Regulatory Compliance

Regulatory Disclaimers &
Compliance Disclosures.

Effective Date: 01 January 2023  ·  Jurisdiction: Republic of the Philippines  ·  Last Reviewed: June 2026

BSP — Bangko Sentral ng Pilipinas
SEC — Securities and Exchange Commission
CCAP — Credit Card Association of the Philippines
RA 10173 — Data Privacy Act of 2012
NPC — National Privacy Commission

Important Notice: International Credit Collection Services (ICCS) is a credit management and NPL resolution agency — not a law firm, legal practitioner, or provider of legal advice. Nothing on this website, in any ICCS communication, or in any ICCS engagement constitutes the practice of law or the provision of legal services. All formal legal proceedings are managed exclusively by affiliated Philippine legal counsel operating under their own professional licensure and independent engagement with your institution.

01
Agency Status Disclaimer
SEC BSP

Nature of Business — Credit Management Agency

International Credit Collection Services (ICCS) is registered and operates as a credit management and accounts receivable services provider in the Republic of the Philippines. ICCS is not a law firm, is not engaged in the practice of law, and does not provide legal representation, legal advice, or corporate legal services of any nature.

ICCS does not:

  • Appear as counsel of record in any Philippine court proceeding
  • File pleadings, motions, or legal documents in any court or quasi-judicial body on its own behalf or as legal representative of any party
  • Issue legal opinions, legal advice, or interpret Philippine law for clients
  • Render judgments, orders, or any instrument of judicial or quasi-judicial authority
  • Hold itself out as a member of the Integrated Bar of the Philippines (IBP) or any bar association

All court-related services referenced on this website — including civil collection filings, provisional remedy applications, and courtroom representation — are performed exclusively by affiliated panel of licensed Philippine legal counsel operating under their own direct engagement frameworks. ICCS facilitates the case preparation preparatory workflow and coordinates the referral to affiliated panel counsel; it does not itself conduct or supervise any legal proceeding.

02
BSP Compliance
BSP Circular No. 454 BSP Circular No. 702 RA 8791

Bangko Sentral ng Pilipinas — Fair Debt Collection Standards

ICCS conducts all collection activities in full compliance with the fair debt collection standards established by the Bangko Sentral ng Pilipinas (BSP), including but not limited to the guidelines set forth under BSP Circular No. 454 (Consumer Protection), BSP Circular No. 702, and applicable provisions of the General Banking Law of 2000 (Republic Act 8791).

In accordance with BSP standards, ICCS does not engage in any of the following prohibited collection practices:

  • Threatening or using violence, harm, or illegal means against any person
  • Using obscene, profane, or abusive language in any communication
  • Publishing or threatening to publish a list of debtors who refuse to pay obligations
  • Misrepresenting the character, amount, or legal status of any debt
  • Falsely representing the identity of ICCS personnel or affiliated parties
  • Communicating with third parties — including the obligor's employer, family members, or neighbors — in a manner that discloses, embarrasses, or harasses the obligor beyond what is permissible under applicable regulation
  • Contacting obligors at unreasonable hours or in a manner designed to harass or oppress

All ICCS field agents, recovery specialists, and paralegal personnel are trained and required to comply with BSP fair collection standards as a condition of engagement. Any conduct inconsistent with these standards is subject to immediate internal disciplinary review.

03
SEC Compliance
SEC Memorandum Circular No. 18 s. 2019 RA 9474 Corporation Code

Securities and Exchange Commission — Regulatory Standing

ICCS is registered with the Securities and Exchange Commission (SEC) of the Republic of the Philippines as a domestic corporation authorized to engage in credit and collection services. ICCS operates strictly within the scope of its SEC-registered business purpose and does not engage in any activity outside the bounds of its authorized corporate mandate.

In compliance with SEC Memorandum Circular No. 18, Series of 2019 (Guidelines on Online Lending Platforms) and applicable circulars governing collection and credit management entities, ICCS:

  • Maintains its SEC registration in good standing and renews all required corporate filings on schedule
  • Does not conduct, broker, or arrange any lending or financing activity for which a separate SEC license would be required
  • Does not collect on behalf of unlicensed or unregistered lending entities
  • Maintains all required corporate books, records, and disclosures in the form prescribed by the SEC
  • Submits to SEC jurisdiction for any matters arising from its corporate operations and client engagements

Institutional clients engaging ICCS are encouraged to independently verify ICCS's SEC registration status through the SEC's official Company Registration and Monitoring Department (CRMD) records.

04
CCAP Compliance
CCAP Code of Conduct BSP Consumer Protection Framework

Credit Card Association of the Philippines — Collection Ethics Standards

Where ICCS engages in the collection of credit card-related receivables or obligations arising from card-linked facilities, all collection activities are conducted in strict observance of the Credit Card Association of the Philippines (CCAP) Code of Conduct for Collection Agencies and the broader BSP Consumer Protection Framework applicable to credit card operations.

Under CCAP standards, ICCS commits to the following principles in all card-related collection engagements:

  • Dignity and Respect: All communications with obligors — whether by telephone, written correspondence, or field visit — are conducted with professional courtesy and do not subject the obligor to harassment, humiliation, or intimidation
  • Accurate Identification: ICCS personnel clearly identify themselves and the purpose of their communication at the outset of any obligor contact
  • Truthful Representation: No false or misleading statements are made regarding the nature of the debt, the identity of the creditor, or the legal consequences of non-payment
  • Privacy Protection: Obligor account information is not disclosed to unauthorized third parties, and all communications respect applicable banking secrecy and data privacy laws
  • Complaint Resolution: ICCS maintains an internal complaint handling mechanism for obligors who wish to raise concerns about the conduct of any collection activity

ICCS does not accept engagements from creditors whose collection mandates require tactics inconsistent with CCAP standards. Engagement proposals that cannot be executed within the bounds of CCAP-compliant collection practice are declined.

05
RA 10173 / NPC
Republic Act 10173 NPC Circular 16-01 NPC Circular 17-01

Philippine Data Privacy Act of 2012 — Data Processing Compliance

ICCS processes personal data in full compliance with Republic Act No. 10173 (Data Privacy Act of 2012) and the implementing rules and regulations promulgated by the National Privacy Commission (NPC). ICCS is registered with the NPC as a personal information controller and processor, as applicable to its engagement activities.

Key data processing commitments under RA 10173:

  • Lawful Basis: All personal data processing by ICCS is conducted on a lawful basis — either legitimate interest in the performance of a collection engagement, contractual necessity, or express consent where required
  • Data Minimization: ICCS requests and retains only the personal data strictly necessary for the specific engagement purpose. No excess data is collected or retained beyond what is operationally required
  • Purpose Limitation: Personal data collected for one engagement is not repurposed, shared, or used for any other commercial or marketing activity without explicit authorization
  • Data Subject Rights: Obligors retain the right to access, correct, and object to the processing of their personal data, subject to applicable legal limitations on disclosure during active collection proceedings
  • Security Measures: ICCS implements organizational and technical security measures proportionate to the sensitivity of the data processed, including access controls, encryption protocols, and staff confidentiality obligations
  • Breach Notification: In the event of a personal data breach, ICCS will notify affected parties and the NPC within the timeframes prescribed by NPC Circular 16-01
  • Cross-Border Transfers: Where personal data is transferred to institutional clients in the GCC or other jurisdictions, such transfers are governed by Data Sharing Agreements that include standard contractual safeguards consistent with NPC cross-border transfer requirements
06
Legal Counsel Disclaimer
CPRA RA 9261 IBP Rules

Affiliated Legal Counsel — Scope & Panel Governance

ICCS maintains exclusive strategic alliances with affiliated Philippine legal counsel for the purpose of facilitating the referral of case preparation dossiers when formal judicial proceedings are warranted. The following disclosures govern the nature of this arrangement:

  • Independence: Each retained law firm is an independent entity operating under its own Philippine Bar licensure, professional ethics obligations under the Code of Professional Responsibility and Accountability (CPRA), and direct engagement arrangement with the creditor client. Retained counsel does not operate as an agent, employee, or subsidiary of ICCS
  • No Control: ICCS does not direct, supervise, or control the legal strategy, court filings, or professional judgments of affiliated panel counsel. Legal decisions within formal proceedings remain exclusively within the authority of licensed attorneys and their clients
  • Separate Engagement: The retention of independent legal counsel for formal proceedings constitutes a separate engagement from the ICCS credit management engagement. Fees charged by affiliated counsel are governed by their own, separately disclosed fee arrangements
  • No Fee Sharing: ICCS does not receive referral fees, commissions, or any financial benefit from affiliated law firms arising from the referral of client matters, in compliance with the CPRA prohibition on improper fee sharing with non-lawyers
  • Client Notification: Institutional clients are notified in writing prior to any referral to affiliated panel counsel and retain approval authority over the decision to escalate to formal proceedings
07
GCC Cross-Border Disclaimer
UAE PDPL KSA PDPL Qatar Law No. 13 of 2016

Cross-Border Operations — GCC Regulatory Considerations

ICCS serves institutional clients domiciled in GCC jurisdictions including the United Arab Emirates, the Kingdom of Saudi Arabia, the State of Qatar, the State of Kuwait, the Kingdom of Bahrain, and the Sultanate of Oman. The following cross-border regulatory considerations apply to all GCC-originated engagements:

  • Philippine Law Governs Operations: All ICCS operational activities — skip tracing, asset verification, demand coordination, and case preparation dossier preparation — are conducted exclusively within the Republic of the Philippines and are governed solely by Philippine law. ICCS does not conduct any activities within GCC jurisdictions and makes no representations as to the legal requirements of GCC legal systems
  • GCC Data Protection Laws: ICCS acknowledges the applicability of GCC data protection frameworks to its institutional clients, including the UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection, the KSA Personal Data Protection Law (PDPL), and Qatar Law No. 13 of 2016 on Personal Data Privacy Protection. Data Sharing Agreements executed with GCC clients include provisions designed to accommodate the cross-border transfer requirements of these frameworks
  • No Legal Practice in GCC Jurisdictions: ICCS does not provide legal services, legal advice, or legal representation in any GCC jurisdiction. Institutional clients requiring legal counsel in their home jurisdiction are advised to engage locally licensed legal practitioners
  • Debt Enforceability: ICCS makes no warranty or representation as to the enforceability of any debt under GCC law. The recoverability of any obligation under Philippine law is subject to the specific facts of each account, applicable prescriptive periods, and the independent assessment of affiliated Philippine legal counsel
08
General Disclaimer
Website Terms General Law

Website Content & No Legal Advice Disclaimer

All content published on the ICCS website at intcreditcollections.com — including all text, case descriptions, process descriptions, FAQ responses, and service descriptions — is provided for general informational and institutional marketing purposes only. No content on this website constitutes or should be construed as:

  • Legal advice, legal opinion, or a legal assessment of any specific situation
  • A guarantee, warranty, or representation as to the outcome of any collection engagement or formal legal proceeding
  • A solicitation to engage in any activity that may be regulated or prohibited under the laws of any jurisdiction
  • An offer to enter into any specific engagement on the terms described, which remain subject to individual assessment, formal engagement letters, and applicable regulatory requirements

ICCS reserves the right to update, amend, or remove any content on this website at any time without notice. The regulatory disclaimers on this page are reviewed periodically and updated to reflect current Philippine regulatory requirements. The date of last review is indicated at the top of this page.

For institution-specific guidance, regulatory questions, or to discuss the specific parameters of a proposed engagement, institutional representatives are invited to contact ICCS through the encrypted Client Access portal.

Governing Regulatory Bodies

ICCS operations are governed by and subject to the jurisdiction of the following Philippine regulatory bodies. Institutional clients with regulatory concerns may contact these authorities directly.

Bangko Sentral ng Pilipinas (BSP)
www.bsp.gov.ph
Central bank and prudential regulator for financial institutions
Securities and Exchange Commission (SEC)
www.sec.gov.ph
Corporate and capital markets regulator
National Privacy Commission (NPC)
www.privacy.gov.ph
Data privacy and RA 10173 enforcement authority
Credit Card Assoc. of the Philippines (CCAP)
www.ccap.ph
Industry self-regulatory body for credit card operations
Questions & Concerns

For compliance inquiries, regulatory questions, or concerns regarding ICCS collection practices, contact our Compliance Officer.

Compliance Enquiries
legal@intcreditcollections.com
Institutional Inquiries
Client Access Portal →
These disclaimers are subject to periodic review and amendment. The version published on this page supersedes all prior versions. © 2023 ICCS International Credit Collection Services.