What is a credit registry?

The World Bank Methodology for Doing Business defines a credit registry as “a database managed by the public sector, usually by the central bank or the superintendent of banks, that collects information on the creditworthiness of borrowers (individuals or firms) in the financial system and facilitates the exchange of credit information among banks and other regulated financial institutions (while their primary objec­tive is to assist banking supervision).”

In the Philippines, the Credit Information Corporation (CIC) serves as the public credit registry or central repository of credit information by virtue of R. A. No. 9510.

It is mandated to provide access to reliable, standardized information on credit history and financial condition of borrowers in the form of a credit report.

What is the difference between a credit registry and a credit bureau?

A credit registry is managed by the public sector, while a credit bureau, also known as “Special Accessing Entity” (SAE), is defined by R. A. No. 9510 as “a duly accredited private corporation engaged primarily in the business of providing credit reports, ratings and other similar credit information products and services.”

A credit registry provides a credit report – a detailed summary of a borrower’s repayment activities. It also contains personal and/or business information, as well as pertinent details of your loans, credit cards, mortgage, and other financial institutions you have transactions with.

A credit bureau provides value-added service such as the credit score – a three-digit numerical value (ranging 300 to 850) that indicates a person’s ability to repay his or her debts. The higher the credit score, the more creditworthy a person is perceived to be.

A credit score also tells lenders how likely a borrower may pay back the money borrowed based on past financial transactions and his or her probability to get approved for a loan or credit card application.

What is CIC’s corporate structure?

What is the pricing scheme for credit report inquiries by Accessing Entities?

In the Letter Circular No. 2022-02 issued by the CIC, the Securities and Exchange Commission (SEC) En Banc has approved the Pricing Scheme for the CIC Basic Credit Reports as follows: a Wholesale Price of PHP 20.00, which may be availed of by Special Accessing Entities and/or Accessing Entities with a pre-paid minimum volume of 1 million Reports annually, and a Retail Price of PHP 30.00 for access in other cases.

Credit reports to be purchased under the New Wholesale and Retail prices shall have a twelve (12) month expiration period. This pricing scheme took effect on 1 April 2022.

Are Submitting Entities required to submit all their borrowers’ data?

Yes, they must submit all credit data of their borrowers in their database.

Can a borrower refuse to submit his credit data?

No. A borrower cannot refuse to submit his credit data. All borrowers’ credit data, through their credit facilities under Republic Act No. 9510 or the Credit Information System Act (CISA) are mandated to submit to the Credit Information Corporation all data pertaining to credit. Notification of the existing law to the borrower is enough for the implementation of R.A. No. 9510.

Will the CIC charge Thirty Thousand Pesos per day if the Submitting Entity fails to comply?

Not necessarily, the law provides that the amount will be determined by the CIC taking into consideration the nature and gravity of the violation or irregularity, but in no case to exceed Thirty Thousand pesos (Php 30,000.00).

Is the submission of data to the CIC violative of the Data Privacy Act?

No, the Data Privacy Act excludes the CIC as provided in Section 4:

SEC. 4. Scope. – This Act applies to the processing of all types of personal information and to any natural and juridical person involved in personal information processing including those personal information controllers and processors who, although not found or established in the Philippines, use equipment that are located in the Philippines, or those who maintain an office, branch or agency in the Philippines subject to the immediately succeeding paragraph: Provided, That the requirements of Section 5 are complied with.

This Act does not apply to the following:

xxx    xxx    xxx

(e) Information necessary in order to carry out the functions of public authority which includes the processing of personal data for the performance by the independent, central monetary authority and law enforcement and regulatory agencies of their constitutionally and statutorily mandated functions. Nothing in this Act shall be construed as to have amended or repealed Republic Act No. 1405, otherwise known as the Secrecy of Bank Deposits Act; Republic Act No. 6426, otherwise known as the Foreign Currency Deposit Act; and Republic Act No. 9510, otherwise known as the Credit Information System Act (CISA);

(f) Information necessary for banks and other financial institutions under the jurisdiction of the independent, central monetary authority or Bangko Sentral ng Pilipinas to comply with Republic Act No. 9510, and Republic Act No. 9160, as amended, otherwise known as the Anti-Money Laundering Act and other applicable laws; [emphasis supplied]

Why are cooperatives included as Submitting Entity?

One of the bills proposing for the creation of the CISA was House Bill No. 2443 which was aimed for the benefit and inclusion of cooperatives in the economic scene. Said Bill was introduced by Rep. Guillermo P. Cua of the Coop-NATCCO. In Rep. Cua’s Explanatory Note thereto, it was stated:

Currently, the banking and finance industry in the country rely on the Credit Information Bureau, Inc. (CIBI) to gather credit information on prospective borrowers. The CIBI, while composed of associations of organizations of the banking and finance industry, is not regulated by the Monetary Board. Due to lack of regulation, it is quite possible, that the credit information sourced from the CIBI is not reliable and is limited. The credit information may be limited because (1) other organizations with credit functions are not members and so do not submit data on their borrowers, most savings and credit cooperatives for example, are not members of the CIBI; (2) there is no regulation as to the accuracy of the credit data that is submitted; (3) Most importantly, there are no existing sanctions/ penalties for persons and organizations who provide inaccurate credit information to the detriment of the general public and/ or who publicize credit information acquired through the credit investigation process.

There therefore is a need to establish a credit information system, one that will be regulated by the Monetary Board, and one whose membership will be expanded to almost all if not all of the organizations which provide credit to the general public. Through a stronger credit information system banks and other financial institutions will be more ready and willing to extend financial assistance and services to borrowers, knowing they have exhaustive and reliable credit information on these borrowers. Moreover, with a more efficient credit information system, the processing of loans will be shortened, making financial institutions more efficient and thus more profitable. 

Prescinding from the foregoing, the passage of this bill is earnestly sought. [emphasis supplied]

When CISA’s House Bill was being approved on its 3rd Reading at the House of Representatives, the results showed 198 votes in favor and none against. As a matter of fact, one of the proponents of the Cooperative Code of 2008 former Congressman Pablo “Noy Pabling” Garcia and his son, former Congressman Pablo John F. Garcia approved the said Bill.

Who were the notable proponents of R.A. No. 9510?

R.A. No. 9510 was legislated by brilliant legislators and legal luminaries, including: then-Congressman and now sitting Sen. Juan Edgardo “Sonny” Angara and former Sen. Edgardo Angara. 

Why is the CIC conducting educational campaigns?

The CIC is mandated by R.A. No. 9510 to do educational campaigns. Section 7 further provides the reasons for the educational campaigns:

• To promote the benefits of a credit information system to the economy.
• To create awareness on the rights of consumers/borrowers to access their credit reports collected, stored and disseminated by the CIC.
• To disseminate the rights of borrowers to dispute any incorrect/inaccurate credit information in the database file of the CIC.
• To familiarize consumers of the procedure in collecting, storing and disseminating credit information of borrowers by the CIC.
• To brief consumers of other related information.

Does R.A. No. 10173 known as the Data Privacy Act of 2012 amend/repeal or make inoperative R.A. No. 9510?

No, the Data Privacy Act of 2012 expressly provides in Section 4(e) that it does not amend or repeal Republic Act No. 9510. (Section 4 (e) is cited under A5 above)

Does R.A. No. 9520, better known as the Cooperative Act of 2008 automatically repeal R.A. No. 9510?

No. Even though R.A. No. 9520 was enacted at a later date, said law does not automatically repeal R.A. No. 9510. RA No. 9520 does not even mention any degree of repeal, whether express or implied, of R.A. No. 9510. Section 143 of RA No. 9520, as worded, does not suffer from any ambiguity. Any concept of a repeal of R.A. No. 9510 advanced by section 143 is absent, and any catch-all provision mirroring a repeal will not affect 9510 as it is not expressly repealed by the said section. In the same vein, RA No. 9520’s repealing clause specifically enumerates the various laws it repealed, and RA No. 9510 was not expressly stated. Expresio Unius Est Exclusio Alterius – Express mention is implied exclusion. Both laws were enacted by the 14th Congress, and if the latter intended to have any law repealed, it would have done so expressly for it was in the best position to do so.

What are the required submissions of insurance companies, mutual benefit associations and other similar entities supervised by the Insurance Commission?

Aside from policy loans, insurance companies, mutual benefit associations and other similar entities supervised by the Insurance Commission are required to submit premium payments and insurance contracts. 

Are employee loans required to be submitted to the CIC?

It depends. Generally, all loans or other credit accommodations availed of by employees as part of their compensation package are not required to be submitted. However, if the loans or credit accommodations are subject to the same terms and conditions imposed on commercial transactions of the company, if there are any, should be submitted to the CIC. 

Are agent’s loans required to be submitted to the CIC?

It depends. If the loans are merely incidental to the insurance company’s engagement with its agents and are treated similarly with that afforded to employees, then such are not required to be submitted to the CIC. However, if the loans or other credit accommodations were extended to agents with the same terms and conditions imposed on commercial transactions, such should be submitted to the CIC.

For questions and/or concerns regarding submission of data to the CIC, please send an email to cichelpdesk@creditinfo.gov.ph.