Who We AreWho We AreISET, Inc. is a Philippine stock corporation registered with the Securities and Exchange Commission (RA 11232). It operates neutral trust infrastructure for digital business; its first capability is the registry of record for electronic transferable records, under already-enacted electronic-commerce and secured-transactions law — recording, signing, and verifying instruments issued by verified counterparties. It does not extend credit, does not advance funds, and is not regulated as a lending or financing institution.
In any transaction on the registry, the bearer owns the underlying right, a bank may extend credit against it, and ISET records and signs the record — distinct roles, each governed by a different regulatory regime.
Because of the language we use throughout the platform — “ePN”, “collateral”, “facility”, “credit” — it is reasonable to ask whether ISET should be regulated as a lender. The answer is no: every regulatory category for credit extension fails on the facts.
| Category | Statute | Why it does not apply | |
|---|---|---|---|
| ✗ | Lending Company | RA 9474 | ISET does not grant loans from its own or third-party capital. |
| ✗ | Financing Company | RA 8556 | ISET does not purchase receivables, factor instruments, or extend installment credit. |
| ✗ | Bank · Quasi-Bank · NSSLA | RA 8791 | ISET does not accept deposits, does not extend loans, and is not under BSP prudential supervision as a credit institution. |
| ✗ | Credit-Granting Institution | Any FS statute | ISET does not perform credit underwriting, does not bear default risk on credit transactions, and does not collect on debts. |
ISET is an electronic-record-keeping infrastructure and the registry of record for electronic transferable records. The closest regulatory analogues are registries, custodial-control agents, and signing roots — not credit institutions.
| Role | Statutory basis | What ISET actually does | |
|---|---|---|---|
| ✓ | Registry of record | MLETR-aligned §10 · RA 8792 §7 | Records, signs, and verifies electronic transferable records issued by verified counterparties — meeting the substantive control standard and the functional-equivalence treatment of electronic records and signatures. |
| ✓ | Registry for sovereign data intangibles | RA 11057 §3, §11 | Data rights, once registered, are property. ISET records perfection, control, and lifecycle events on the registry. |
| ✓ | Signing root | NIST FIPS 204 | Every lifecycle event is signed with post-quantum cryptography (ML-DSA-65). Public key is published; signatures are independently verifiable. |
| ✓ | Personal information controller | RA 10173 | ISET processes personal data — names, TINs, addresses — of bearers and counterparties in issuing and maintaining registry records, and is subject to the Data Privacy Act and National Privacy Commission oversight on that basis. Registration with the National Privacy Commission is in progress. |
In any complete ISET-issued transaction, three regulatory functions are distinct — performed by three different parties, under three different statutory frames. Conflating any two of them produces the lending-company question. Distinguishing them dissolves it.
| Party | Function | Regulatory frame |
|---|---|---|
| Bearer | Owns the underlying data right; retains it throughout. | RA 10173 data subject · registered beneficiary |
| Registration Provider | Bearer-facing registration; captures identity and consent. | RA 10173 personal-information controller for registration data |
| Partner Bank | Extends credit to the Bearer against the ePN as security. Takes control during the credit term. | RA 8791 BSP-supervised · lender under RA 11765, BSP 1213, NPC 22-02 |
| Secondary Holder | (Optional) takes control on assignment, pooling, or securitisation. | Acquirer of scheduled-payment rights · subject to carried-consent condition on the registry |
A bank may lend, the bearer owns the right, and ISET records the record. These are distinct legal roles under distinct regulatory regimes, and ISET acts only as the registry and signing root — never as issuer of the obligation, and never as lender. On personal data, ISET does not step back: it is directly accountable under RA 10173 for what it processes in operating the registry.
Because ISET is not a credit institution, it does not answer to the prudential, consumer-credit, or anti-usury frames that govern lenders. It answers to a different statutory stack — corporate law, secured-transactions law, electronic-commerce law, data-privacy baseline, and the model-law on electronic records.
| Instrument | What it gives ISET |
|---|---|
| RA 11057 §3, §11, §§30-33 | Personal Property Security Act · registers and perfects intangibles as property. |
| RA 8792 §7 | Electronic Commerce Act · functional-equivalence treatment of electronic records and signatures. |
| RA 10173 | Data Privacy Act · governs ISET’s role as a personal information controller for registry data — consent, security, and processing transparency, under National Privacy Commission oversight. |
| UNCITRAL MLETR §10 | Model-law standard for singular reliable identification of control. |
| FATF Rec. 24/25 | Beneficial-ownership transparency · met by ISET’s disclosure undertakings. |
| NIST FIPS 204 | Post-quantum signature standard (ML-DSA-65) · published public key. |
Notably absent from the list: RA 9474 (Lending Company), RA 8556 (Financing Company), RA 8791 (General Banking), BSP Circular 1213 §4 (SCA for lenders), NPC Circular 22-02 (loan-related data processing). These attach to credit institutions. ISET is not one.
ISET aligns to the complete UNCITRAL digital-commerce stack — the same model laws national legislatures are adopting worldwide. Six texts, from electronic commerce to AI-era automated contracting, define the standards ISET is engineered to meet.
| UNCITRAL Model Law | Year | ISET’s use | PH status |
|---|---|---|---|
| Electronic Commerce (MLEC) | 1996 | Functional equivalence of electronic records & signatures | Enacted · RA 8792 |
| Electronic Signatures (MLES) | 2001 | Reliable electronic signature standard | Enacted · RA 8792 |
| Secured Transactions (MLST) | 2016 | Perfection & priority of registered intangibles | Enacted · RA 11057 |
| Electronic Transferable Records (MLETR) | 2017 | The eTR instrument family · §10 control standard | Aligned · not yet enacted |
| Identity Management & Trust Services (MLIT) | 2022 | The signing root, identity, and trust-service role | Aligned · not yet enacted |
| Automated Contracting (MLAC) | 2024 | Legal frame for automated / AI-agency issuance & transfer | Aligned · not yet enacted |
Read honestly: these are model laws — international templates for national legislatures, not binding until a country enacts them. ISET aligns to their substantive standards (control, attribution, functional equivalence) while operating under the Philippine statutes actually in force (RA 11057, RA 8792). The Philippines has enacted MLST and MLEC; ISET is a working operational precedent for the three it has not yet adopted — MLETR-aligned, MLIT, and MLAC.
ISET, Inc. is a Philippine stock corporation registered with the Securities and Exchange Commission, operating the registry of record for electronic transferable records grounded on registered intangibles, under already-enacted RA 11057 and RA 8792. ISET’s constitutive instruments are available to verified counterparties under review.
ISET does not extend credit, does not advance funds, does not bear default risk on credit transactions, and is not regulated as a Lending Company under RA 9474, a Financing Company under RA 8556, a Bank or Quasi-Bank under RA 8791, or any equivalent credit-extending institution. ISET operates the registry of record for electronic transferable records under RA 11057, RA 8792, and the UNCITRAL Model Law on Electronic Transferable Records. ISET is not a party to the instruments it records; the obligations they evidence run between the issuing and holding counterparties. Credit, where extended in connection with an ISET-issued instrument, is extended by the BSP-supervised partner bank, not by ISET.
This statement appears on every customer-facing surface, every counterparty document, every integration spec, and every BSP-facing material. It is not a marketing disclaimer; it is the operative regulatory positioning of ISET.