SEC En Banc Case No. 07-25-580In the Matter of Cashbee Lending Services Incorporated

Republic of the Philippines Department of Finance Securities and Exchange Commission COMMISSION EN BANC CASHBEE LENDING SERVICES INCORPORATED, Appellant, SEC En Banc Case No. 07-25-580 -versus- RE: Revocation of the Certificate of Registration and Authority to Operate as a Lending Company FINANCING AND LENDING COMPANIES DEPARTMENT, Appellee. Promulgated: 07 November 2025 x- -----X DECISION Before this Commission is the Memorandum on Appeal (the "Appeal") filed by Cashbee Lending Services Incorporated on 11 July 2025,1 praying for the reversal and setting aside of the Order of Revocation dated 19 May 2025 (the "Assailed Order") issued by the Financing and Lending Companies Department (FLCD), the dispositive portion of which, reads: WHEREFORE, pursuant to SEC Office Order No. 545, grantin g the FinLenD the authority to revoke Certificate of Registr ation and Authority of erring financing and lending companies in accordance with existing rules and to act on cognate activities, the Certificate of Registration and authority of CASHBEE LENDING SERVICES INC., including its Online Lending Platforms/Applications is hereby REVOKED for continuous non-compliance with MC 3 series of 2022 for non-submission of its Business Plan. SO ORDERED. The Assailed Order was sustained by the FLCD in its Resolution dated 26 June 2025 (the "Assailed Resolution"). THE PARTIES Appellant Cashbee Lending Services Incorporated ("Cashbee Lending") is a corporation duly organized and existing under Phili ppine laws, having been issued a Certificate of Incorporation bearing Company 1 Docket Fees were paid on the same day.

Cashbee Lending Services Inc. v. FLCD SEC EB Case No. 07-25-580 DECISION Registration No. CS201912321. Cashbee Lending was also issued on 26 July 2019, a Certificate of Authority (CA) to Operate as a Lending Company with CA No. 3041. Its principal place of business is at Unit 10-B SIX/NEO Building, 5th Avenue corner 26th Street, Bonifacio Global City, Taguig. Appellee, the FLCD is a department of this Commission tasked to monitor and enforce compliance by financing companies (FCs) and lending companies (LCs) with the Financing Company Act (FCA), the Lending Company Regulation Act (the "Lending Act"), the Financial Products and Services Consumer Protection Act, and their respective implementing rules and regulations, among others; having the authority to suspend or revoke the Certificates of Regist ration and CA of LCs or FCs. THE RELEVANT FACTS On 19 March 2025, the FLCD conducted a walkthrough audit of Cashbee Lending which resulted in the issuance of a Walkthrough Audit Findings2 (the "Audit Findings") sent via email on 24 March 2025 to Cashbee Lending. Based on the Audit Findings, Cashbee Lendi ng failed to submit its Business Plan, as required under Section 5 of SEC Memorandum Circular No. 3, series of 2022 (MC No. 3-2022 ).3 Thus, Cashbee Lending was directed to either show proof of compli ance with MC No. 3-2022 or show cause why its licenses/registrat ions should not be suspended or revoked.4 On 03 April 2025, Cashbee Lending submitted its Busine ss Plan and other relevant supporting documents by email to one of the FLCD's official accounts (finlend_queries@sec.gov.ph), in compliance with the directive from the FLCD. The FLCD acknowledged receipt of Cashbee Lending's submission in its 04 April 2025 email and stated that it had forwarded the same to the designated processor.5 On 19 May 2025, the FLCD issued the Assailed Order revoking the Certificate of Registration and CA (collectively referred to as the "Certificates") of Cashbee Lending on the basis of its continuous non- compliance with MC No. 3-2022, specifically for its allege d non- submission of its Business Plan. 2 Appeal. Annex "D". See Comment dated 15 August 2025. Par. 1. 3 Ibid. par. 2 * Comment dated 15 August 2025. Par. 1. See Position Paper dated 17 September 2025. Par 5 Ibid. Annex "G". 3.0. 6 Id. par. 4. (see Annex "А").

Cashbee Lending Services Inc. v. FLCD SEC EB Case No. 07-25-580 DECISION On May 2025, Cashbee Lending filed its Motion for 22 Reconsideration (the "Motion")7, which was thereafter denied by the FLCD in the Assailed Resolution, ruling that that the failure of Cashbee Lending to timely submit its Business Plan constitutes a blatant disregard of the regulatory deadlines and raises doubts in its capacity to operate in a lawful, responsible, and compliant manner within the financial services industry. Hence, the instant Appeal. Cashbee Lending prays for the Commission to consider the fact that it actually submitted its Business Plan, including theother requirements enumerated in the Audit Findings, to the FLCD via email on 04 April 2025,º which was acknowledged by the latter.9 Considering that during the conference conducted by the FLCD on 14 May 2025, it was allegedly not informed of any irregularity or infirmity relating to its submission, Cashbee Lending was led to assume that it has complied with the requirement in Section 5 of MC No. 3-2022.10 In its Comment,11 the FLCD moved for the denial of the Appeal for lack of merit. The FLCD maintained that Cashbee Lending's failure to (a) submit its Business Plan within the prescribed period, and (b) comply with the proper mode and manner of submission thereof, in violation of MC No. 3-2022, warranted the revocation of its Certificates which is the penalty prescribed under Section 6 of MC No. 3-2022,12 In compliance with the Order of the Commission, Cashbee Lendi ng and the FLCD filed their Position Papers on 11 September 2025 and 18 September 2025, respectively, essentially reiterating the allegations and arguments in their earlier pleadings. ISSUE Lending's belated filing of its Business Plan Whether Cashbee warrants the imposition of the ultimate penalty of revocation of its Certificates. 7 Id. Annex "E" 8 Supra. Note 5. 9 Id. par. 9. 10 Id. par. 13. 11 dated 15 August 2025 12 Comment.

Cashbee Lending Services Inc.v. FLCD SEC EB Case No. 07-25-580 DECISION х--- RULING The Appeal is impressed with merit. Section 5 of MC No. 3-2022 provides for the requirement to submit a Business Plan by FCs and LCs. The provision, in part, reads: SECTION 5. Other Requirements. The Commission shall require all LCs - and FCs, whether or not offering loans covered by the ceiling, to submit a Business Plan indicating the company's loan products and services as well as the applicable pricing parameters, which must be compliant with Section 3 of this Circular. The Business Plan shall be submitted on or before 5 May 2022 in portable document format (pdf) layer to with text cgfd_md@sec.gov.ph following with the subject line: CGFD_Complete Name of the Company_Type of Document_Date Submitted. The Business Plan submitted under this Section shall supersede the initial Business Plan or Plan of Operation in the Company Information Sheet submitted to the Commission prior to the issuance of the Certificate of Authority of the LC/FC. (Emphasis supplied) The requirement in the afore-quoted provision is intend ed to implement and ensure transparency in the conduct of business of all FCs and LCs, including those operating OLPs. A Business Plan submi tted in compliance with MC No. 3-2022 constitutes a formal statement or declaration by the submitting FC or LC that the interest rates, penalties, loan costs, and other information provided therein are all within the prescribed limits, and/or complies with the requirements prescr ibed under applicable laws, rules and regulations. Such requirement implements the broader mandate of the Commission under the Lending Act to ensure that lending companies operate on a sound, efficient and stable condition, thus allowing the public to derive optimum advantages from them as an additional source of credit; and preventing lending companies from engaging in practices that are prejudicial to public interest.13 MC No. 3-2022 is intended to facilitate the attainment of the objectives of the law that it seeks to implement.14 It has the force and 13 SEC 2. Of R.A. No. 9474 provides: "It is hereby declared the policy of the State to regulate the establishment oflending Companies and to place their operation on a sound, efficient and stable condition to derive the optimum advantages from them as an addition al source ofcredit, to prevent and mitigate, asfar as practicable, practices prejudicial to public interest; and to lay down the minimum requirements and standards under which they may be established and do business." 14 "The authority to make IRRs in order to carry out an express legislative purpose, or to effect the operation and enforcement of a law is not a power exclusively legislative in character, but is rather administrative in nature. The rules and regulations adopted and promulgated must not, however,