Title
Consumer Protection in Ficial Services
Law
Republic Act No. 11765
Decision Date
May 6, 2022
The Financial Products and Services Consumer Protection Act in the Philippines aims to safeguard the rights and interests of consumers by ensuring transparency, fair treatment, and effective handling of disputes in the financial sector, while imposing penalties for prohibited practices and holding financial service providers accountable for the acts of their representatives.
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Declaration of Policy

  • State policy aims to protect consumers of financial products and services.
  • Ensures transparency, fair market conduct, and effective handling of consumer disputes.
  • Protects consumers' rights including:
    • Equitable and fair treatment.
    • Disclosure and transparency.
    • Protection against fraud and misuse of assets.
    • Data privacy and protection.
    • Timely handling and redress of complaints.

Definition of Terms

  • Financial consumer: Person/entity purchasing or transacting in financial products/services.
  • Financial consumer complaint: Dissatisfaction expressed expecting resolution.
  • Financial product/service: Includes savings, credit, insurance, securities, digital financial services, etc.
  • Financial regulators: BSP, SEC, IC, CDA.
  • Financial service provider: Entity offering financial products/services under regulators' jurisdiction.
  • Investment fraud: Deceptive solicitations like Ponzi schemes, unauthorized offerings.
  • Market conduct: How providers design, deliver and manage financial products/services.
  • Marketing: Communication and promotion of financial products/services.
  • Responsible pricing: Pricing that is affordable for clients and sustainable for providers.

Scope and Coverage

  • Applies to all financial products or services offered by any financial service provider.

Financial Regulators

  • BSP, SEC, and IC enforce this Act per their charters.
  • CDA implements with respect to cooperatives (excluding insurance cooperatives under IC and cooperative banks under BSP).

Powers of Financial Regulators

  • Rulemaking: Formulate standards and rules guided by international standards.
  • Market Conduct Surveillance and Examination: On-site/off-site examinations for compliance.
  • Market Monitoring: Require reports from financial service providers and obtain data from government agencies.
  • Enforcement: Actions include fines, suspensions, cease and desist orders, and suspension of operations.
  • Consumer Redress: Provide alternative dispute resolution like mediation.
  • Adjudication: Authority to adjudicate civil claims up to PHP 10 million; decisions are final and executory.
  • Other Powers: As provided by enabling laws or necessary to enforce the Act.

Investment Adviser

  • Defined as persons who advise on investments for compensation.
  • Subject to SEC rules and regulations.
  • Exclusions include lawyers, accountants, insurance agents in incidental roles, bona fide publishers.

Duties and Responsibilities of Financial Service Providers

  • Board and Management must ensure compliance and manage consumer protection risks.
  • Product Design and Delivery:
    • Assess affordability and suitability.
    • Implement cooling-off periods allowing contract cancellation without penalty, except in certain cases.
    • Allow loan prepayment with disclosure of any fees.
  • Transparency and Disclosure:
    • Clear language and disclosure of pricing and changes.
    • Marketing materials must disclose regulator and consumer assistance contacts.
  • Fair Treatment:
    • No discrimination on various protected bases.
    • Prohibit abusive debt collection.
  • Privacy:
    • Comply with Data Privacy Act; protect client data and allow clients to correct or remove data.
  • Consumer Assistance:
    • Establish mechanisms for complaints and dispute handling.
    • Provide reasonable accommodations during investigations.
  • Information Security:
    • Implement security standards protecting client information and transactions.

Bundling of Products

  • Consumers may choose providers for bundled products when required as condition for financial services.

Training

  • Staff must be adequately trained according to product/service complexity.
  • Staff qualifications must match complexity.

Investment Fraud

  • Prohibited by law.
  • Penalties include criminal and administrative sanctions.

No Waiver of Rights

  • Contract provisions waiving legal rights to sue, to information, or to complaint handling are unenforceable.

Liability of Financial Service Providers

  • Providers liable for acts/omissions of their representatives.
  • Solidary liability with accredited third-party service providers.

Prescription

  • Legal actions under this Act prescribe in 5 years from transaction or discovery of violation.
  • Maximum 10 years from commission of violation.
  • Insurance contracts subject to Insurance Code prescriptive periods.

Penalties

  • Violators face imprisonment (1-5 years), fines (PHP 50,000 to PHP 2,000,000), or both.
  • Corporate officers responsible are also liable.

Administrative Sanctions

  • Financial regulators may impose fines, suspend or cancel licenses, and impose other penalties.
  • Investment fraud penalties can reach PHP 10 million plus daily fines.
  • Disgorgement of profits may be ordered.

Independent Civil Action

  • Financial regulators may sue on behalf of consumers.
  • Civil penalties may be added to disgorgement or consumer benefit funds.

Implementing Rules and Regulations

  • Financial regulators to issue IRR within one year from effectivity.

Separability Clause

  • Unconstitutional provisions do not affect remaining provisions.

Repealing Clause

  • Repeals Articles 131 to 147 of RA 7394 and other inconsistent laws or rules.

Effectivity

  • The Act takes effect 15 days after publication in Official Gazette or two newspapers of general circulation.

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