Below is an overview of the legal and administrative avenues one can pursue in the Philippines to file a complaint against a lending application (“lending app”). It covers the primary government agencies with jurisdiction over these matters, the relevant laws, what types of complaints each agency typically handles, and practical guidance on how to lodge such complaints.

1. Overview of Laws and Regulatory Authorities

1.1. Lending Company Regulation Act of 2007 (R.A. 9474)

Purpose: Governs and regulates all lending companies in the Philippines.
Key Point: Requires every lending company (including those operating via mobile applications) to register with the Securities and Exchange Commission (SEC). Non-compliant entities may face penalties and closure.

1.2. Securities and Exchange Commission (SEC)

Role: Primary regulator of lending companies. Oversees compliance with corporate rules and the Lending Company Regulation Act.
Enforcement: The SEC, through its Enforcement and Investor Protection Department (EIPD), investigates reports of violations, such as illegally operating lending apps, excessive and hidden charges, or abusive collection practices.

1.3. Bangko Sentral ng Pilipinas (BSP)

Role: Regulates banking institutions, e-money issuers, and other financial entities that may also offer lending via apps (e.g., digital banks or bank-affiliated fintech lenders).
Note: If the lending app is operated by or partnered with a bank, the BSP may have regulatory authority as well.

1.4. National Privacy Commission (NPC)

Role: Oversees data privacy and data protection under the Data Privacy Act of 2012 (R.A. 10173).
Complaint Basis: If the lending app mishandles personal information, harvests excessive permissions from your phone (e.g., contacts, photos) without consent, or commits privacy breaches such as unauthorized disclosure of personal data.

1.5. Department of Trade and Industry (DTI)

Role: Implements the Consumer Act (R.A. 7394), which covers certain types of consumer complaints.
Note: While the DTI may not be the main venue for lending disputes (the SEC typically handles these), it can entertain complaints about misleading advertisements, unfair trade practices, or other consumer protection issues.

1.6. Philippine National Police (PNP) / NBI Cybercrime Division

Role: Addresses criminal aspects, including harassment, cyber-libel, unlawful debt collection practices, or if a lender’s staff threatens or intimidates borrowers.
Note: If a lending company’s representatives harass or threaten you via text messages, calls, or social media, you may file a complaint with the PNP’s Anti-Cybercrime Group or the NBI Cybercrime Division.

2. Common Grounds for Filing a Complaint

Unauthorized or Unfair Collection Practices
- Threats, harassment, or other abusive tactics in collecting debts.
- Public shaming or unauthorized contact of personal references.
- Excessive collection charges or fees not clearly disclosed in the loan agreement.
Exorbitant or Hidden Fees and Charges
- Interest rates well above the legal limit or far beyond what is stated in the loan agreement.
- Additional or “hidden” fees that were not disclosed at the time of contracting.
Misleading Advertising or False Promises
- Claims of “low interest” or “interest-free” loans that turn out to have high hidden charges.
- Misrepresentations about terms, conditions, or promotional benefits.
Privacy Violations
- Accessing a borrower’s phone contacts without explicit consent.
- Using or disclosing personal data for purposes other than loan repayment without authorization.
- Posting or threatening to post personal information online.
Unregistered Lending Operations
- Lending companies or apps operating without the requisite SEC license or failing to comply with regulations.
- Entities that do not provide legitimate business addresses or contact details.

3. Where and How to File Complaints

3.1. Filing a Complaint with the Securities and Exchange Commission (SEC)

a. When to Approach the SEC:

The lending app is suspected of operating without proper registration.
The company is engaging in predatory lending, charging illegal or exorbitant rates, or violating provisions of R.A. 9474.
There are deceptive or unfair practices that violate SEC regulations.

b. What to Prepare:

Complaint Letter or Affidavit: Detailing the nature of the complaint, the lending app’s name, contact details, dates of incidents, and relevant supporting evidence.
Supporting Documents:
- Screenshots of the app’s terms and messages (including harassing messages, if any).
- Loan agreements or promissory notes.
- Proof of payments made, if applicable.
- Personal identification documents.

c. Where to File:

Enforcement and Investor Protection Department (EIPD) of the SEC.
SEC has multiple offices; you may submit complaints at the SEC head office or regional offices.
You can also inquire via the SEC’s official hotline or email (check the SEC website for the latest details).

3.2. Filing a Complaint with the Bangko Sentral ng Pilipinas (BSP)

a. When to Approach the BSP:

The lending app is affiliated with a bank or if the service is provided by a BSP-supervised financial institution.
Issues related to banking regulations or e-money issuance.

b. What to Prepare:

Similar documentation as with SEC complaints: complaint letter, proof of transactions, relevant screenshots or communications.

c. Where to File:

The BSP’s Financial Consumer Protection Department typically handles consumer complaints against BSP-regulated entities.
Complaints can be made online through BSP’s official channels or by mail/visit to BSP offices.

3.3. Filing a Complaint with the National Privacy Commission (NPC)

a. When to Approach the NPC:

If the lending app violates the Data Privacy Act of 2012 by mishandling your personal data, accessing your phone contacts without authorization, or disclosing sensitive information.

b. What to Prepare:

Detailed narrative of the privacy violation.
Proof of unauthorized data usage or privacy breach (e.g., screenshots showing they contacted people in your phonebook, evidence of data leaks).

c. How to File:

NPC Online Complaints Portal: You may submit your complaint and supporting documents online through the NPC’s official website.
Physical Submission: You can also file your complaint in person at the NPC office in Metro Manila if you’re able to do so.

3.4. Filing a Complaint with the Department of Trade and Industry (DTI)

a. When to Approach the DTI:

If the matter involves unfair trade practices, misleading advertisements, or other consumer-related concerns not strictly related to lending regulations.
If the app’s marketing claims are deceptive or do not match actual service delivery.

b. How to File:

Reach out to your local or regional DTI office.
Fill out a consumer complaint form and submit evidence of the alleged violation.

3.5. Filing Criminal Complaints (PNP Anti-Cybercrime Group / NBI Cybercrime Division)

a. When to Approach Law Enforcement:

If you experience harassment, cyber-libel, stalking, or intimidation from representatives of the lending app.
For any activities possibly violating the Cybercrime Prevention Act (R.A. 10175) or penal provisions under other laws.

b. Steps to Take:

Gather Evidence: screenshots of messages, call logs, or audio recordings (if legally obtained).
Sworn Affidavit: stating the facts and nature of the harassment.
File the Report: at the PNP Anti-Cybercrime Group station or the NBI Cybercrime Division.

4. Practical Tips for Lodging a Complaint

Document Everything: Keep copies (digital and printed) of all communications, loan agreements, payment receipts, screenshots of app interfaces, and text messages or call logs. This evidence strengthens your claim.
Identify the Correct Agency: Filing with the right regulator saves time. If it’s strictly a lending issue (e.g., undisclosed fees, harassment, unregistered lending app), begin with the SEC. If it involves privacy concerns, go to the NPC.
File Formal Complaints Promptly: Delays can weaken your case if the lending company closes or changes names.
Be Prepared for Follow-Ups: You may be called to provide further details, attend hearings, or offer sworn statements. Respond promptly to requests from the agency handling your complaint.
Seek Legal Assistance: For more complex or serious disputes (especially those involving large sums or criminal activity), consult with a lawyer who can guide you through procedures or draft legal documents on your behalf.

5. Possible Outcomes and Remedies

Administrative Penalties: If the SEC or BSP finds the lending app in violation of relevant laws, they may impose fines, suspend or revoke licenses, or issue cease-and-desist orders.
Criminal Charges: In cases of severe harassment, threats, or other illegal acts, the responsible individuals may face criminal prosecution.
Civil Remedies: If you suffer damages (financial loss, emotional distress, etc.), you may seek compensation via civil cases in regular courts.
Data Privacy Sanctions: The NPC can order the app to correct practices, delete improperly collected data, or impose fines for data privacy violations.
Consumer Protection Actions: The DTI may mediate settlements, require changes in advertising, or impose penalties for deceptive trade practices.

6. Conclusion

Filing a complaint against a lending app in the Philippines involves understanding which agency has the proper jurisdiction over your specific grievance—whether it is unregistered lending, harassment, privacy violations, or deceptive marketing. The Securities and Exchange Commission is the primary authority for licensing and regulating lending companies, while the National Privacy Commission, Bangko Sentral ng Pilipinas, the Department of Trade and Industry, and law enforcement agencies each address specific legal and regulatory aspects.

To ensure the best chance at a favorable resolution:

Identify the correct agency or entity to approach.
Prepare a comprehensive complaint packet with all evidence.
Respond promptly to official requests and, if possible, seek professional legal advice.

Disclaimer: This article is for general informational purposes and does not constitute legal advice. Laws and regulations may change, and individual circumstances can vary significantly. For tailored guidance, consult a qualified attorney or approach the relevant government agency directly.