FA-PCC-CIA
Project site for the response to the Philippine Competition Commission (PCC) on interest rate ceilings.
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The Philippine Competition Commission (PCC) runs a Competition Impact Assessment (CIA) of three interest rate ceiling issuances. The association must answer the PCC data request by 13-Nov-2026.
Objective
Show whether the caps protect borrowers without cutting their access to credit. Use covered-loan, product and BNPL data from member firms, once it arrives and is checked.
Monitoring
Days to response
16 days
From 28-Oct-2026 to 13-Nov-2026.
Data sets requested
3
Covered-loan, product and BNPL data.
Target rates
NIR: 6% per month.
EIR: Conflict
- BSP Circular No. 1133: 15% per month.
- SEC MC No. 14: 12% per month.
Decision owner: Project Team. Legal counsel must confirm before the response uses either figure.
Scope of work
In scope
Out of scope
Deliverables
Dates marked proposed are set by the charter. The board confirms them.
Misalignments
Nine items to raise with the PCC or fix in the project files.
In the PCC letter (6)
In the strategic brief (3)
Open items
Risks and timeline
Risk register
Likelihood values are estimates by NZB Consulting. They are not measured. IDs follow the consolidated register, 20261027_CIA_Risks_Consolidated.md.
| ID | Risk | Rating | Likelihood | Response | Owner |
|---|
Timeline: 26-Oct-2026 to 13-Nov-2026
Dark markers show milestones. Bars show deliverables from 28-Oct-2026 to the due date. Start dates are proposed. Confirm them with each owner. Hover a bar to see its dates.
PCC clarifying questions
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Documents
Upload and download happen in the project Google Drive folder. This page does not upload files. Sign in to Google Drive to add or change files.
Open the project folder in Google Drive
Do not upload member-level data yet. Confirm the member data terms first.
Files
Last check on 28-Oct-2026 found no files in the three folders. To list a file here, add a row to the DOCS list in this page.
| File | Folder | Date added | Download |
|---|
Glossary of FA-CIA regulatory terms
Regulatory reference
Terms from BSP Circular No. 1133, SEC MC No. 3, SEC MC No. 14 and SEC MC No. 20
Notes
- Definitions use plain words. Section numbers point to the source text.
- Where two documents define a term differently, both versions are listed.
- Terms from BSP Circular No. 1133, SEC MC No. 3 and SEC MC No. 14 were checked against their PDFs.
- SEC MC No. 20 terms come from its converted Markdown file. No PDF of it is in the FA-CIA folder.
- Use the search box, the document filter or a letter to find a term.
Glossary
| Term | Definition | Source |
|---|
No terms match your search.
Comparison of SEC & BSP regulations
BSP Circular No. 1133, SEC MC No. 3, SEC MC No. 14 and SEC MC No. 20
Comparison table
No rows match your search.
Discussion: SEC MC No. 14 and the EIR ceiling
This section explains how SEC MC No. 14 affects SEC MC No. 3 and the EIR ceiling. It supports criteria 4 and 5 of the table above.
What changes
- MC 14 sets the EIR ceiling at 12% per month. BSP Circular No. 1133 and MC 3 set it at 15% per month.
- MC 14 keeps the NIR ceiling (6% per month), the late penalty (5% per month) and the total cost cap (100%).
- MC 14 applies to covered loans entered into, restructured or renewed from 01-Apr-2026.
How MC 14 affects SEC MC No. 3
- MC 14 Section 8 repeals or amends SEC issuances that conflict with it. It names no issuance.
- MC 14 likely overwrites MC 3 Section 3, which sets the 15% EIR. For loans from 01-Apr-2026, MC 14 Section 3 governs.
- MC 14 likely overwrites the ceiling penalty amounts in MC 3 Section 6, Part A. For example, the first-offence penalty for an LC rises from PHP 25,000 to PHP 50,000.
- MC 3 keeps the Impact Evaluation Report (Section 4) and the reporting penalties (Section 6, Parts B and C). MC 14 does not conflict with these.
- MC 3 Section 5 requires business plan pricing that complies with MC 3 Section 3. That reference now points to a section that MC 14 likely overwrites. Counsel must confirm which EIR a business plan must follow.
- MC 3 covers loans from 03-Mar-2022. MC 14 covers loans from 01-Apr-2026. The MC 14 text does not state which EIR applies to loans from 03-Mar-2022 to 31-Mar-2026. MC 3 appears to apply to them, but counsel must confirm this.
How MC 14 affects the BSP ceiling
Open legal question. BSP Circular No. 1133 sets the EIR at 15% per month. MC 14 does not name this circular or amend it.
- MC 14 Section 8 reaches only SEC issuances. It does not reach a BSP circular.
- The BSP circular has no repeal clause. This review found no BSP amendment in 2026.
- The 15% BSP ceiling therefore appears to remain on the books. MC 14 sets a lower SEC ceiling for SEC-supervised FCs and LCs.
- The legal question remains open. RA 8556 Section 5 and RA 9474 Section 7 give the Monetary Board the power to set the cap. MC 14 cites FCPA Section 6(a). The texts do not link the two powers.
Practical reading
- MC 14 likely governs the EIR for covered loans from 01-Apr-2026 for SEC-supervised FCs and LCs.
- MC 3 and BSP Circular No. 1133 likely govern the EIR for loans entered into from 03-Mar-2022 to 31-Mar-2026.
- Counsel must confirm both points before the association uses either figure in the PCC response.
Other points
- MC 14 does not name OLPs. It applies to loans offered by FCs and LCs. The text does not state whether it reaches OLP loans.
- Press reports describe 12% as a cut from the 15% set by the Monetary Board. None cites a BSP amendment.
- The MC 14 recitals cite SEC MC No. 05 (2023). Footnote 1 cites the SEC FCPA rules of 2022. The text does not reconcile these references.
Correction to the table
MC 3 Section 6, Part A also allows the SEC to suspend or revoke the primary registration. This applies to a third offence. The table above omits this point.
Actions
- Ask legal counsel which EIR governs covered loans by date range.
- Ask legal counsel whether the SEC can set an EIR below the Monetary Board cap.
- Ask legal counsel whether MC 14 covers OLP loans.
- Check the SEC and BSP for any later issuance on the EIR ceiling.
- Do not state a single EIR in the PCC response until counsel confirms it.
Sources
- SEC MC No. 14 (PDF, FA-CIA folder, source of record)
- SEC MC No. 3 (PDF, FA-CIA folder, source of record)
- BSP Circular No. 1133 (PDF, FA-CIA folder, and BSP website)
- Press and law-firm reports listed in the chat summary of 28-Oct-2026. They do not state a supersession rule.
Project team
Names marked "Not named" are pending. The charter asks the board to name the response owner and data owners by 03-Nov-2026.
Association and NZB Consulting
| Name or group | Role in this project | Status | Due |
|---|---|---|---|
| Lito M. Villanueva, Chairman | Executive sponsor. Addressee of the PCC letter. | Named | Not set |
| Board of the association | Names owners. Chooses the rate position. Approves the letter, the response and any extension request. | Board | 03-Nov-2026 |
| Response owner | Runs the response. Reports to the sponsor. | Not named | 03-Nov-2026 |
| Data owners | Own each data set and each survey question. | Not named | 03-Nov-2026 |
| Legal counsel | Gives a view on the EIR ceiling, the repeal clause and the transition rule. | Not named | 10-Nov-2026 (proposed) |
| Data protection lead | Confirms member data terms. | Not named | Before member data is shared |
| Member firms offering covered loans | Provide data and views. | Pending | 10-Nov-2026 (proposed) |
| Ninfa, NZB Consulting lead | Leads the NZB Consulting advisory team. Signs the charter as NZB Consulting lead. | Named | Not set |
| NZB Consulting advisory team | Drafts templates, letters and the response. Checks totals. Does not decide. | Named | Not set |
External contacts and bodies
| Name or body | Role in this project |
|---|---|
| Carlos L. Vega, PhD, Director IV, PCC Economics Office | Author of the PCC request letter. |
| David Paul C. Arzadon, PCC Economics Office | PCC contact for written questions. |
| Securities and Exchange Commission (SEC) | Holds sanction records and member filings. Contact only with board approval. |
| Bangko Sentral ng Pilipinas (BSP) | Receives SEC reports under BSP Circular No. 1133, section 2. Monitor only. |
| BNPL providers | Provide BNPL data, if they are members. Confirm membership first. |