SEC Memorandum Circular No. 19 (2019): Disclosure Requirements for Online Lending Platforms

Summary

SEC Memorandum Circular No. 19, Series of 2019, requires every financing or lending company operating an Online Lending Platform (OLP) to disclose to the SEC and to the borrower the names and details of all OLPs it operates, all third-party service providers, and the data the platform collects from users. It mandates that the SEC's authority to operate be reflected in app-store listings and on the platform itself, and forms the disclosure backbone of subsequent SEC enforcement against unregistered or undisclosed OLPs.