I. Introduction

The rapid growth of online lending platforms in the Philippines has made credit more accessible, especially to borrowers who cannot easily obtain bank loans. Many lending applications advertise fast approval, minimal documentary requirements, and same-day disbursement. Some of these platforms are registered with the Securities and Exchange Commission (SEC), while others operate without authority.

Registration, however, does not give a lending company unlimited power. A lending app may be SEC-registered and still violate Philippine law if it imposes unconscionable interest, conceals fees, misuses borrower data, shames borrowers, threatens criminal prosecution, contacts third parties abusively, or uses harassment as a collection method.

This article discusses the Philippine legal framework governing SEC-registered lending apps, high interest rates, abusive collection practices, data privacy violations, and the remedies available to borrowers.

II. What Does It Mean When a Lending App Is SEC-Registered?

In the Philippines, lending companies and financing companies are regulated primarily by the SEC. A legitimate lending or financing company must generally be registered with the SEC and must have the appropriate Certificate of Authority to operate as a lending or financing company.

SEC registration means that the entity has been recognized as a juridical entity and, where applicable, has authority to engage in lending or financing activities. It does not mean that every term in its loan agreement is valid. It also does not mean that the company may ignore consumer protection laws, data privacy rules, disclosure requirements, or fair debt collection standards.

A borrower should distinguish between:

SEC company registration, which shows that the business exists as a corporation or entity;
Certificate of Authority, which allows the company to operate as a lending or financing company;
Compliance with lending, privacy, and consumer protection rules, which must be observed continuously; and
Lawfulness of the specific loan terms and collection conduct, which can still be challenged even if the company is registered.

Therefore, the defense “we are SEC-registered” does not automatically legalize excessive charges, abusive collection, or privacy violations.

III. Laws and Regulations Commonly Involved

Several Philippine laws and regulations may apply to lending app disputes.

A. Lending Company Regulation Act

The Lending Company Regulation Act governs lending companies and places them under SEC supervision. Lending companies must comply with registration and operational requirements and may be sanctioned for violations.

B. Financing Company Act

Financing companies are also regulated by the SEC. If the online platform operates as a financing company rather than a lending company, separate rules may apply, but similar principles of registration, disclosure, and fair dealing remain relevant.

C. Truth in Lending Act

The Truth in Lending Act requires creditors to disclose the true cost of credit. Borrowers must be informed of finance charges, effective interest, deductions, service fees, penalties, and other loan costs.

A lending app that advertises a certain loan amount but releases a much smaller amount because of upfront deductions may be scrutinized if the disclosures were unclear or misleading.

D. Consumer Act and Financial Consumer Protection Principles

Borrowers are financial consumers. They are entitled to fair treatment, transparency, protection from deceptive practices, and access to complaint mechanisms. Lending companies must avoid misleading claims and unfair practices.

E. Data Privacy Act of 2012

The Data Privacy Act is especially important in lending app harassment cases. Lending apps often require access to mobile phone contacts, photos, device information, or social media data. Collection and processing of personal data must have a lawful basis, must be proportional, and must be limited to legitimate purposes.

Even when the borrower consents to data access, consent is not a blank check. The lending app may not use personal information to shame, threaten, expose, or harass the borrower or the borrower’s contacts.

F. Cybercrime Prevention Act

If harassment is committed through electronic means, such as text messages, calls, social media posts, online threats, defamatory messages, or unauthorized publication of personal information, cybercrime-related provisions may become relevant.

G. Revised Penal Code

Depending on the facts, abusive collection may involve criminal offenses such as unjust vexation, grave threats, light threats, slander, libel, coercion, or other offenses. Whether a criminal case is viable depends on the actual words used, the intent, the harm caused, and available evidence.

H. SEC Rules on Online Lending Platforms and Collection Practices

The SEC has issued rules and advisories addressing online lending platforms, unfair debt collection, and abusive practices. The SEC may impose penalties, suspend authority, revoke registration or certificates, and take enforcement action against violators.

IV. Are High Interest Rates Illegal?

High interest alone is not automatically illegal in every case. Philippine law generally allows parties to agree on interest, subject to limits imposed by law, regulation, public policy, and judicial scrutiny.

However, interest and charges may be challenged when they are:

Unconscionable;
Iniquitous;
Exorbitant;
Not clearly disclosed;
Misleadingly presented;
Combined with hidden charges;
Structured to evade disclosure rules; or
Grossly disproportionate to the principal and loan period.

Courts in the Philippines have reduced excessive interest rates in various cases when the charges were found to be unconscionable or contrary to morals and public policy. A borrower may therefore question a loan arrangement where the effective cost of borrowing is oppressive, especially if the app deducted fees upfront, imposed daily penalties, or used automatic rollovers that trapped the borrower in repeated debt.

V. Nominal Interest vs. Effective Interest

Many lending app disputes arise because the advertised interest rate does not reflect the true cost of the loan.

For example, a lending app may say that the interest is “only 10%,” but the borrower receives much less than the face amount because of processing fees, service fees, platform fees, insurance fees, convenience fees, or other deductions. If the borrower is required to repay the full face amount within a short period, the effective interest rate may be far higher than what was advertised.

The relevant question is not only “What rate was written?” but also:

How much did the borrower actually receive?
How much must the borrower repay?
How many days was the loan period?
Were fees deducted upfront?
Were fees disclosed before acceptance?
Were penalties clearly explained?
Was the annualized or effective cost of credit shown?
Did the borrower have a real opportunity to review the terms?

If the disclosures were incomplete or confusing, the borrower may invoke truth-in-lending and consumer protection principles.

VI. Common Abusive Practices by Lending Apps

Borrowers frequently report the following practices:

Charging extremely high interest for very short loan terms;
Deducting large fees before releasing the loan;
Imposing daily penalties and compounding charges;
Requiring access to phone contacts;
Calling or messaging the borrower’s family, employer, friends, or colleagues;
Sending humiliating messages to third parties;
Threatening arrest or imprisonment;
Falsely claiming that nonpayment of debt is a criminal offense;
Creating group chats to shame the borrower;
Posting the borrower’s photo or personal details online;
Sending edited images, “wanted” posters, or defamatory statements;
Using profane, obscene, or threatening language;
Calling repeatedly at unreasonable hours;
Pretending to be lawyers, police officers, court staff, barangay officials, or government agents;
Threatening to file fabricated criminal charges;
Accessing or using data beyond what is necessary for lending; and
Refusing to provide a proper statement of account.

These practices may expose the lending company, its officers, collection agents, service providers, and individual collectors to administrative, civil, and criminal liability.

VII. Debt Is Generally a Civil Obligation, Not a Ground for Imprisonment

A key principle borrowers must understand is that nonpayment of a loan, by itself, is generally a civil matter. A person is not ordinarily imprisoned merely for failing to pay a debt.

This does not mean borrowers may ignore legitimate obligations. Lenders may file a civil collection case, demand payment, charge lawful penalties, report to appropriate credit systems if legally allowed, or pursue lawful remedies. But threatening imprisonment solely because of unpaid debt is generally misleading and abusive.

A lending app may not lawfully tell a borrower, without basis, that the borrower will be arrested, jailed, or criminally prosecuted simply for nonpayment. Criminal liability may arise only if there are separate facts constituting a crime, such as fraud, falsification, identity theft, or other criminal conduct. Mere inability to pay is not the same as fraud.

VIII. Harassment and Unfair Debt Collection

Fair collection is allowed. Harassment is not.

A lending company may remind a borrower of due dates, send demand letters, call within reasonable limits, negotiate repayment, or endorse the account to a legitimate collection agency. However, collection must be conducted with fairness, dignity, accuracy, and respect for privacy.

Collection becomes abusive when it involves:

Threats of violence;
Threats of arrest without lawful basis;
Profanity and insults;
Repeated calls intended to harass;
Public shaming;
Contacting uninvolved third parties;
Disclosure of debt to employers or relatives without lawful basis;
Misrepresentation of legal consequences;
False accusations of crimes;
Use of borrower photos or personal data for humiliation;
Pretending to be connected with courts, police, or government offices; or
Any conduct that goes beyond legitimate collection.

Borrowers should preserve evidence of these acts because harassment cases are fact-sensitive.

IX. Contacting Third Parties: When Is It Improper?

One of the most controversial practices of lending apps is contacting people in the borrower’s phone contacts. Some apps argue that the borrower consented by allowing contact-list access. This argument is legally questionable when the contacts are used for harassment, public shaming, or debt disclosure.

Third parties who are not co-borrowers, guarantors, sureties, or references generally have no obligation to pay the debt. Disclosing the borrower’s debt to them may violate privacy and fair collection rules.

Even if a borrower listed a person as a reference, that does not automatically authorize the lending app to harass, threaten, shame, or repeatedly call that person. The use of references must be limited, proportionate, and lawful.

X. Data Privacy Issues in Lending Apps

The Data Privacy Act requires that personal data processing be lawful, fair, and proportionate. Lending apps often collect sensitive amounts of data, including:

Name;
Address;
Phone number;
Government ID;
Facial image or selfie;
Employment information;
Emergency contacts;
Contact list;
Device identifiers;
Location data;
Photos;
Social media links; and
Financial information.

A lending app may violate privacy rules if it:

Collects more data than necessary;
Fails to explain why data is collected;
Uses data for harassment;
Shares borrower information with unauthorized persons;
Publishes borrower data online;
Sends debt information to contacts;
Accesses contacts without genuine, informed consent;
Retains data longer than necessary;
Fails to secure borrower data;
Uses deceptive consent mechanisms; or
Refuses to honor lawful data subject rights.

Borrowers have rights as data subjects, including the right to be informed, the right to access, the right to object, the right to erasure or blocking in proper cases, and the right to file complaints with the National Privacy Commission.

XI. “Name and Shame” Tactics

Some lending apps or collectors send messages to a borrower’s contacts stating that the borrower is a scammer, fraudster, thief, or criminal. Others create posters or social media posts containing the borrower’s face, address, phone number, or loan information.

These tactics can give rise to several legal issues:

Violation of data privacy rights;
Defamation or cyberlibel;
Unjust vexation;
Harassment;
Unfair debt collection;
Civil liability for damages;
Administrative sanctions from regulators; and
Potential criminal liability depending on the content and method.

Even if the borrower owes money, the lender does not gain the right to destroy the borrower’s reputation.

XII. Threats of Barangay, Police, NBI, Court, or Lawyer Action

Some collectors claim that barangay officials, police officers, NBI agents, sheriffs, or court personnel will come to the borrower’s house. Others say a warrant of arrest will be issued immediately.

Borrowers should treat such statements carefully. A real court case follows formal legal procedure. A warrant of arrest does not arise from an ordinary unpaid loan unless there is a valid criminal case and a judge issues a warrant according to law.

A legitimate demand letter from a lawyer is different from a threat pretending that criminal enforcement is automatic. Borrowers may verify the sender’s identity, law office, address, roll number if applicable, and the existence of any actual case.

Collectors who falsely represent themselves as lawyers, police officers, court employees, or government agents may face liability.

XIII. Can the Borrower Stop Paying Because of Harassment?

Harassment by the lender does not automatically erase a valid debt. If the borrower received money under a valid loan, the principal obligation may remain. However, harassment may give the borrower grounds to:

Contest excessive interest, penalties, and charges;
Demand a recomputation;
File complaints with regulators;
Seek damages;
Request cessation of unlawful processing of personal data;
Report abusive collectors;
Negotiate a settlement limited to principal and reasonable charges; or
Raise defenses if sued.

A practical approach is to separate the issues:

Debt issue: What amount is legally and fairly payable?
Conduct issue: Did the lender violate privacy, collection, consumer protection, or criminal laws?

The borrower should not ignore legal notices but should not submit to unlawful threats either.

XIV. What Borrowers Should Do Immediately

A borrower experiencing high-interest charges or harassment should take organized steps.

1. Preserve Evidence

Keep screenshots, call logs, text messages, chat messages, emails, social media posts, demand letters, payment receipts, app screenshots, loan terms, disclosure pages, and proof of disbursement.

Important evidence includes:

Date and time of calls;
Caller numbers;
Names used by collectors;
Exact words of threats;
Screenshots of group chats;
Messages sent to third parties;
Proof that contacts were messaged;
Loan amount applied for;
Amount actually received;
Amount demanded;
Interest and fees;
Payment history; and
The app’s permissions and privacy notice.

2. Revoke Unnecessary App Permissions

Borrowers should remove unnecessary app permissions, such as access to contacts, photos, camera, microphone, and location, where possible. They may also uninstall the app after preserving evidence and ensuring that account and loan records are saved.

3. Request a Statement of Account

The borrower may demand a written statement showing principal, interest, fees, penalties, payments made, and remaining balance. A lender should be able to explain how the amount was computed.

4. Communicate in Writing

Where possible, borrowers should communicate by email or written message. This creates a record and reduces the risk of verbal threats.

5. Notify Contacts

If contacts are being harassed, the borrower may inform them not to engage, not to pay, and to preserve screenshots. Third-party contacts may also file complaints if their privacy or peace is violated.

6. Avoid Giving New Access

Borrowers should avoid sending additional IDs, selfies, passwords, one-time passwords, or financial information unless they are certain the request is legitimate and necessary.

XV. Where to File Complaints

Depending on the issue, complaints may be filed with several offices.

A. Securities and Exchange Commission

The SEC is the primary regulator for lending and financing companies. A borrower may complain about:

Unfair collection practices;
Unauthorized lending operations;
Lack of Certificate of Authority;
Excessive or undisclosed charges;
Misleading loan terms;
Harassment by online lending platforms;
Abusive collectors; and
Violations of SEC rules.

The complaint should include the company name, app name, screenshots, loan documents, messages, collector numbers, and proof of payment.

B. National Privacy Commission

The National Privacy Commission handles complaints involving misuse of personal data. A complaint may be appropriate where the lending app:

Accessed phone contacts improperly;
Sent debt information to third parties;
Posted personal details online;
Used photos or IDs for shaming;
Failed to protect borrower data;
Refused data subject requests; or
Processed data without valid consent or lawful basis.

C. Philippine National Police Anti-Cybercrime Group or NBI Cybercrime Division

If threats, cyberlibel, identity misuse, online shaming, extortion, or digital harassment occurred, the borrower may seek assistance from cybercrime authorities.

D. Prosecutor’s Office

For possible criminal offenses, a complaint-affidavit may be filed with the prosecutor’s office. The evidence must be organized and must show the elements of the alleged offense.

E. Courts

Borrowers may seek judicial relief in appropriate cases, including damages, injunctions, or defenses in collection suits. Courts may also reduce unconscionable interest and penalties.

F. Barangay

For some disputes between individuals in the same city or municipality, barangay conciliation may be required before court action. However, corporate or cybercrime-related matters may involve different rules, and legal advice may be needed.

XVI. Possible Legal Claims and Causes of Action

Depending on the facts, a borrower may raise or pursue:

Violation of lending regulations;
Violation of disclosure requirements;
Unfair or abusive debt collection;
Violation of data privacy rights;
Breach of contract;
Nullity or reduction of unconscionable interest;
Damages for mental anguish, embarrassment, or reputational harm;
Defamation or cyberlibel;
Unjust vexation;
Grave threats or coercion;
Injunction against continued harassment;
Administrative complaint against the company;
Complaint against individual collectors; and
Complaint against third-party collection agencies.

The proper remedy depends on the exact conduct, evidence, amount involved, and identity of the lender.

XVII. Liability of Collection Agencies

A lending app may outsource collection to a third-party collection agency, but outsourcing does not eliminate responsibility. A lender may still be held accountable for abusive collection done on its behalf, especially if it authorized, tolerated, ignored, or benefited from the conduct.

Collection agencies and individual collectors may also be independently liable for their own unlawful acts.

Borrowers should document whether the collector identified the lending company, agency, supervisor, office address, or account reference number.

XVIII. The Role of Consent in Lending Apps

Many lending apps rely on consent forms, privacy policies, and app permissions. However, consent must be informed, specific, freely given, and limited to legitimate purposes.

A borrower’s act of clicking “I agree” does not necessarily validate:

Excessive data harvesting;
Public shaming;
Disclosure of debt to contacts;
Threats;
Harassment;
Misleading charges;
Waiver of basic legal rights; or
Unconscionable terms.

Contracts of adhesion, such as standard-form app agreements, may be interpreted against the party that drafted them when provisions are unclear or oppressive.

XIX. Can a Lending App Access a Borrower’s Contacts?

A lending app should not access contacts unless such access is necessary, proportionate, clearly explained, and supported by a lawful basis. Even then, use of the contact list must be limited.

Accessing contacts to evaluate credit risk is already sensitive. Using contacts to shame or pressure the borrower is far more problematic. The borrower’s contacts are separate data subjects. They usually did not consent to have their personal information harvested by the lending app.

This is one of the strongest legal issues in many online lending harassment cases.

XX. What Counts as Excessive Interest?

There is no single universal number that automatically determines illegality in all private lending cases. The assessment depends on the totality of circumstances. The following factors matter:

Principal amount;
Amount actually received;
Loan term;
Stated interest rate;
Effective interest rate;
Processing fees;
Service fees;
Rollover fees;
Penalties;
Compounding;
Disclosure quality;
Bargaining power;
Whether the borrower understood the terms;
Whether the charges are grossly disproportionate;
Whether the lender engaged in deception or pressure; and
Whether the terms shock the conscience.

Short-term app loans may look small in nominal terms but become oppressive when annualized or when fees are deducted upfront.

XXI. Sample Computation Issue

Suppose a borrower applies for ₱5,000 but receives only ₱3,500 after deductions. The app demands ₱5,000 after seven days, plus penalties if unpaid. The borrower may question the true finance charge because the borrower did not actually receive ₱5,000. The effective cost should be evaluated against the amount actually released and the short repayment period.

If the app did not clearly disclose this before the borrower accepted the loan, there may be disclosure and consumer protection issues.

XXII. Defenses When the Lending App Files a Case

If a lender files a collection case, the borrower should not ignore summons or court notices. Possible defenses or counterclaims may include:

The interest is unconscionable;
Penalties are excessive;
Charges were not properly disclosed;
Payments were not properly credited;
The amount claimed is incorrect;
The lender violated privacy rules;
The lender engaged in harassment;
The lender lacks authority to operate;
The contract contains void or abusive provisions;
The borrower is entitled to damages or set-off.

A borrower should prepare receipts, screenshots, bank records, app records, and communication history.

XXIII. Settlement and Negotiation

Many borrowers prefer settlement to avoid prolonged stress. A fair settlement may involve:

Payment of principal actually received;
Waiver or reduction of excessive interest;
Waiver of penalties;
Written confirmation of full settlement;
Deletion or lawful limitation of personal data;
Cessation of contact with third parties;
Removal of defamatory posts;
Written apology where appropriate;
Agreement that no further collection will occur; and
Official receipt or acknowledgment.

Borrowers should avoid verbal-only settlements. Any settlement should be in writing and should clearly state that payment is in full satisfaction of the account.

XXIV. Practical Demand Letter Points

A borrower’s letter to a lending app may demand:

A complete statement of account;
Proof of SEC registration and Certificate of Authority;
Copy of the signed or accepted loan agreement;
Explanation of all interest, fees, and penalties;
Immediate cessation of harassment;
No further contact with third parties;
Deletion or blocking of unlawfully processed data;
Identification of collection agents;
Correction or removal of defamatory messages;
Recalculation of the debt based on lawful and reasonable charges; and
Written confirmation of compliance.

The tone should be firm, factual, and evidence-based.

XXV. Evidence Checklist

A strong complaint usually includes:

Borrower’s full name and contact details;
Lending app name;
Company name;
SEC registration number, if known;
Certificate of Authority number, if known;
Screenshots from the app store;
Screenshots of the app interface;
Loan agreement or terms;
Disclosure statement;
Amount applied for;
Amount received;
Date of release;
Due date;
Amount demanded;
Payment receipts;
Collector messages;
Call logs;
Screenshots from contacts who were messaged;
Social media posts;
Threatening or defamatory content;
Privacy policy;
App permission screenshots;
Names and numbers of collectors; and
Timeline of events.

The clearer the timeline, the stronger the complaint.

XXVI. Rights of Third Parties Contacted by the Lending App

Relatives, friends, coworkers, and employers contacted by the lending app may also have rights. They are not automatically liable for the borrower’s debt. If they were insulted, threatened, repeatedly called, or sent private borrower information, they may preserve evidence and file their own complaints.

Employers should not be pressured into deducting salary or disciplining the borrower unless there is a lawful basis. A private debt collector cannot simply command an employer to pay the borrower’s debt.

XXVII. Employer and Workplace Harassment

Contacting the borrower’s workplace can be especially damaging. It may cause embarrassment, reputational harm, or employment consequences. Unless the employer is a guarantor, co-maker, payroll partner, or otherwise lawfully involved, disclosure of the borrower’s debt to the workplace may be improper.

Borrowers should document:

Who was contacted;
What was said;
Whether the debt was disclosed;
Whether threats were made;
Whether the collector used official-looking documents;
Whether the borrower suffered workplace consequences.

XXVIII. Public Posting and Cyberlibel Concerns

If a collector posts the borrower’s photo with accusations such as “scammer,” “thief,” or “fraudster,” this may raise defamation concerns. If posted online, cyberlibel may be considered depending on the content, publication, identifiability, malice, and other legal elements.

Truth is not always a complete shield if the post is made in an abusive, excessive, or unlawful manner. Debt collection should be pursued through lawful channels, not public humiliation.

XXIX. The Borrower’s Own Responsibilities

Borrowers also have responsibilities. They should:

Read loan terms before accepting;
Borrow only what they can reasonably repay;
Keep records;
Avoid using false identities or documents;
Avoid taking new loans to pay old app loans without a plan;
Communicate in writing;
Pay lawful obligations when able;
Seek restructuring if necessary;
Avoid ignoring court documents; and
Avoid retaliatory threats or defamatory posts.

A borrower’s rights against harassment exist even when the borrower is in default. However, the borrower should act carefully and lawfully.

XXX. Red Flags Before Using a Lending App

Before borrowing, consumers should watch for red flags:

No clear company name;
No SEC Certificate of Authority shown;
Unclear interest and fees;
Very short repayment periods;
High upfront deductions;
Required access to contacts and photos;
No physical address;
Poor reviews mentioning harassment;
No customer support channel;
Threatening language in terms;
Automatic rollover fees;
Refusal to provide written loan documents;
App not matching the registered company name.

Borrowers should verify the company and read the permissions requested by the app before proceeding.

XXXI. Remedies Against Excessive Charges

Where interest, penalties, or fees are excessive, borrowers may seek:

Recalculation;
Reduction of interest;
Waiver of penalties;
Administrative action by regulators;
Judicial reduction of unconscionable charges;
Damages where warranted;
Settlement based on principal and reasonable interest;
Refund or crediting of overpayments in appropriate cases.

The borrower should not rely only on verbal assurances. Any recalculation or waiver should be documented.

XXXII. Remedies Against Harassment

For harassment, borrowers may seek:

Cease-and-desist demands;
SEC complaint;
National Privacy Commission complaint;
Cybercrime complaint;
Criminal complaint, where applicable;
Civil action for damages;
Injunction, in appropriate cases;
Complaint against the collection agency;
Complaint against individual collectors;
Takedown requests for unlawful posts;
Preservation of digital evidence.

The most effective remedy often depends on the type of harassment. Privacy-related misuse of contacts may be best raised with the National Privacy Commission, while abusive lending practices may be brought to the SEC. Threats, defamation, and online shaming may require law enforcement or prosecutor action.

XXXIII. Sample Borrower Position

A borrower may take the following position:

“I acknowledge that I may have an obligation to pay the lawful amount actually owed. However, I dispute the excessive interest, undisclosed fees, penalties, and unlawful collection practices. I demand a complete statement of account and a recomputation. I also demand that the company and its agents stop contacting third parties, stop disclosing my personal information, and stop using threats, insults, or public shaming. I reserve my right to file complaints with the SEC, the National Privacy Commission, law enforcement, and the courts.”

This position recognizes the debt issue while firmly opposing unlawful conduct.

XXXIV. Important Distinction: Inability to Pay vs. Fraud

Lending apps sometimes accuse borrowers of fraud merely because they missed payment. This is improper if there is no evidence of deceit at the time the loan was obtained.

Fraud generally requires more than nonpayment. It involves deceit, false pretenses, or fraudulent intent. A borrower who intended to pay but later became unable to do so is different from a person who used fake identities or falsified documents to obtain money.

Collectors should not casually label borrowers as criminals.

XXXV. Conclusion

SEC registration does not authorize a lending app to impose oppressive charges, hide the true cost of credit, misuse personal data, or harass borrowers. Philippine law protects both the right of lenders to collect legitimate debts and the right of borrowers to be treated with fairness, dignity, transparency, and privacy.

A borrower facing high interest and harassment should preserve evidence, request a statement of account, challenge excessive charges, revoke unnecessary app permissions, communicate in writing, and file complaints with the proper agencies where warranted.

The central rule is simple: a lender may collect what is lawfully due, but it may not use fear, humiliation, threats, privacy violations, or public shaming as collection tools.