CREDLADDER

ENFORCEMENT AND INVESTOR PROTECTION DEPARTMENT In the matter of: SEC EIPD CDO Case No. 2026-0021 CREDLADDER FOR: REPUBLIC ACT NO. 11765 OTHERWISE KNOWN AS “THE FINANCIAL PRODUCTS AND SERVICES CONSUMER PROTECTION ACT (FCPA); SECTION 4.4 OF THE SEC RULES AND REGULATION OF THE FINANCIAL PRODUCTS AND SERVICES CONSUMER PROTECTION ACT OF 2022 (SEC FCPA IRR); SECTION 12 OF THE REPUBLIC ACT NO. 9474 OTHERWISE KNOWN AS THE LENDING COMPANY REGULATION ACT OF 2007 (LCRA); MEMORANDUM CIRCULAR NO. 19, SERIES OF 2019 (MC 19); AND MEMORANDUM CIRCULAR NO. 10 SERIES OF 2021 (MC 10). Respondent x-------------------------------------------------x CEASE AND DESIST ORDER This Cease and Desist Order (CDO) is prompted by inquiries, reports and information received by the Commission concerning the operation of an unrecorded Online Lending Platform (OLP) named CREDLADDER and its engagement in unfair collection practices. ANTECEDENTS The Commission has received information that an online lending application called CREDLADDER is actively engaged in unauthorized lending and financing activities. Based on the reports, CREDLADDER is imposing excessive interest charges and engages in abusive collection practices by sending humiliating and/or threatening messages to its debtors. Below are some of the screenshot copies of the said electronic communications which were sent to the Commission:  The SEC Headquarters, 7907 Makati Avenue Salcedo Village, Bel-air, Makati City 🕾 1-4732 (1-4SEC) www.sec.gov.ph | imessage.sec.gov.ph https://linktr.ee/secphilippines

Likewise, it was reported that CREDLADDER is utilizing FlexiFund, FundXpress, QuickPesa and Paymatic as its remittance agents in its lending activities, as shown below:  The SEC Headquarters, 7907 Makati Avenue Salcedo Village, Bel-air, Makati City 🕾 1-4732 (1-4SEC) www.sec.gov.ph | imessage.sec.gov.ph https://linktr.ee/secphilippines

In its facebook page which can be found at https://web.facebook.com/profile.php?id=61589091975941, CREDLADDER is actively advertising its lending activities, as shown below:  The SEC Headquarters, 7907 Makati Avenue Salcedo Village, Bel-air, Makati City 🕾 1-4732 (1-4SEC) www.sec.gov.ph | imessage.sec.gov.ph https://linktr.ee/secphilippines

Further, investigation reveals that the Online Lending Platform (OLP) of CREDLADDER can be downloaded on Google Play using this link https://play.google.com/store/apps/details?id=com.credit.ladder.online&pcampaignid=web_sh are. Below is a screenshot copy of the web interface of CREDLADDER: CREDIT INSIGHTS Moreover, upon online verification with the DTI’s Business Name Registration System (BNRS), it was discovered that the name CREDLADDER does not appear in their system. Below is a screenshot copy of the said BNRS result:  The SEC Headquarters, 7907 Makati Avenue Salcedo Village, Bel-air, Makati City 🕾 1-4732 (1-4SEC) www.sec.gov.ph | imessage.sec.gov.ph https://linktr.ee/secphilippines

In view thereof, on 10 June 2026, the Commission issued an Advisory against CREDLADDER, which was posted on the Commission’s website on 19 June 2026, informing the public that the name CREDLADDER / CREDLADDER: CREDIT INSIGHTS does not appear in the Commission’s database and that CREDLADDER / CREDLADDER: CREDIT INSIGHTS is not in the Commission’s list of recorded Online Lending Platforms. Notwithstanding the prevailing Advisory, CREDLADDER continues to engage in unauthorized lending and financing activities. ISSUE Whether a Cease and Desis Order (CDO) should be issued against CREDLADDER for its continued operation of unrecorded OLP and its alleged violation of Memorandum Circular No. 19, Series of 2019 and Memorandum Circular No. 10, Series of 2021 (“MC 10”), RULING The Commission finds the issuance of a Cease and Desist Order (CDO) against CREDLADDER warranted. Clearly in this case, CREDLADDER’s act of sending humiliating and/or threatening messages to its debtors constitutes abusive collection or debt recovery practices, which are considered prohibited acts under Republic Act No. 11765 otherwise known as “The Financial Products and Services Consumer Protection Act (FCPA)". Section 4.4. of the SEC Rules and Regulations of The Financial Products and Services Consumer Protection Act of 2022 (SEC FCPA IRR) provides that financial service providers and their collection agencies, counsels and other authorized third-party representatives are prohibited from employing abusive collection or debt recovery practices against their financial consumers. Without limiting the general application of the foregoing, the following shall constitute abusive collection or debt recovery practices: • Use or threat of use of violence or other criminal means to harm the physical person, reputation, or property of any person; • Use of threats to take any action that cannot legally taken; • Use of obscenities, insults or profane language the natural consequence of which is to abuse the financial consumer and/or which amount to a criminal act or offense under applicable laws; • Disclosure or publication of the names and other personal information of borrowers or financial consumers who allegedly refuse to pay debts or obligations arising from transactions involving financial products and services; • Communication or threat of communication to any person of loan information, which is known, or which should be known, to be false, including  The SEC Headquarters, 7907 Makati Avenue Salcedo Village, Bel-air, Makati City 🕾 1-4732 (1-4SEC) www.sec.gov.ph | imessage.sec.gov.ph https://linktr.ee/secphilippines

the failure to communicate that the debt is disputed, except as any be allowed under Section 2 of SEC Memorandum Circular No. 18, Series of 2019; • Use of any false representation or deceptive means to collect or attempt to collect any debt or to obtain information concerning a borrower; • Making contact at unreasonable / inconvenient times or hours, which shall be defined as contact before 6:00 a.m. and after 10:00 p.pm, unless the account is past due for more than fifteen (15) days, or the financial consumer has given express consent that the said times are the only reasonable opportunities for contact; • Notwithstanding the financial consumer’s consent, contacting the persons in the financial consumer’s contact list other than those who were named as guarantors or co-makers shall also constitute unfair debt collection practice; and • Other acts that may be determined by the Commission to constitute abusive collection or debt recovery practices. Further, an entity engaging in the lending business without the required authority from the Commission commits an illegal activity under Section 12 of Republic Act No. 9474 otherwise known as the lending Company Regulation Act (LCRA) of 2007. It is important to emphasize that CREDLADDER is not among the recorded Online Lending Platforms (OLPs) in the Commission’s records. Hence, the continued operation of CREDLADDER violates Memorandum Circular No. 19, Series of 2019 (“MC 19”), which requires the Disclosure of Online Lending Platforms, and Memorandum Circular No. 10, Series of 2021 (“MC 10”), which imposes a Moratorium on New OLP’s. Furthermore, the continued operation of CREDLADDER poses undue risk to the general public and places each of its customers outside the protection afforded by the Financial Products and Services Consumer protection Act and its Implementing Rules and Regulations (“FCPA-IRR”), considering that it is not regulated and not supervised by the Commission. Pursuant to Section6 (d) (4) of the FCPA, as implemented by SEC Memorandum Circular No. 5, Series of 2023, the Commission is empowered to issue a CDO without the necessity of a prior hearing if, in its judgment, the act or practice, unless restrained, constitutes fraud, violates the FCPA, or its Implementing Rules and Regulations (IRR), or may unjustly cause grave or irreparable injury to financial consumers. “RULE 6 Powers of the SEC Section 1. Power of the Commission – The Commission shall, in the implementation of these Rules and the Provisions of the FCPA, have the authority to impose enforcement actions against financial service providers for noncompliance with the FCPA, its IRR, and other applicable laws.  The SEC Headquarters, 7907 Makati Avenue Salcedo Village, Bel-air, Makati City 🕾 1-4732 (1-4SEC) www.sec.gov.ph | imessage.sec.gov.ph https://linktr.ee/secphilippines

Such enforcement action may include: Issuance of a Cease and Desist Order (CDO) to a financial service provider without the necessity of a prior hearing if, in the Commission’s judgment, the act or practice, unless restrained, amounts to fraud or a violation of the FCPA and/or the SEC FCPA IRR, or may unjustly cause grave or irreparable injury or prejudice to financial consumers. A CDO is immediately executory upon service or publication on the Commission’s website.” (Emphasis supplied) In light of the CREDLADDER’s continued unauthorized operation of its OLP, the EIPD finds it imperative to issue a Cease and Desis Order (CDO) in order to prevent further harm or prejudice to the public, and to safeguard the integrity of the regulatory framework governing lending companies. WHEREFORE, premises considered, CREDLADDER, its agents, representatives, salesmen, conduit entities, subsidiaries, and any and all persons claiming and acting for and on their behalf, are hereby ordered to immediately Cease and Desist from engaging in, conducting, carrying out, promoting, facilitating, advertising, or otherwise participating, whether directly or indirectly, in any lending activities or transactions. This prohibition expressly includes, but is not limited to, the operation, maintenance, promotion, or continued availability of the OLP known as CREDLADDER and any other platform, application, website, or digital interface operated under whatever name, alias, or guise. This Cease and Desist Order shall be immediately executory upon service or publication on the Commission’s official channels and shall remain in full force and effect unless sooner lifted by the Commission. Let copies of this Cease and Desist Order be furnished to the Philippine National Police- Anti-Cybercrime Group (PNP-ACG), the Cybercrime Investigation and Coordinating Center (CICC) and the Presidential Anti-Organized Crime Commission (PAOCC), for their appropriate action, coordination, investigation, and enforcement assistance, including such measures as may be necessary to prevent the continued operation, digital accessibility, promotion, and facilitation of CREDLADDER’s unauthorized online lending operation. Further, let a copy of this Order be published on the official website of the Commission for general circulation. In accordance with Section 64.3 of the SRC and Rule XI of the 2026 Rules of Procedure of the SEC, Respondents may file a verified Motion to Lift the CDO with the EIPD within five (5) days from receipt of this Order, or the posting of the CDO on the Commission’s website, whichever is earlier.  The SEC Headquarters, 7907 Makati Avenue Salcedo Village, Bel-air, Makati City 🕾 1-4732 (1-4SEC) www.sec.gov.ph | imessage.sec.gov.ph https://linktr.ee/secphilippines

The public is hereby warned to refrain from transacting with CREDLADDER. SO ORDERED. 15 September 2026, Makati City. Digitally signed by Lupango- Tamayo Sheara Laurio Date: 2026.09.18 13:46:07 +0 8'0 0' SHEARA L. LUPAN G O -TAMAYO Officer-in-Charge  The SEC Headquarters, 7907 Makati Avenue Salcedo Village, Bel-air, Makati City 🕾 1-4732 (1-4SEC) www.sec.gov.ph | imessage.sec.gov.ph https://linktr.ee/secphilippines