How to file a SEC complaint against an online lending app

Before filing, look up the company. SEC maintains a public list of registered lending and financing companies and a complementary list of cease-and-desist or revoked entities. The company name on the loan agreement may differ from the operator behind the app — many apps are operated by a separately incorporated lender.

If the lender is unregistered, that fact alone is a violation. Operating a lending company without a Certificate of Authority under RA 9474 carries a penalty of up to ₱1,000,000 and ten years' imprisonment. Cite this in your complaint.

SEC Memorandum Circular No. 18, series of 2019, lists prohibited debt-collection practices. The most-cited grounds are: contacting persons in the borrower's contact list other than the borrower's stated co-makers or guarantors; threats of violence or harm; obscene or profane language; misrepresentation of legal authority; communication at unreasonable hours (before 6 AM or after 10 PM); and public disclosure of the debt to the borrower's employer, social network, or family.

For each violation you allege, identify the specific paragraph of MC-18, the date and channel (call, SMS, Viber, Messenger), and the message content. The Commission's Corporate Governance and Finance Department dismisses complaints that allege harassment in the abstract; specific paragraph citations and timestamped evidence move cases forward.

SEC will not act on screenshots without metadata. Collect: the original SMS thread on the device, complete with sender number; call logs showing date, time, and number; Messenger or Viber threads with the lender's named profile (download the chat where possible); and any third-party-contacted complaints (your friends or family who received messages from the lender — get them to forward the message and a sworn statement).

Where possible, supplement with the app's Play Store or App Store listing screenshot showing developer details, and a screenshot of the in-app permissions screen at install time. The latter shows whether the app demanded access to contacts, SMS history, photos, and location — relevant to a parallel National Privacy Commission filing.

SEC accepts complaints by email to cgfd@sec.gov.ph (Corporate Governance and Finance Department) and through the FinCare e-complaint portal. Address the email to: Director, Corporate Governance and Finance Department, Securities and Exchange Commission, Secretariat Building, PICC Complex, Roxas Boulevard, Pasay City. Subject line: "Complaint under SEC MC 18 — [Company name] — [Date]."

In the body: identify yourself, identify the respondent (corporate name, SEC registration number if known, app name), state the violations with paragraph citations, summarise the facts, and request relief: investigation, suspension or revocation of the Certificate of Authority, takedown order against the application, and imposition of administrative fines under SEC's enforcement powers. Sign the complaint and have it notarised — SEC requires a verified complaint for formal proceedings.

SEC enforces lending-company rules. The National Privacy Commission enforces RA 10173 (Data Privacy Act) violations such as unauthorised contact-list scraping. The BSP handles bank-side issues if the lender uses a partner bank for disbursement. These regulators do not coordinate intake; you must file separately with each.

A parallel NPC filing is particularly useful when the lender used your contact list to send shaming messages, because that conduct is both an MC-18 unfair-collection violation and a Data Privacy Act violation. The NPC has previously ordered takedowns of lending apps including JuanHand, Pesopop, CashJeep, and Lemon Loan in March 2021, and decided against Cashalo (NPC SS-21-005) in June 2022.

SEC acknowledges complaints within five business days. The Corporate Governance and Finance Department evaluates, may issue a show-cause order to the company, and can elevate to the En Banc for a cease-and-desist or revocation order. The process can take six to eighteen months for a final disposition.

While your complaint is pending, the strongest accelerant is volume. SEC's enforcement actions against online lenders (the 2019–2022 takedown wave) followed coordinated complaint volumes from groups of borrowers. If your friends or family received the same harassing messages, encourage them to file separately. Each filing is independent under SEC procedure.