November 28, 2018
SEC-OGC OPINION NO. 21-18
RE: MASS MEDIA, DIGITAL PLATFORM
Angelito M. Villanueva
Managing Director
FINTQnologies Corp.
6/F Launchpad
Reliance cor. Sheridan Street
Mandaluyong City, 1550PH
Dear Mr. Villanueva,
This refers to your request for opinion on whether the Lendr online platform with a "marketplace" feature, which is operated by FINTQnologies Corp. (FINTQ), a registered software development company, is engaged in advertising and/or mass media, which are considered as nationalized activities and therefore subject to nationality restrictions provided under the Philippine Law.
In your letter dated 10 September 2018, you disclosed that FINTQ developed Lendr, a digital Platform-as-a-Service (PaaS) solution to provide an option for Bangko Sentral ng Pilipinas ("BSP")-supervised financial institutions and non-bank financial institutions ("BSFI") to outsource the performance of loan-related services electronically and interactively. Specifically, Lendr is FINTQ's loans origination and management platform which provides the following services: (a) providing information about its loan products in the Lendr marketplace; (b) accepting, processing, and approving applications for such loan products; and (c) monitoring the status of loan products availed of.
The Lendr platform is accessible via the website (www.lendr.com.ph) and through a...
