Profiles · OversightControversial
- Type
- Person
- Role
- Oversight and enforcement
- Programs
- PPP
- Updated
The profile
An FTC Bureau of Consumer Protection staff attorney, one of three FTC lawyers named on the 2024 Womply complaint, which ended in a $26 million stipulated judgment.
Individuals whose conduct was challenged or called into question during or after the pandemic. See sources: Womply stipulated order, April 3, 2024
In the archive
- Interactive: Where Pandemic-Oversight Lawyers Went Next
- Profile: Lina Khan
- Profile: Samuel Levine
Identity and role
Paola Henry (NY Bar No. 5612890) is a staff attorney in the FTC Bureau of Consumer Protection. She is one of three FTC attorneys listed on the complaint in FTC v. OTO Analytics, Inc., also d/b/a Womply, and Toby Scammell, N.D. Cal. No. 3:24-cv-01661, filed March 18, 2024, with Julia Heald and Katherine Worthman. The complaint's electronic signature is Heald's (complaint). The FTC's release names the same three as the staff attorneys on the matter (FTC press release).
What the complaint alleged
The FTC sued Womply (OTO Analytics) and its CEO, Toby Scammell, under Section 5(a) of the FTC Act and the COVID-19 Consumer Protection Act, in four counts. The complaint alleges that Womply told small businesses their PPP applications would be processed fast, "such as within 24 hours," and that funds would be secured for them. By the complaint's count, of more than 3.25 million PPP applications consumers started with Womply, more than 1.99 million, or 61 percent, were never funded (complaint). It quotes referral-partner material offering a loan "of up to $41,666" in five minutes.
How it ended
The complaint and a proposed order were filed the same day. The court entered the stipulated order on April 3, 2024. It permanently bans misrepresentations about any financial product or service unless substantiated, and it enters a $26,000,000 judgment against Womply and Scammell jointly and severally, paid to the Commission from funds held in escrow by defense counsel (stipulated order). The defendants neither admitted nor denied the allegations; the order provides that the complaint's facts will be taken as true in any later FTC action to collect. Kelley Drye & Warren signed for the defendants.
The FTC announced the Womply order alongside a separate $33 million Biz2Credit settlement and said the two were "the largest damages amounts ever secured by the agency under Section 19 of the FTC Act" (FTC press release).
Since 2025
No later role is documented in a source we have.
Documents on this site
Original source documents and archived copies
- Court-filed complaint, FTC v. OTO Analytics / Womply, N.D. Cal. 3:24-cv-01661
- Court-filed stipulated order, FTC v. OTO Analytics / Womply
- FTC, Womply, FTC v. case page
- FTC press release, combined Womply/Biz2Credit settlements Mar. 18, 2024
- FTC stipulated order, FTC v. OTO Analytics/Womply entered Apr. 3, 2024
- FTC complaint, FTC v. OTO Analytics/Womply Mar. 18, 2024
Sources
- FTC, Womply, FTC v. case page: FTC, Womply, FTC v. case page (original: ftc.gov · stored capture)
- FTC complaint, FTC v. OTO Analytics/Womply (Mar. 18, 2024): Womply FTC FTC Womply Complaint Pdf (original: ftc.gov · stored capture)
- FTC stipulated order, FTC v. OTO Analytics/Womply (entered Apr. 3, 2024): Womply Ftc Ftc Womply Signed Stipulated Order Pdf (original: ftc.gov · stored capture)
- FTC press release, combined Womply/Biz2Credit settlements (Mar. 18, 2024): FTC, "FTC Actions Against Companies Making Deceptive Pandemic Loan Promises…" March 2024 (original: ftc.gov · stored capture)
- Complaint, FTC v. OTO Analytics, Inc., No. 3:24-cv-01661 (N.D. Cal. Mar. 18, 2024)
- Stipulated Order for Permanent Injunction and Monetary Judgment (Apr. 3, 2024)
- Cross-reference: Julia Heald, Katherine Worthman, FTC v. Womply case file