PERSONS OR ENTITIES OPERATING, MAINTAINING, ADMINISTERING, AND/OR ACTING THROUGH THE FACEBOOK PAGE “CASH-EXPRESS PAYDAY LOAN"

FINANCING AND LENDING COMPANIES DEPARTMENT IN THE MATTER OF: FinLenD Case No. 10-26-01 PERSONS OR ENTITIES OPERATING, FOR: APPARENT VIOLATION OF MAINTAINING, ADMINISTERING, REPUBLIC ACT NO. 8556, OTHERWISE AND/OR ACTING THROUGH THE KNOWN AS THE FINANCING COMPANY FACEBOOK PAGE ACT OF 1998; REPUBLIC ACT NO. 9474, “CASH-EXPRESS PAYDAY LOAN” OTHERWISE KNOWN AS THE LENDING (Facebook link: COMPANY REGULATION ACT OF 2007; https://www.facebook.com/profile.php?id=61 SEC MEMORANDUM CIRCULAR NO. 05, 591789874838&_rdc=1&_rdr#) SERIES OF 2023; AND SEC MEMORANDUM CIRCULAR NO. 20, SERIES OF 2026, FOR ENGAGING IN AND/OR HOLDING OUT AS ENGAGED IN FINANCING OR LENDING ACTIVITIES WITHOUT THE REQUISITE AUTHORITY FROM THE COMMISSION, AND FOR FALSE OR MISLEADING REPRESENTATIONS TO FINANCIAL Respondent. CONSUMERS x----------------------------------------------------x CEASE AND DESIST ORDER Before the Commission is information concerning the operation of a Facebook page denominated “Cash-Express Payday Loan”, which uses the name, branding, corporate particulars, and other representations associated with Cash-Express Philippines Financing Inc., a financing company registered with the Securities and Exchange Commission (“Commission” or “SEC”). The matter calls for the Commission's exercise of its preventive and protective jurisdiction over financial products and services within its regulatory authority. Antecedents On 02 September 2026, the Financing and Lending Companies Department (“FinLenD” or “Department”) received a report from Cash-Express Philippines Financing Inc. (“Cash-Express”) concerning a Facebook page denominated “Cash-Express Payday Loan.” Cash-Express categorically disclaimed any ownership, operation, authorization, association, or affiliation with the subject Facebook page. It further stated that the people operating the page used its company name and branding without authorization, creating confusion among the e public and exposing financial consumers to potential harm.

In the Matter of: CASH-EXPRESS PAYDAY LOAN FINLEND CASE NO. 10-26-01 Cease and Desist Order x----------------------------------------x Cash-Express identified two Facebook pages as its official and authorized pages and separately identified the “Cash-Express Payday Loan” page as fraudulent and unauthorized. The supporting evidence submitted with the report shows that the subject page bears representations associated with Cash-Express and contains promotional material relating to the availment of loans. The page thus presents itself to the public in a manner that may convey the impression that it is an authorized lending or financing channel of Cash-Express. Cash-Express likewise informed the concerned government agencies that it had preserved the subject page as potential digital evidence and refrained from immediately reporting it for removal pending appropriate law-enforcement guidance. The foregoing circumstances prompted this Department to determine whether immediate regulatory restraint is warranted. Issue Whether a Cease and Desist Order should be issued against the Respondents for apparent violations of Republic Act No. 8556, Republic Act No. 9474, SEC Memorandum Circular No. 05, Series of 2023, and SEC Memorandum Circular No. 20, Series of 2026. Ruling The Commission resolves the issue in the affirmative. The facts before the Commission are neither obscure nor equivocal. Cash-Express is a financing company duly registered with the Commission. It has categorically denied any ownership of, authority over, affiliation with, or participation in the Facebook page denominated “Cash-Express Payday Loan.” Notwithstanding such categorical disclaimer, the subject page uses the name, branding, corporate identity, and other indicia of legitimacy belonging to Cash-Express while disseminating lending- related representations to the public. The legal consequence of these facts is clear. Respondents have no authority to engage in, or hold themselves out as engaged in, financing or lending activities. The authority to engage in the business of financing or lending is not presumed. It proceeds from law and from the corresponding authority granted by the Commission.

In the Matter of: CASH-EXPRESS PAYDAY LOAN FINLEND CASE NO. 10-26-01 Cease and Desist Order x----------------------------------------x Republic Act No. 8556, otherwise known as the Financing Company Act of 1998, as amended (“FCA”), governs the business of financing and subjects the same to the regulatory and supervisory jurisdiction of the Commission. Republic Act No. 9474, otherwise known as the Lending Company Regulation Act of 2007 (“LCRA”), likewise requires authority from the Commission before a person may lawfully engage in the business of a lending company. The statutory policy is unmistakable. Financing and lending are regulated businesses. The right to conduct either business cannot be assumed, self-conferred, or acquired merely by representing to the public that one is capable of extending credit. The requisite authority must first exist. This principle is expressly reflected in the Implementing Rules and Regulations of the LCRA. Rule 10 penalizes any person who engages in the business of a lending company without a validly subsisting authority from the Commission. It likewise proscribes holding oneself out as a lending company through advertisements or other representations, as well as the use of a trade or firm name or other designation calculated to give the public the impression that the person is engaged in the business of lending without the appropriate SEC authority. The prohibition therefore extends beyond the consummated grant of a loan. It reaches the advertisement, solicitation, promotion, representation, or holding out that one is engaged in the regulated business without lawful authority. The records disclose precisely such conduct. The Facebook page “Cash-Express Payday Loan” publicly displays lending-related promotional materials while using the name, branding, corporate particulars, and apparent regulatory identity of Cash-Express. In so doing, Respondents do not merely appropriate the identity of Cash-Express; they hold themselves out to the public as persons capable of offering, arranging, facilitating, or otherwise undertaking financing or lending transactions. Yet nothing in the records shows that Respondents possess a Certificate of Authority from the Commission to operate either as a financing company or as a lending company. Neither is there any showing that they are authorized representatives, agents, instrumentalities, or service providers of a duly licensed financing or lending company. To the contrary, Cash-Express—the very financing company whose identity Respondents invoke—has categorically disowned the subject page. Respondents therefore stand on neither ground. They possess no demonstrated authority of their own, and they derive none from Cash-Express.

In the Matter of: CASH-EXPRESS PAYDAY LOAN FINLEND CASE NO. 10-26-01 Cease and Desist Order x----------------------------------------x The use of another entity’s corporate identity cannot supply what the law requires the Commission itself to grant. Respondents cannot circumvent the regulatory requirements governing financing and lending by appropriating the name, branding, corporate registration particulars, or Certificate of Authority information of a legitimate financing company. Regulatory authority is personal to the entity upon which it is conferred. It cannot be borrowed, assumed, simulated, or manufactured through misrepresentation. Accordingly, insofar as Respondents offer, advertise, solicit, promote, facilitate, or otherwise hold themselves out as engaged in financing or lending activities without demonstrated authority from the Commission, their conduct is prima facie contrary to the statutory and regulatory requirements governing the conduct of financing and lending businesses under the FCA and LCRA. This regulatory infirmity exists independently of Respondents’ impersonation of Cash-Express. Even absent the unauthorized use of Cash-Express’s identity, Respondents would have no lawful basis to engage in, advertise, promote, or hold themselves out as engaged in financing or lending activities without the requisite authority from the Commission. Their appropriation of Cash-Express’s identity does not cure that absence of authority; it aggravates the violation by clothing an otherwise unauthorized operation with the appearance of regulatory legitimacy. The Commission will not permit persons without demonstrated authority to obtain indirectly, through deception, the regulatory standing which the law requires to be obtained directly from the Commission. Respondents’ conduct warrants immediate preventive intervention under the FCPA and the SEC FCPA IRR. Respondents’ apparent violations of the regulatory requirements governing financing and lending are compounded by the consumer-protection consequences of their misrepresentations. Republic Act No. 11765, otherwise known as the Financial Products and Services Consumer Protection Act of 2022 (“FCPA”), together with its implementing rules, vests the Commission with authority to immediately restrain acts and practices that amount to fraud, violate the FCPA or the SEC FCPA IRR, or may unjustly cause grave or irreparable injury or prejudice to financial consumers. Rule 6, Section 1(D)(iv) of the SEC FCPA IRR authorizes the Commission to issue a Cease and Desist Order without the necessity of a prior hearing where, in its judgment, the act or practice sought to be restrained falls within the circumstances prescribed therein. Such Order is immediately executory upon service or publication on the Commission’s website.

In the Matter of: CASH-EXPRESS PAYDAY LOAN FINLEND CASE NO. 10-26-01 Cease and Desist Order x----------------------------------------x The remedy is preventive by design. The Commission is not required to sit idly by until an unsuspecting borrower has surrendered money, personal information, identification documents, or access credentials to unidentified persons. Neither must it await the completion of a fraudulent or unauthorized transaction before exercising the coercive authority granted to it by law. The present case falls squarely within the purpose of that preventive authority. By using the identity and branding of a legitimate financing company while disseminating lending-related representations, the subject page creates an appearance of authority, legitimacy, and regulatory standing that Respondents have not established. A financial consumer encountering the page may consequently be induced to believe that he or she is dealing with Cash-Express itself or with an authorized representative thereof, and on that premise disclose confidential information, transmit funds, pay purported processing or facilitation fees, submit identification documents, or enter into purported loan transactions with persons whose identities, authority, and regulatory status remain unverified. The danger arises at the point of solicitation and representation. The Commission need not await the consummation of the threatened injury or the actual infliction of financial loss before exercising the preventive authority expressly conferred upon it by law. The use of a digital platform does not remove Respondents’ activities from the Commission’s regulatory jurisdiction. The foregoing statutory requirements are not displaced merely because the questioned activities are undertaken through cyberspace. SEC Memorandum Circular No. 20, Series of 2026 (“MC No. 20”), did not open the digital lending space to indiscriminate participation. The lifting of the moratorium on Online Lending Platforms (“OLPs”) did not authorize unlicensed persons to engage in, advertise, solicit, promote, facilitate, or otherwise hold themselves out as engaged in financing or lending activities through websites, mobile applications, social-media pages, or other electronic channels. Rather, MC No. 20 subjected OLP operations to a regulatory framework anchored on authority, traceability, accountability, disclosure, and continuing Commission supervision. Consistent therewith, the 2026 OLP Disclosure Guide provides that only financing companies and lending companies duly registered with the Commission and possessing a valid Certificate of Authority may disclose and register an OLP. The regulatory framework further requires disclosure of the platform’s identity, brand identifiers, official access points, customer-support channels, and relevant third-party service providers.

In the Matter of: CASH-EXPRESS PAYDAY LOAN FINLEND CASE NO. 10-26-01 Cease and Desist Order x----------------------------------------x An OLP therefore possesses no independent regulatory authority. It is merely a medium through which a duly authorized FC or LC may deliver its financial products or services to the public. Whatever authority attaches to its operations necessarily derives from, and remains anchored upon, the regulatory authority of the FC or LC operating it. Here, no such regulatory nexus has been established. The subject Facebook page has not been shown to be an OLP duly disclosed and recorded under a licensed FC or LC. More decisively, Cash-Express—the registered financing company whose identity Respondents invoke—has expressly denied any connection with the subject page. Respondents cannot transform an unauthorized digital operation into a lawful one merely by assuming the identity of a regulated entity. What the FCA, LCRA, and MC No. 20 require to be established through lawful authority, disclosure, and regulatory accountability cannot be simulated through the unauthorized use of another company’s name, branding, or regulatory credentials. Accordingly, Respondents’ apparent financing or lending activities through the subject Facebook page are prima facie inconsistent with the regulatory requirements governing financing and lending under the FCA and LCRA and with the framework governing OLPs under MC No. 20. The foregoing circumstances, taken together, warrant the issuance of a Cease and Desist Order. The applicable statutory and regulatory frameworks operate in tandem. The FCA and LCRA regulate the authority to enter into and conduct the financing and lending businesses. MC No. 20 regulates the use of OLPs as channels for the delivery of such regulated financial services. The FCPA and SEC FCPA IRR, in turn, supply the Commission with the preventive enforcement mechanism necessary to immediately restrain conduct that threatens prejudice to financial consumers. Respondents cannot evade these requirements merely by operating through cyberspace, much less by appropriating the identity and regulatory credentials of a duly registered financing company. The Commission will not permit regulatory authority lawfully granted to one entity to be simulated, appropriated, or invoked by persons possessing no demonstrated authority of their own. In Primanila Plans, Inc. v. Securities and Exchange Commission,1 the Supreme Court recognized the validity of preventive regulatory intervention where the Commission had undertaken sufficient investigation and verification of the questioned activity. Here, the evidentiary record—particularly Cash-Express’s unequivocal denial of any ownership, 1 740 PHIL. 624.

In the Matter of: CASH-EXPRESS PAYDAY LOAN FINLEND CASE NO. 10-26-01 Cease and Desist Order x----------------------------------------x operation, authorization, or affiliation with the subject page, coupled with Respondents’ continued use of its name and branding in connection with lending representations— provides sufficient factual basis for immediate regulatory restraint. In sum, Respondents are holding themselves out as engaged in financing or lending-related activities without demonstrated authority from the Commission; operating outside the regulatory framework governing OLPs; and appropriating the identity and regulatory standing of a legitimate financing company in a manner capable of misleading and prejudicing financial consumers. These circumstances implicate the regulatory requirements of the FCA and LCRA, the safeguards governing OLPs under MC No. 20, and the consumer-protection regime established under the FCPA and SEC FCPA IRR. The Commission need not await the consummation of the threatened injury. Its preventive enforcement authority exists precisely to arrest unlawful or unauthorized conduct before the resulting prejudice to financial consumers becomes irreversible. The issuance of a Cease and Desist Order is therefore warranted. WHEREFORE, premises considered, the PERSONS OR ENTITIES OPERATING, MAINTAINING, ADMINISTERING, CONTROLLING, AND/OR ACTING THROUGH THE FACEBOOK PAGE “CASH-EXPRESS PAYDAY LOAN,” together with their representatives, agents, nominees, instrumentalities, and all persons acting for, under, or on their behalf, are hereby ORDERED to IMMEDIATELY CEASE AND DESIST from: (1) ENGAGING IN, CONDUCTING, CARRYING ON, OFFERING, ADVERTISING, SOLICITING, PROMOTING, ARRANGING, FACILITATING, PROCESSING, OR OTHERWISE PARTICIPATING, DIRECTLY OR INDIRECTLY, IN ANY FINANCING OR LENDING ACTIVITY OR TRANSACTION WITHOUT THE REQUISITE AUTHORITY FROM THE COMMISSION; (2) holding themselves out, expressly or impliedly, as a financing company, lending company, provider of financing or lending products or services, or as otherwise authorized by the Commission to engage in such regulated activities; (3) representing, expressly or impliedly, that they are Cash-Express Philippines Financing Inc., or that they are owned, operated, authorized, accredited, affiliated, connected with, sponsored by, endorsed by, or acting for or on behalf of said company; (4) using, displaying, reproducing, appropriating, or otherwise employing the corporate name, trade name, business name, logo, branding, SEC registration information, Certificate of Authority details, or any other identifying or regulatory particulars of Cash-Express Philippines Financing Inc. in connection with any financing or lending activity, solicitation, advertisement, promotion, offer, or transaction;

In the Matter of: CASH-EXPRESS PAYDAY LOAN FINLEND CASE NO. 10-26-01 Cease and Desist Order x----------------------------------------x (5) operating, maintaining, promoting, or making available the Facebook page “Cash-Express Payday Loan”, or any other website, mobile application, social-media page, digital interface, or electronic platform under the same or substantially similar name or identity, for purposes of offering, advertising, soliciting, promoting, arranging, facilitating, processing, or purporting to provide financing or lending products or services without lawful authority; (6) soliciting, requesting, obtaining, collecting, receiving, or causing the transmission or disclosure of money, fees, personal data, sensitive personal information, financial information, identification documents, account credentials, or other information from members of the public in connection with any such unauthorized financing or lending activity; and (7) committing any other act or representation calculated to create the false or misleading impression that Respondents, the subject Facebook page, or any related digital account or platform is duly authorized by the Commission or is an official or authorized financing or lending channel of Cash-Express Philippines Financing Inc. This CEASE AND DESIST ORDER shall be immediately executory upon service or publication on the Commission’s website, in accordance with the SEC FCPA IRR, without prejudice to the Commission’s continuing investigation and the institution of such administrative, civil, or criminal proceedings as may be warranted by the evidence. In accordance with Rule XI of the 2026 Rules of Procedure of the SEC, the Respondent may file a verified Motion to Lift the CEASE AND DESIST ORDER with this Department within five (5) days from receipt of this Order or the posting of the same on the Commission’s website, whichever is earlier. SO ORDERED. 05 07 October 2026. Makati City. Digitally signed by Lupango- Tamayo Sheara Laurio Date: 2026.10.07 22:19:40 +08'00' SHEARA L. LUPANGO-TAMAYO Director