Regulation

The Truth in Lending Act: Disclosure Requirements for Philippine Lenders

By the LendKoPH Team· Apr 20, 2026· 7 min read
The Truth in Lending Act: Disclosure Requirements for Philippine Lenders
In short: The Truth in Lending Act (Republic Act No. 3765) requires lenders to tell borrowers the true cost of credit before they sign — in writing, on a disclosure statement. That means the amount financed, the finance charge, the effective interest rate, and the total amount to be paid. Failing to disclose exposes you to penalties and can make charges uncollectible.

The Truth in Lending Act is short, old, and easy to overlook — and that is exactly why lenders get caught by it. Its premise is simple and fair: a borrower has the right to know what a loan really costs before agreeing to it. For a lending company, compliance is not just avoiding penalties; a clear disclosure statement prevents disputes and builds the trust that brings borrowers back.

What the law is trying to prevent

RA 3765 exists to stop hidden costs. Before it, a lender could advertise a low "rate" while burying fees, add-on interest, and charges that made the real cost far higher. The Act forces those costs into the open by requiring a standardized disclosure statement that lays out, in one place, exactly what the borrower is paying for credit. The borrower can then compare offers honestly and consent with full information.

What you must disclose

The disclosure statement must present the key cost elements clearly and before the loan is consummated. At its core, the borrower needs to see how much they are actually receiving, how much the credit costs, and what the total repayment will be.

Core disclosure elements
The cash price or amount of the loan (the amount financed)
Any down payment or deductions made at release
The finance charge — the total peso cost of the credit
All other charges not part of the finance charge
The effective interest rate on the unpaid balance
The total amount to be paid (principal plus all charges)
The borrower must see all of this in writing, before signing.

The finance charge and the effective rate

Two figures are the heart of the disclosure. The finance charge is the total cost of credit expressed in pesos — interest plus any fees that are part of the cost of borrowing. The effective interest rate expresses that cost as a single annualized percentage on the declining balance, so the borrower can compare it to any other loan. Quoting a low nominal add-on rate without disclosing the higher effective rate is precisely what the Act prohibits.

The two numbers that matter
Finance charge
total cost of credit, in ₱
EIR
the true annualized rate
Before
disclosed prior to signing
Written
on a disclosure statement
Disclose both the peso finance charge and the effective interest rate, in writing, before signing.
A "3% per month add-on" loan may carry an effective rate well above its nominal figure. The Truth in Lending Act says the borrower has the right to see that real number before they agree.

What happens if you don't disclose

Non-compliance has teeth. The Act provides for civil liability to the borrower and penalties, and regulators can act against lenders who conceal the cost of credit. Practically, poor disclosure also weakens your position in any dispute over charges — a borrower who was never properly shown the finance charge has a strong argument against paying it. Good disclosure, by contrast, makes your charges defensible.

Building a compliant disclosure
1
Compute the true cost
Determine the amount financed, the finance charge, and the effective interest rate.
2
Put it on a disclosure statement
Lay out every required element clearly on a standard form.
3
Present it before signing
Give the borrower the disclosure to read and understand before consummating the loan.
4
Keep the signed copy
Retain the acknowledged disclosure as proof of compliance.
Compute, disclose in writing, present before signing, and keep the record.

Disclosure in the age of online lending

The Truth in Lending Act was written for paper contracts, but it applies with full force to digital lending. An app that approves a loan in ninety seconds still owes the borrower a clear, understandable disclosure of the finance charge and effective rate before they tap "accept." Regulators have paid close attention here precisely because the speed and small screens of app-based lending make it easy to bury the true cost behind a single tap. A compliant digital lender surfaces the amount financed, the total charges, and the effective rate on the confirmation screen, in plain language, not in fine print or a linked document nobody opens.

The most common disclosure failures are variations on the same theme: quoting an attractive nominal rate while hiding the effective one, folding fees into the principal so the "loan amount" looks larger than what the borrower receives, and presenting the total cost only after the borrower is already committed. Each of these defeats the purpose of the law. The fix is simple and it is also good business — show the real numbers early, clearly, and in a form the borrower can actually read, whether the contract is signed on paper or on a phone.

Make disclosure automatic

Because the disclosure hinges on figures you already compute — amount financed, finance charge, effective rate — it should flow straight out of your loan system, not be assembled by hand for each borrower. LendKoPH computes the amortization and cost figures behind every loan, giving you the numbers a compliant disclosure statement needs. Transparent by design means Truth-in-Lending compliance becomes part of how you originate loans, not a separate worry.

Frequently asked questions

What is the Truth in Lending Act?

Republic Act No. 3765, which requires lenders to disclose the true cost of credit to borrowers in writing before a loan is signed — including the finance charge and the effective interest rate.

What must a disclosure statement contain?

The amount financed, any down payment or deductions, the finance charge (total peso cost of credit), other charges, the effective interest rate, and the total amount to be paid.

What is the difference between the finance charge and the effective rate?

The finance charge is the total cost of credit in pesos; the effective interest rate expresses that cost as a single annualized percentage on the declining balance so borrowers can compare loans.

What happens if I don’t disclose properly?

You face civil liability to the borrower and possible penalties, and undisclosed charges are harder to enforce — a borrower who was never shown the finance charge has a strong argument against paying it.

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