt generally remains (subject to defenses). You may challenge unconscionable rates/penalties and unlawful fees.

Q: What if my loan was granted after revocation or when the lender had no CA? A: The lender and its officers face penalties for illegal operation; enforceability of interest and charges is doubtful and may be struck down. Courts typically ensure repayment of principal actually received while denying abusive yields. Seek counsel.

Q: Can they threaten me with jail for non-payment? A: No, not for mere non-payment of a civil loan. Threats of arrest, public shaming, or contacting your employer/family to coerce payment are unlawful.

Q: Can they call my contacts and disclose my debt? A: Generally no. Unconsented disclosure to third parties can violate privacy and collection rules.

11) Frequently asked lender/creditor questions

Q: May we use a third-party collection agency after revocation? A: Yes, for legacy receivables only, and the agency must follow lawful collection and privacy standards. You remain responsible for your agents’ misconduct.

Q: May we restructure accounts? A: Restructuring to facilitate repayment of an existing loan is part of wind-down; however, no new money should be extended, and terms cannot be more oppressive than before. Avoid marketing or cross-selling.

Q: What communications are safe? A: Neutral, factual notices (balance, due dates, lawful consequences, payment channels). No use of “licensed lender” branding, no solicitations, and no threats.

12) Practical compliance checklist (for wind-down)

Freeze new lending; remove “apply” funnels and ads.
Issue a public notice clarifying wind-down status and consumer channels.
Retain books/records; prepare for SEC examination.
Map and extinguish data flows that exceed DPA-permitted purposes.
Retrain/replace collector scripts to meet fair collection standards.
Honor opt-out and data subject requests (access/correction/erasure, where applicable).
Keep a complaints log and show active remediation.
If seeking reinstatement, cure all regulatory deficiencies first.

13) Templates you can adapt (plain-language)

A) Borrower: request for regulatory status & lawful collection

Subject: Request for Confirmation of Regulatory Status and Lawful Collection Channels

Dear [Lender/Agency], I refer to my account [No./Name]. Please confirm in writing whether [Company] currently holds an active SEC Certificate of Authority to operate as a lending company. If not, kindly provide: (1) your designated wind-down/collection contact details; (2) lawful payment channels; and (3) assurance that all communications and data processing will comply with consumer-protection and privacy laws. Pending your reply, please direct all communications to me only via this email/number. Do not contact my employer, relatives, or references. Sincerely, [Name]

B) Lender: borrower-facing wind-down notice (no solicitations)

Notice to Existing Borrowers [Company] is in wind-down and is not issuing new loans. For existing accounts, you may view statements and pay through [channels]. We comply with applicable consumer-protection and privacy laws. For concerns, contact [email/hotline]. Do not accept loan offers claiming to be from us.

14) Key takeaways

Revocation = no more lending. You can wind down and collect lawfully on valid legacy loans, but no new credit, no solicitations, and no misrepresentations.
Operating after revocation is illegal, attracting SEC action, possible criminal liability, and civil damages.
Borrowers should keep proof, pay through official channels, and report harassment; lenders should pivot to compliance and wind-down execution.

Disclaimer

This article is a general overview based on Philippine statutes and common regulatory practice. Specific facts can change outcomes. For concrete action—whether you’re a borrower or a corporate officer—consult a Philippine lawyer and check the latest SEC issuances relevant to lending companies.