Where to File a Complaint Against an Online Lending App in the Philippines (A practitioner-oriented guide as of June 2025)
1. Regulatory Snapshot
| Regulator / Forum | When to Complain | Key Legal Basis | Expected Relief |
|---|---|---|---|
| Securities and Exchange Commission (SEC) – Financing & Lending Companies Division, Corporate Governance and Finance Department | The app is a lending or financing company (registered or not) engaging in abusive collection, unregistered operations, misrepresentation. | ▸ Lending Company Regulation Act (RA 9474) ▸ SEC Memorandum Circular 18-2019 & 28-2021 (prohibiting unfair debt-collection) ▸ Financial Products & Services Consumer Protection Act (RA 11765) |
- Cease-and-desist order - Revocation of license & fines - Take-down of the app from Google Play/App Store |
| Bangko Sentral ng Pilipinas (BSP) – Consumer Protection and Market Conduct Office | The lender is a bank, e-money issuer, or non-bank financial institution supervised by BSP (ex: an app operated by a thrift bank). | ▸ RA 7653 (BSP Charter, as amended) ▸ RA 11765 & BSP Circular 1160-2023 (Consumer Protection) |
- Monetary penalties - Direction to refund or correct records |
| National Privacy Commission (NPC) | The app scraped your contacts, leaked your data, or shamed you through “contact blasting.” | ▸ Data Privacy Act (RA 10173) ▸ NPC Circular 2023-01 (Complaints procedure) |
- Order to delete data - Protective order, fines, criminal referral |
| National Telecommunications Commission (NTC) | Spam texts or spoofed calls originate from the lender or its agents. | ▸ Public Service Act ▸ NTC Memorandum 05-2024 (SMS spam) |
- Blocking of numbers - Fines to telco or content provider |
| Department of Trade & Industry (DTI) – Fair Trade Enforcement Bureau | Misleading advertising or hidden fees on consumer loans below ₱250,000. | ▸ Consumer Act (RA 7394) | - Administrative fines - Mediation / arbitration |
| PNP Anti-Cybercrime Group (PNP-ACG) / NBI Cybercrime Division | Harassment, threats, doxxing, online libel, phishing, or fake court summons. | ▸ Revised Penal Code (libel, unjust vexation, grave threats) ▸ Cybercrime Prevention Act (RA 10175) |
- Criminal investigation, arrest, takedown |
| Barangay/Katarungang Pambarangay | Purely civil collection disputes ≤ ₱400,000 vs. a neighbor debt collector (rare). | ▸ Local Government Code (RA 7160) | - Mediation, amicable settlement |
| Regular Courts / Small Claims | Damages, injunction, or collection counter-suit. Small claims cap: ₱400,000 (A.M. 08-8-7-SC, as amended 2024). | Civil Code Arts. 19-21, 32, 26; RA 11765 (consumer suits); Data Privacy Act; RPC | - Monetary award, TRO/PI, moral damages |
2. How to Determine the Proper Forum
Identify the entity behind the app. Look for the SEC Registration No., Certificate of Authority (CA) number, or BSP “OR No.” on the splash screen, website footer, or Google Play listing.
Match the conduct to a legal violation.
- Unregistered app → SEC (registration & licensing).
- Harassment / shaming → SEC (MC 18-2019) and NPC (data privacy).
- Hidden interest or “processing fee” → SEC, BSP or DTI (depending on licence).
- Threats / doxxing → PNP-ACG / NBI for criminal case; civil damages in court.
Sequence your actions.
- Internal dispute resolution (IDR). RA 11765 requires lenders to maintain a Consumer Assistance Unit (CAU) and give a written response within 15 calendar days. Keep the ticket/reference number.
- Regulator escalation if IDR fails, or immediately for serious harassment.
- Parallel complaints are allowed: e.g., you may file simultaneously at SEC and NPC.
3. Filing Procedures (Step-by-Step)
| Regulator | Channels | Documentary Requirements | Fees | Turn-around |
|---|---|---|---|---|
| SEC | • Online: SEC eFAST → “Company Complaints” • Email: cgfd@sec.gov.ph • Walk-in: PICC Secretariat Bldg., Pasay City |
─ Complaint-affidavit (notarized) ─ Valid ID ─ Proof of transaction (screenshots, SOA, bank slips) ─ Proof of harassment (recordings, SMS export) |
None | 30 days for evaluation; CDO may issue within 24 h for grave cases |
| BSP CAMS | • https://www.bsp.gov.ph/CAMS • Hotline: (02) 8708-7087 |
Same as SEC plus proof of prior IDR | None | 10 days for initial reply; 45 days to resolve |
| NPC | • Cases Portal (https://complaints.privacy.gov.ph) • Email: complaints@privacy.gov.ph |
─ Filled-out Complaint Form ─ Sworn attestation of failed mediation ─ Evidence of personal data misuse |
None | 35 days for fact-finding; orders executory upon receipt |
| NTC | • Email: consumer@ntc.gov.ph • SMS: 0919-888-NTC1 |
─ Screenshot of spam ─ Sender’s number / shortcode |
None | Blocking within 3-5 days |
| DTI | • FTC e-complaint portal (https://ftc.dti.gov.ph) | ─ Complaint form ─ Proof of purchase/service |
None; small arbitration fee if escalated | 10-15 days mediation |
| PNP-ACG | • Camp Crame walk-in • One-stop “E-Complaint Desk” Facebook page |
─ Sinumpaang Salaysay ─ Two IDs ─ Digital evidence |
None | Variable; inquest within 36 h for warrantless arrests |
4. Gathering Winning Evidence
Screenshots or screen recording of:
- Loan offer page (interest, tenor, fees).
- Threatening messages, group chats, social-media posts.
Metadata: export SMS in .xml, retain email headers.
Audio recordings (lawful in PH if you are a party to the call).
Bank statements / GCASH history for disbursement & repayment.
Timeline of events (use a spreadsheet).
Copies of IDs only with redactions: write “For SEC Case No. ____ only” in permanent marker to curb identity theft.
5. Criminal vs. Civil Remedies
| Conduct | Potential Crimes | Penalty Range |
|---|---|---|
| Publicly posting the borrower’s photo with “Scammer” caption | Grave Threats (Art. 282 RPC) or Libel (Art. 355) or Unjust Vexation (Art. 287) | Arresto mayor – Prisión correccional; up to ₱1 M fine (cyber-libel multipliers) |
| Accessing phone contacts without consent | Unauthorized Processing of Personal Data (Sec. 25 RA 10173) | 1–3 yrs & ₱500k–₱2 M |
| Using bots to spam texts | Sec. 12 Cybercrime Act, Sec. 7 SIM Registration Act (RA 11934) | 6 yrs &/or ₱4 M |
Civilly, you may sue for: Actual damages (lost job for reputational harm), Moral damages (humiliation), Exemplary damages (to deter), and Attorney’s fees (Art. 2208 Civil Code). Small claims require no lawyer; regional trial courts do.
6. Penalties Imposed on Rogue Apps (Illustrative)
| Year | App / Company | Regulator Action | Outcome |
|---|---|---|---|
| 2023 | “H•••Cash” | SEC CDO + Google Play takedown | ₱1.4 M fine; CA revoked |
| 2024 | “PesoFlash” (BSP-licensed EMI) | BSP administrative case | ₱3 M penalty; mandated refund ₱7 M to 18,000 users |
| 2025 | “EasyLoan PH” | NPC enforcement order | Ordered data deletion; officers indicted under RA 10173 |
7. Practical Tips for Complainants
Act quickly—screenshots of the app may disappear after updates.
Keep emotions off paper; stick to facts and legal grounds.
Bundle complaints: The SEC welcomes consolidated affidavits from multiple borrowers, strengthening the public-interest angle.
Monitor dispositions via SEC Helpline Portal; download orders for your records.
Follow-up politely every 15 days; agencies clock SLA but dockets are congested.
Seek free legal help:
- Public Attorney’s Office (if your net monthly income ≤ ₱24k outside NCR, ≤ ₱27k in NCR).
- Integrated Bar of the Philippines Legal Aid.
- Law school clinics (UP, Ateneo, San Beda, etc.).
8. FAQs
| FAQ | Answer |
|---|---|
| Can I refuse app permission to contacts/camera? | Yes. RA 10173 enshrines data minimization and legitimate purpose. Denial of a non-essential permission cannot be used to increase your interest rate. |
| Will complaining hurt my credit score? | No. Credit bureaus may only record factual defaults; filing a complaint is not a default event. |
| Is bankruptcy an option? | The Personal Property Security Act (RA 11057) and the Financial Rehabilitation Rules 2021 acknowledge consumer insolvency, but courts remain reluctant. Debt restructuring via voluntary settlement is faster. |
| Can foreigners use this guide? | Yes, but you must appoint a PH-based attorney-in-fact for notarized filings. |
9. Conclusion
The Philippines now treats consumer-finance misconduct—especially by online lending apps—as a multi-regulator problem. The SEC remains the first stop for most grievances, but the BSP, NPC, NTC, DTI, and law-enforcement agencies all have bite. Filing in the right venue, with well-organized evidence, usually yields faster relief than venting on social media. Borrowers should exhaust internal remedies, document every interaction, and escalate without delay when lenders cross the line from lawful collection to abuse.
This article summarizes law and procedure as of 18 June 2025. It is not a substitute for formal legal advice.