BSP Circular 1133 and PH collection-conduct rules

BSP Circular 1133, series of 2021, is a price-control issuance from the Bangko Sentral ng Pilipinas. It sets ceilings on the interest rates and fees that lending companies, financing companies, and their online lending platforms can charge on small, unsecured, general-purpose loans, those up to ₱10,000 with a tenor of up to four months. It caps the nominal interest rate, the effective interest rate inclusive of fees, late-payment penalties, and the total cost of the loan. It is implemented for SEC-regulated lenders through SEC Memorandum Circular No. 3 series of 2022.

Note what it is not: BSP Circular 1133 is not a debt-collection conduct rule. The conduct standards, how and when a lender or its agent may contact a borrower about an overdue account, live in a separate set of rules covered below.

Collection conduct in the Philippines is governed primarily by SEC Memorandum Circular No. 18, series of 2019 (the prohibition on unfair debt-collection practices for financing and lending companies), and by Republic Act No. 11765, the Financial Products and Services Consumer Protection Act, with its implementing rules. These are the issuances that actually set the conduct envelope, and they are what the prohibitions and requirements below come from.

• Abusive language: threats, profanity, intimidation, harassment.
• Third-party contact: calling the borrower's employer, family, references, or social network about the debt.
• Unreasonable hours: typically calls before 6am or after 10pm Philippine time.
• Excessive contact: repeated calls in a short window, multiple channels simultaneously, retry loops after no-contact.
• Misrepresentation: false claims of legal consequence, identity of caller, amounts owed, or authority.
• Public shaming: social media posts, public lists, employer notification.

• Clear identification at the start of every interaction: the lender's name, the caller's role, and the reason for the contact.
• Honest disclosure: the actual outstanding balance, applicable charges, and the calculation basis.
• Channel preference: honor the borrower's request to communicate via a specific channel, for example SMS only.
• Contact logs: every attempt (time, channel, content, outcome) documented and retained per the applicable retention rules.
• Accessible complaints: the borrower can file complaints with the SEC and, under RA 11765, the relevant financial regulator.

The conduct rules apply identically to AI voice and SMS agents. The lender is responsible for ensuring its AI agent complies. In practice, this means:

• Time-window enforcement: calls only fire between 6am and 10pm Philippine time, with respect for borrower-specified preferences.
• Identification script at the start: the agent identifies the lender and itself as automated.
• Opt-out detection: if the borrower says "stop calling", "don't contact me", or the equivalent, the agent ends the call and the system marks the account opt-out.
• Channel honoring: if the borrower says "SMS only", the system disables voice contact.
• Transcript and outcome logs: every interaction is recorded with a full transcript, timestamp, and resolution, retained for regulator audit.
• No third-party contact: the agent does not call references, the employer, or anyone not on the borrower's verified contact list.

Nova for Finance is engineered around the SEC MC 18 and RA 11765 conduct rules from the call-flow design level, not patched on top, and it respects the BSP Circular 1133 rate and fee ceilings on covered loans. Time-window enforcement, identification scripts, opt-out detection, channel honoring, and audit logs are not configurable add-ons; they are the baseline. Voice agents identify themselves as automated when asked. All interactions are auditable from the lender’s dashboard.

This is the operational reason Nova for Finance works for Philippine BNPL portfolios where the average ticket is ₱500 and traditional agent collection is net-negative: AI agents handle volume at roughly ₱8 to ₱15 per account contacted while staying inside the conduct envelope set by SEC MC 18 and RA 11765.