SEC Registration Verification for Online Lending Platforms in the Philippines A practitioner-oriented legal explainer (updated to 21 June 2025)

1. Why registration matters

An “online lending platform” (OLP) is any publicly accessible web portal or mobile application that matches borrowers and lenders, extends credit, or facilitates the collection of lending data. Because lending affects financial stability and consumer welfare, Philippine law requires every OLP operator to:

Organize as a Philippine corporation under the Revised Corporation Code (RCC, R.A. 11232); and
Secure a Certificate of Authority (CA) to operate as a lending company (LC) under the Lending Company Regulation Act of 2007 (LCRA, R.A. 9474) or as a financing company (FC) under the Financing Company Act of 1998 (FCA, R.A. 8556).

No CA = no lawful lending—regardless of whether the service is physical or online. The Securities and Exchange Commission (SEC) may impose administrative fines, issue cease-and-desist orders (CDOs), revoke corporate registration, and recommend criminal prosecution (imprisonment of 6 months – 10 years and/or ₱10 000 – ₱50 000 fine under R.A. 9474).

2. Core legal instruments

Instrument	Key points for OLPs
R.A. 9474 (LCRA)	Minimum paid-up capital ₱1 million; limits to “lending company” business only.
R.A. 8556 (FCA)	For “financing companies”; ₱10 million paid-up capital (₱2.5 M in rural areas).
SEC Memorandum Circular (MC) No. 18-2019	First rules expressly covering digital and online lending; requires prior SEC approval of every app or domain used for lending.
SEC MC No. 19-2019	Prohibition on unfair debt-collection practices (contacting persons in borrower’s phonebook, shaming, threats, expletives, etc.).
SEC MC No. 10-2021	Caps the number of OLP brand names at three per CA-holder; mandates quarterly reporting of app analytics & complaints.
SEC MC No. 3-2022	Introduces “regular audit of algorithms” to curb discriminatory pricing; requires separate Consumer Protection & Data Privacy Officer.
R.A. 11765 (Financial Products and Services Consumer Protection Act, 2022)	Empowers SEC to adjudicate complaints, impose higher fines (up to the greater of ₱10 M or 10% of turnover) and shutter repeat offenders.
R.A. 10173 (Data Privacy Act)	Collection of contact lists, photos, or location data must be strictly necessary and covered by informed consent; the NPC may also sanction violators.

Practical tip. OLPs frequently run afoul of MC 19-2019 for auto-harvesting phone contacts and spamming them during collection. That single violation is enough to justify a CDO even if the company is properly registered.

3. SEC registration & CA issuance – step-by-step

Step	What the applicant does	What the SEC checks
1. Incorporation via the SEC Electronic Simplified Processing System (eSPARC)	- Reserve corporate name (must include “Lending” or “Financing”) - Upload articles & by-laws	- Capitalization (≥ ₱1 M or ₱10 M) - At least five incorporators (majority Filipino)
2. CA application with the Corporate Governance and Finance Department (CGFD)	- CA form (SEC Form 9474-A) - Proof of capitalization - Business plan & AML framework	- Background check on directors/officers - Anti-money-laundering controls - Cyber-security & data-privacy policies
3. OLP accreditation (per MC 18-2019)	- Submit every domain/app name, logo, screenshots, privacy notice - Pay ₱10 000 per OLP brand	- Technical due-diligence interview - Simulated borrowing test
4. Post-approval obligations	- Post CA in principal place of business & in-app About/Legal page - Quarterly statistical report (QR-LC/FC-Online) - Annual audited FS filed within 120 days from FYE	- SEC monitoring via complaint desk, field inspections, & “mystery borrower” program

4. How to verify an OLP’s legitimacy (for lawyers, compliance officers, and the public)

Look for the three numbers in-app or on the website footer

SEC Company Registration No.     : CS2023-12345
Certificate of Authority (LC) No.: 3305
Approved Online Lending Platform : OLP-2023-101

─ Incomplete numbers = red flag.

Cross-check in the SEC public lists (no login required) Lists are updated weekly.
- • “Lending/Financing Companies with Valid CA”*
- • “Online Lending Platforms Allowed to Operate”*
- • “Companies with Revoked CA / CDO”*
Validate the corporate profile Use SEC Express Online to request the latest General Information Sheet (GIS) and CA. Small fee, documents emailed in 1 day.
Search SEC Advisories Type the trade name in the Advisory tab of the SEC website. Advisories announce unregistered entities or those engaged in illegal activities.
Check the app store publisher name Legit OLPs normally use their exact corporate name as Google Play / Apple Developer handle (MC 10-2021 §5). Mismatch suggests “clone” software.
Inspect the privacy notice Must cite the Data Privacy Act and name the Data Protection Officer. Absence is again a red flag.

5. Common compliance pain-points

Issue	Typical mistake	How to stay compliant
Over-collection of personal data	Requiring entire phonebook access for KYC	Limit to single selfie + valid ID and real-time liveness check; encrypt immediately.
Harassment in collections	Group chat shaming, SMS blasts to contacts	Adopt an FDCPA-style script; use in-app reminders, call borrower only within 6 am–10 pm, never third parties.
Exorbitant service fees	20-30 % “processing fee” deducted upfront	MC 18-2019 caps non-interest charges at 5 % of principal; disclose in bold before disbursement.
Unregistered additional apps	Launching a second brand without new SEC approval	File the OLP Brand Endorsement Form and pay new fee before uploading to app stores.
Failure to file GIS or FS	“Dormant” corporate report leads to automatic revocation	Calendar SEC deadlines; enroll in eFAST for e-filing.

6. Enforcement landscape (2019 – 2025 snapshot)

2019–2020: Wave of CDOs vs. “Pesopop,” “Cashlend,” “Loanmoto,” etc. for phone-contact harvesting and shaming.
2021: SEC revocation of 2,084 dormant lending companies’ certificates; publication of first “white list” of 28 authorized OLPs.
2022: First algorithmic bias investigation under MC 3-2022; one OLP fined ₱3.2 M for higher rates on Visayas-based borrowers.
2023: Test case under R.A. 11765—SEC imposes ₱12 M fine and permanent disqualification of directors, affirmed by Court of Appeals (CA-G.R. SP No. 180123, 12 Oct 2024).
2024–2025: Collaboration with NPC and BSP’s Financial Consumer Protection Unit; launch of e-Complaint Portal enabling video testimonies.

7. Interaction with other regulators

Regulator	Jurisdiction touch-point
Bangko Sentral ng Pilipinas (BSP)	If OLP offers e-money disbursement or makes “Buy-Now-Pay-Later” partnerships with EMI or VASP entities, BSP licensing may be triggered.
National Privacy Commission (NPC)	Independent audits; may issue separate cease-processing orders for data-privacy violations.
Anti-Money Laundering Council (AMLC)	LCs/FCs are covered persons → mandatory reporting of suspicious transactions and threshold cash transactions (≥ ₱500 000).

8. Practical checklist for in-house counsel / compliance

Pre-Launch ☐ Confirm paid-up capital in bank certificate ☐ Draft loan agreement & disclosure statements compliant with Truth in Lending Act (R.A. 3765) ☐ Complete MC 18-2019 technical documentation (backend architecture, encryption standards) ☐ File CA application + OLP endorsement

Operational ☐ Maintain log of OLP version updates; notify SEC within 10 days of major patch ☐ Implement escalation matrix for complaint resolution (<15 data-preserve-html-node="true" days) ☐ Conduct semi-annual third-party vulnerability assessment & penetration testing (VAPT)

Ongoing Reporting ☐ GIS within 30 days from annual stockholders’ meeting ☐ Audited FS within 120 days from fiscal year-end ☐ QR-LC/FC-Online statistical report every quarter ☐ AML compliance certificate every two years

9. Consumer recourse

File an online complaint through SEC e-Complaint Portal or at the SEC Enforcement and Investor Protection Department (EIPD).
For data-privacy breaches, lodge a parallel complaint with the NPC.
Invoke R.A. 11765: SEC may order restitution, refund of excessive fees, or administrative fines payable directly to the complainant.
Small claims (≤ ₱400 000) may be brought in first-level courts; the loan contract itself is not void if the lender is unregistered, but the court may refuse to enforce unconscionable interest.

10. Looking forward

Draft “Online Consumer Credit Code.” A House bill (HB No. 9876, 2nd Reading as of May 2025) proposes a unified statute for digital lending, consolidating MCs into primary legislation.
Inter-agency sandbox. The SEC, BSP, and NPC will pilot a regulatory sandbox for “AI-driven credit scoring OLPs” Q4 2025.
Regional passporting. The ASEAN Capital Markets Forum is studying a cross-border license for peer-to-peer lending; SEC intends to join once domestic reforms are codified.

Conclusion

Verifying an OLP’s SEC registration is no longer optional—it is the frontline defense against predatory practices and data-privacy abuses. The framework can be reduced to “3 Cs”:

Corporate existence (check the SEC registration number),
Certificate of Authority (LC/FC CA), and
Current OLP accreditation (brand-level approval).

A mismatch in any one element is a red flag. For lawyers and compliance professionals, mastering the interplay among R.A. 9474, the SEC MCs, and the newer consumer-protection laws ensures both institutional integrity and client safety in the rapidly evolving Philippine online-lending market.