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Toby Scammell

Executive

PPP
Type
Person
Role
Executive
Programs
PPP
Updated

The profile

Founder and CEO of Womply, the small-business software company that argued in March 2020 for sending relief through existing payment systems. Those systems already served small merchants, and in 2021 Womply routed about 1.4 million PPP loans from partner lenders to sole proprietors and other small businesses.

Individuals whose conduct was challenged or called into question during or after the pandemic. See sources: FTC complaint, March 18, 2024 Stipulated order, April 3, 2024 Kolbert complaint, Jan. 7, 2025 Kolbert dismissal, Sept. 5, 2025

Identity and role

  • Full name: Toby Scammell.
  • Role: Founder and CEO of Womply (legal entity OTO Analytics, Inc., formed in Delaware in February 2011, later Oto Analytics, LLC), San Francisco, from 2011 until the company wound down in 2022.12 He signed Womply's December 2021 sale as President; the buyer was an entity he owned.3
  • Also: co-founder, with Cory Capoccia, of Solo Global, Inc., a 2022 payments venture.4

Early career

Scammell studied at the University of Southern California and worked at Bain & Company, the management consultancy, before founding Womply. His AngelList page also listed him as an angel investor.5

Womply, 2011–2020

Scammell founded Womply in San Francisco in February 2011.1 It began with a consumer product: launched in the Washington, D.C., area in late October 2011, it loaded local merchants' offers onto shoppers' credit and debit cards and credited the discount after purchase, backed by nearly $1 million in seed money from Dave McClure of 500 Startups and Deebek Ventures.6 By early 2013 it had turned to software for the merchants themselves — CRM, marketing, reputation management and payments analytics for restaurants, salons and Main Street retail — built on partnerships, starting with TSYS in late 2013, with dozens of card processors that shared their merchants' transaction data.7 In 2014 while running Womply, Scammell pled guilty to insider trading, was sentenced to three months, and separately settled with the SEC over his trades.8 By Crunchbase's account Womply grew to about 500,000 software customers in more than 400 industries.2 It raised about $65 million in equity, including a $30 million round led by Sageview Capital in 2016 and about $15 million from Rakuten in 2019, and lost about $11 million in its last year before the pandemic.91011 Its data became a regular source for local business news, and from April 2020 the Federal Reserve cited it, including in its June Monetary Policy Report.1213

Advocacy, 2020–2021

In March 2020 Scammell argued for moving relief through the payment systems that already reached small merchants. A March 20 Business Wire release set out Womply's plan: using existing card-processing systems, the government would deposit each merchant's average daily card sales into its business bank account every day until the crisis passed, and recoup the money later from a small share of sales.14 A deck, "The Economic Apocalypse," made the case with Womply's data, and he briefed payments analysts at Citi, Deutsche Bank and Wells Fargo.1516 On March 24 he signed the fintech coalition letter asking Congress to let Treasury move "upwards of $500 billion" to small businesses through non-bank channels; the CARES Act, signed three days later, let non-bank lenders make PPP loans.1718 In March 2021, by Forbes Advisor's account, he wrote Womply's letter asking Congress to extend PPP past its March 31 deadline; the PPP Extension Act moved it to May 31.192021 When the SBA said on May 4 that PPP's general funding was exhausted, Womply's #fairPPP campaign, a petition and 414 tweets to about 385 Members of Congress, asked Congress to add money. Congress didn't.2223

PPP Fast Lane, 2021

Womply's first PPP year was small: in 2020 it referred about 7,000 loans and earned just under $3 million in fees.24 After the SBA let sole proprietors qualify on gross income in February 2021, Womply launched PPP Fast Lane on February 23. It took applications, checked identity and documents, and passed applicants to partner lenders, among them Harvest, Benworth, Capital Plus and Fountainhead.252627 The lenders made the credit decisions, held the SBA guarantees and collected the SBA's processing fees, and paid Womply under contract a referral fee, a per-loan API fee and a technology fee tied to those processing fees.28 About 1.4 million loans were funded through the platform in 2021, mostly for sole proprietors and the self-employed; Womply puts their value at about $19.6 billion, and a loan-level attribution of the SBA's data at about $24.2 billion.293031 The House Select Subcommittee identified Scammell as the highest-ranking executive responsible for Fast Lane's identity checks and anti-fraud measures, which relied on outside vendors that Womply paid for.3233

Womply's own two PPP loans, $3,103,440 in April 2020 and $1,999,997 in February 2021, both through Harvest, came before Fast Lane earned anything.343536

Lawsuits after the sale, 2021–2025

After the December 2021 sale Scammell stayed on as CEO of Oto Analytics, LLC and ran its litigation, most of it against partner lenders that had kept Womply's share of the fees on loans the SBA had already paid them for.

Benworth was the largest. Womply's JAMS arbitration, filed in August 2021, sought at least $151.7 million in withheld fees; Benworth had paid $465.0 million of the $616.7 million Womply billed. The arbitrator found $86.3 million of referral, API and technology fees unpaid. Benworth counterclaimed for about $420 million, arguing that the contracts were illegal. After a seven-day hearing in March 2023, the corrected final award of June 2024 gave Womply about $117.9 million, including finance charges and legal fees, and denied Benworth's counterclaims except for a request for borrowers' loan files.3738 To collect, Womply sued in Puerto Rico in January 2023 to unwind a transfer of about $171 million from Benworth to an affiliate owned by its founder; the Federal Reserve Bank of San Francisco later filed its own claims there. The award dispute ended in a confidential stipulated dismissal in January 2025, and the Puerto Rico action settled in September 2025.39

Womply's September 2021 suit against Capital Plus sought $76.7 million in fees on 86,521 funded loans, which had earned Capital Plus $186.9 million in SBA fees. After a May 2022 ruling kept Womply's main claims alive, the two settled on confidential terms, and the case was dismissed with prejudice in January 2023.4041 Against Fountainhead, Womply began a JAMS arbitration in June 2021 claiming more than $90 million; Fountainhead's CEO said it had already paid more than 80 percent of what Womply claimed. Fountainhead's Florida suit for its loan files was dismissed with prejudice in November 2022; the arbitration's outcome is not public.424344

Womply was also on the other side. Atlas Technology Group, which had worked on its fundraising, won a $27.2 million arbitration award in July 2023 over its fee on the 2021 sale.4546 The SBA denied forgiveness of Womply's own $5.1 million in PPP loans in September 2022; Womply appealed, and the SBA withdrew both denials that December.35

The FTC's 2024 case over Fast Lane's advertising is the one action that has named him personally. It said Womply promised applicants loans through an application taking "as little as five minutes" when 61 percent of the 3.25 million applications consumers started were never funded, and it quoted his memo on where applications fell away and his "You should ignore them," about applicants seeking help through a contractor's staff on LinkedIn. He and the company settled without admitting or denying the allegations: a $26 million judgment, a permanent injunction, and compliance reporting that runs to 2034.4748 A December 2022 House Select Subcommittee report built its Womply chapter around his conviction, and a week later the SBA announced it had suspended Womply; SAM.gov, the federal exclusions list, shows no active exclusion for Oto Analytics, Womply or Scammell.495051 No criminal charge, False Claims Act case or fraud finding by any court exists against him in any pandemic-relief matter.52

Where he is now (2025–2026)

In December 2021, after a year in which its internal financials showed net revenue of $2.09 billion, Womply was sold for about $1.09 billion to an entity Scammell owned; he remains the documented CEO of Oto Analytics, LLC in its litigation captions.533 Solo Global, the payments venture he and Capoccia formed in January 2022, appears dormant.4 womply.com now presents the company's account of its PPP years as "The Record."31

Documents on this site

Original source documents and archived copies

  • Womply March 2020 advocacy set (memo + deck)
  • Sell-side briefings (Citi, Deutsche Bank, Wells Fargo)
  • #fairPPP campaign (414 tweets and petition)
  • FTC v. OTO Analytics — RECAP pull
  • FTC v. OTO Analytics — case summary
  • JAMS Oto Analytics v. Benworth — corrected final award
  • Oto Analytics v. Capital Plus
  • Fountainhead v. OTO Analytics — full Florida docket
  • womply.com, "The Record" (archived on June 27, 2026)
  • womply.com, "The Record" (archived on September 17, 2026)
  • House Select Subcommittee report (Dec. 1, 2022), archived copy
  • BusinessWire, Womply direct-cash appeal (Mar. 20, 2020), archived copy
  • Coalition letter — OnDeck hosting, archived copy
  • Coalition letter — Womply hosting, archived copy

Sources

  1. California SOS business entity record C3363590 (Foreign Stock; registered March 7, 2011; agent Toby Scammell; 548 Market St. #73871, San Francisco): OpenCorporates, OTO Analytics, Inc. (California branch registration C3363590) (original: https://opencorporates.com/companies/us_ca/C3363590). Delaware formation date February 22, 2011 per OpenCorporates and the entity descriptions in the FTC complaint and JAMS award. The FTC complaint pins the same Market Street address as the principal place of business "between at least February 2021 and May 2021." ↩
  2. Crunchbase, "Toby Scammell" (Founder and CEO at Womply, Feb. 2011–2022; "approximately 500,000 software customers across more than 400 industries"), viewed Sept. 28, 2026 — original: https://www.crunchbase.com/person/toby-scammell. ↩
  3. Atlas Technology Group LLC v. Oto Analytics, LLC, AAA Interim Award (July 10, 2023): ¶ 2 ($1,092,500,000 distributed to shareholders), ¶ 13 (buyer holding company Oto Holdco, LLC), ¶ 15 ($1,090,984,577.30 allocated to stockholders before escrow; $1,413,347,000 in cash reported on the balance sheet before closing) and ¶ 16 (a $630,720,000 secondary escrow for claims tied to the PPP investigations) — original: https://jusmundi.com/en/document/decision/en-atlas-technology-group-llc-v-oto-analytics-llc-fka-oto-analytics-inc-and-dba-womply-interim-award-monday-10th-july-2023; Del. Ch. No. 2023-0900 confirmation petition (Sept. 1, 2023): buyer owned by Scammell, who signed as President; SRS Acquiom as paying agent. ↩
  4. Profile: Solo Global, Inc. (Delaware file 6583768, formed Jan. 31, 2022; solo.co offline as of June 2026). ↩
  5. AngelList, "Toby Scammell" ("Founder @Womply; Worked at @Bain & Company. Studied at @USC"), Internet Archive, Feb. 25, 2013 — original: https://web.archive.org/web/20130225164659/https://angel.co/toby-scammell; the Feb. 7, 2016 copy gives "University of Southern California": AngelList, Toby Scammell profile (Internet Archive copy of Feb. 7, 2016) (original: https://web.archive.org/web/20160207085231/https://angel.co/toby-scammell?desktop=0). ↩
  6. Sarah Perez, "Womply's New Deals Startup Loads Local Offers Onto Your Credit Cards," TechCrunch (Nov. 2, 2011), nearly $1 million from Dave McClure of 500 Startups and Deebek Ventures — original: https://techcrunch.com/2011/11/02/womplys-new-deals-startup-loads-local-offers-onto-your-credit-cards/; Crunchbase, "Seed Round - Womply" (May 1, 2011; lead Streamlined; also Otter Rock Capital, Charles Yim, Brendan Wallace), viewed Sept. 28, 2026: https://www.crunchbase.com/funding_round/womply-seed--54cf7c81; AngelList profile, Feb. 25, 2013 (20 investors, among them Dave McClure, Adam Jackson, Don Hutchison and Ullas Naik): AngelList, Womply company page (Internet Archive copy of Feb. 25, 2013) (original: https://web.archive.org/web/20130225164810/https://angel.co/womply). ↩
  7. Processor-partnership source set (primary press releases from the processors themselves) — TSYS Merchant Insights "powered by Womply" (Nov. 5, 2013, via Secure Technology Alliance) — original: https://www.securetechalliance.org/tsys-merchant-insights-allows-customers-to-monitor-impacts-of-social-media/; Vantiv "BizShield and Insights" (Apr. 12, 2017, PR Newswire): Vantiv "BizShield and Insights" (Apr. 12, 2017, PR Newswire) (original: https://www.prnewswire.com/news-releases/vantiv-announces-partnership-with-womply-to-put-the-power-of-big-data-in-the-hands-of-business-owners-300438510.html); Celero Commerce (Sept. 5, 2019): Celero Commerce Partners with Womply (original: https://celerocommerce.com/resources/2019/09/celero-commerce-partners-with-womply-to-help-businesses-grow/). The "50+ … data partners" roster is Womply's own "Economic Apocalypse" deck, slide 4. Note: the 2013 TSYS release names Jim Egbert as Womply's CEO — an unresolved CEO-name discrepancy. ↩
  8. SEC Litigation Release No. 22066 (Aug. 11, 2011); SEC Litigation Release No. 22838 (consent judgment and permanent injunction, June 2012): https://www.sec.gov/enforcement-litigation/litigation-releases/lr-22838; DOJ C.D. Cal. plea and sentencing releases (2014), as cited in Subcommittee footnotes ¶¶ 456–461. ↩
  9. Womply press release, Business Wire (Nov. 15, 2016), as carried by VentureBeat, putting the total raised since 2011 at $50 million — original: https://venturebeat.com/2016/11/15/womply-raises-30m-to-run-smb-front-offices; Business Wire: Womply Raises $30M to Run SMB Front Offices (original: http://www.businesswire.com/news/home/20161115006836/en/). Womply's site now gives "about $50 million" for everything "from Seed to Series C," the same figure it announced before the Series C; Crunchbase also shows $50 million, without the Series C. ↩
  10. Atlas Technology Group LLC v. Oto Analytics, LLC, AAA Interim Award (July 10, 2023) ¶ 9 (engagement amended Aug. 5, 2019 for "a Series C Financing effort"; Atlas's account of "a $15 million equity investment by Rakuten") and ¶ 20 (Scammell's testimony that Womply paid Atlas "as a thank you for their efforts in introducing us to Rakuten") — original: https://jusmundi.com/en/document/decision/en-atlas-technology-group-llc-v-oto-analytics-llc-fka-oto-analytics-inc-and-dba-womply-interim-award-monday-10th-july-2023; Aneeta Mathur-Ashton, The Messenger (Nov. 6, 2023), reporting Rakuten as lead investor of the Series C, citing "documents obtained by The Messenger": Japanese Company With Ties To Chinese Government May Have Profited From PPP Scheme (Exclusive) (original: https://web.archive.org/web/20240106142833/https://themessenger.com/politics/japanese-company-with-ties-to-chinese-government-may-have-profited-from-ppp-scheme-exclusive); Alana Goodman and Adam Kredo, Washington Free Beacon (Sept. 27, 2023): China’s Tencent Profited Off Fraudulent PPP Loans (original: https://freebeacon.com/national-security/chinas-tencent-profited-off-fraudulent-ppp-loans/). ↩
  11. House Select Subcommittee on the Coronavirus Crisis, "We Are Not the Fraud Police" (Dec. 1, 2022), ¶ 506 (internal financials). All ¶ citations below are to this report text unless noted. ↩
  12. Womply press page ("In the news"), Internet Archive copies 2016–2020, entries including Deseret News (Mother's Day in Utah), Phoenix Business Journal (spring break), Cincinnati Business Courier and Philadelphia Business Journal (March Madness), Fort Worth Star-Telegram (Super Bowl Sunday), Reno Gazette-Journal and Pacific Business News (Black Friday), Houston Business Journal and Houston Public Media (Hurricane Harvey), and Forbes, Search Engine Land and MediaPost (online reviews): https://web.archive.org/web/2020*/womply.com/press/*. The count of about 200 is of entries whose titles report Womply data, out of 446 listed before March 2020. ↩
  13. Diane Alexander and Ezra Karger, "Do stay-at-home orders cause people to stay at home? Effects of stay-at-home orders on consumer behavior," Federal Reserve Bank of Chicago Working Paper 2020-12 (first posted Apr. 17, 2020) — original: https://www.chicagofed.org/~/media/publications/working-papers/2020/wp2020-12-pdf.pdf; Board of Governors, Monetary Policy Report (June 12, 2020), Part 1: Board of Governors, Monetary Policy Report (June 12, 2020), Part 1 (original: https://www.federalreserve.gov/monetarypolicy/2020-06-mpr-part1.htm); FOMC, transcript of the June 9–10, 2020 meeting, p. 159 (Vice Chair Williams): FOMC Meeting Transcript, June 9-10, 2020 (original: https://www.federalreserve.gov/monetarypolicy/files/FOMC20200610meeting.pdf); Diane Alexander, Ezra Karger and Amanda McFarland, Chicago Fed Letter No. 445 (Aug. 2020): Measuring the Relationship Between Business Reopenings, Covid-19, and Consumer Behavior (original: https://www.chicagofed.org/publications/chicago-fed-letter/2020/445); Liberty Street Economics, "How Did State Reopenings Affect Small Businesses?" (Sept. 21, 2020): Liberty Street Economics, "How Did State Reopenings Affect Small Businesses?" (Sept. 21, 2020) (original: https://libertystreeteconomics.newyorkfed.org/2020/09/how-did-state-reopenings-affect-small-businesses/); Pia Orrenius and Chloe Smith, Federal Reserve Bank of Dallas (Sept. 24, 2020): Texas economy improves despite lagging sectors as COVID-19 cases decline (original: https://www.dallasfed.org/research/economics/2020/0924); Leland D. Crane et al., "Business Exit During the COVID-19 Pandemic: Non-Traditional Measures in Historical Context," FEDS 2020-089: Business Exit During the COVID-19 Pandemic (FEDS 2020-089) (original: https://www.federalreserve.gov/econres/feds/files/2020089pap.pdf); Ryan A. Decker, Robert J. Kurtzman, Byron F. Lutz and Christopher J. Nekarda, "Across the Universe: Policy Support for Employment and Revenue in the Pandemic Recession," FEDS 2020-099: Fed Feds Across Universe 2020 099 (original: https://www.federalreserve.gov/econres/feds/files/2020099pap.pdf); FOMC Tealbook A (Dec. 4, 2020), p. 93: Tealbook A, December 2020 (original: https://www.federalreserve.gov/monetarypolicy/files/FOMC20201216tealbooka20201204.pdf); FOMC presentation materials, July 28–29, 2020 (chart source "Federal Reserve Bank of Dallas, Opportunity Insights, Womply"): FOMC presentation materials, July 28–29, 2020 (chart source "Federal Reserve Bank of Dallas, Opportunity Insights, Womply") (original: https://www.federalreserve.gov/monetarypolicy/files/FOMC20200729material.pdf); Raj Chetty, John N. Friedman, Nathaniel Hendren, Michael Stepner and the Opportunity Insights Team, NBER Working Paper 27431 (June 2020): Document from nber.org (original: https://www.nber.org/papers/w27431). ↩
  14. Womply, "Womply Calls on Government, Fintech Leaders to Provide Direct Cash Stimulus to American Small Businesses," Business Wire (Mar. 20, 2020): source document; original: https://www.businesswire.com/news/home/20200320005097/en/. ↩
  15. Womply, "The Economic Apocalypse" / Stimulus2020 deck (March 2020, 16 slides): source document. ↩
  16. Citi Research, "FinTech Spotlight Series: Womply," Part I (Mar. 20, 2020) and Part II (May 1, 2020); Deutsche Bank, payments expert call with Womply (Apr. 5, 2020); Wells Fargo, "Trends in Small Business" call with Womply (Apr. 13, 2020). ↩
  17. Coalition "Letter to Congress" (March 24, 2020), verbatim text, signatories, and provenance/organizer notes. Hosted at OnDeck letter to Congress Mar. 24, 2020 (original: https://www.ondeck.com/press-releases/congress-letter OnDeck letter to Congress Mar. 24, 2020 (stored capture)) and Womply, "Letter to Congress" (March 24, 2020), womply.com press page (Internet Archive copy of Sept. 28, 2020) (original: womply.com). The letter names no organizer; the signature block is alphabetical by company. ↩
  18. CARES Act, Pub. L. 116-136 (signed Mar. 27, 2020), § 1102 (authorizing additional lenders for PPP). ↩
  19. Robin Saks Frankel, "Congress Could Extend The PPP Loan Deadline—If Lawmakers Can Act In Time," Forbes Advisor (updated Mar. 19, 2021): https://www.forbes.com/advisor/loans/ppp-loan-application-extension/; Internet Archive (Mar. 20, 2021): Robin Saks Frankel, "Congress Could Extend The PPP Loan Deadline—If Lawmakers Can Act In Time," Forbes Advisor (updated Mar. 19, 2021) (original: https://web.archive.org/web/20210320074205/https://www.forbes.com/advisor/loans/ppp-loan-application-extension/). ↩
  20. Womply, "Womply Joins 500+ Trade Organizations & Companies Urging Congress to Extend the PPP Until June 30th, 2021," Business Wire (Mar. 1, 2021), with the full text of the letter: https://www.businesswire.com/news/home/20210301005982/en/; Womply's copy of the release, Internet Archive (Apr. 11, 2021): Womply Joins 500+ Trade Organizations & Companies Urging Congress to Extend the PPP Until June 30th, 2021 (Press Release) (original: https://web.archive.org/web/20210411125144/https://www.womply.com/press/womply-joins-500-trade-organizations-companies-urging-congress-to-extend-the-ppp-until-june-30th-2021-press-release/); Womply blog, "PPP deadline looms: Womply joins 500+ orgs urging Congress for an extension" (Mar. 1, 2021), Internet Archive: Womply blog, "PPP deadline looms: Womply joins 500+ orgs urging Congress for an extension" (Internet Archive copy of Mar. 1, 2021) (original: web.archive.org). The release linked the list of co-signers as a PDF on womply.com; the file is no longer online and the Internet Archive has no copy, so the signers and the count of 500 are Womply's statement. ↩
  21. PPP Extension Act of 2021, H.R. 1799, Pub. L. 117-6: introduced Mar. 11, 2021 by Rep. Carolyn Bourdeaux; passed the House 415–3 (Roll no. 80) on Mar. 16 and the Senate 92–7 (Record Vote 140) on Mar. 25; signed Mar. 30, 2021 — original: https://www.congress.gov/bill/117th-congress/house-bill/1799 H.R.1799 - 117th Congress (2021-2022): PPP Extension Act of 2021 (stored capture). ↩
  22. Dan Ennis, "PPP runs out of funds for most lenders," Banking Dive (May 5, 2021), citing the SBA update posted by the American Bankers Association and SBA spokesperson Carol Wilkerson ("funding for the bipartisan Paycheck Protection Program has been exhausted") — original: https://www.bankingdive.com/news/paycheck-protection-program-SBA-ABA-ICBA/599606/. ↩
  23. fairppp.com petition (Internet Archive, May 18, 2021): fairppp.com, "Ask Congress to add funds to the Paycheck Protection Program (PPP)" petition page (Internet Archive copy of May 18, 2021) (original: web.archive.org); the 414 @womply #fairPPP tweets, May 5–21, 2021, each with its permalink. ↩
  24. Subcommittee ¶¶ 397–398 (ten referral agreements; ~7,000 loans; ~$360M; just under $3M in 2020 fees). ↩
  25. Economic Aid Act (Dec. 27, 2020); White House fact sheet and SBA IFR on Schedule C gross-income calculation (effective Feb. 22–March 2021 window). ↩
  26. Womply, "Womply Launches PPP Fast Lane" (Feb. 23, 2021). ↩
  27. Partnership releases: Benworth (Mar. 10, 2021); Harvest (Apr. 20, 2021); published lender network page, Internet Archive copies Apr. 17 and Aug. 5, 2021. ↩
  28. JAMS Corrected Final Award (June 26, 2024) — contract architecture (Referral Agreement Feb. 25 / Apr. 14, 2021; Developer Order Form; Technology Fee tiers), Under-Funding Fee and 10% finance charges; Subcommittee ¶ 421. The all-in Benworth rate — $616.7M billed against $680M in SBA fees received, ~91%, ~$2,022 per funded loan — is computed. ↩
  29. Scale and attribution: House Select Subcommittee ¶¶ 397–408 (3.7M submitted / 2.58M referred / ~1.3M funded in 2021); loan-level attribution identifies ~1.41M loans / ~$24.2B across seven identifiable lenders, on full-program lender totals. Lender-attribution caveats apply — partner-lender totals are not single-fintech totals. ↩
  30. Loan-level attribution across seven identifiable Womply-associated lenders, on full-program lender totals, including Lendistry via its relationship with Harvest (~1.41M loans; ~$24.2B net; ~$17.1k average). ↩
  31. womply.com "The Record," claims attributed to Womply: as archived on June 27, 2026 and September 17, 2026; homepage FAQ: "Toby Scammell founded Womply (legally Oto Analytics, Inc.) in San Francisco in 2011 and led the company as CEO through its merger in 2021"; homepage loan figures ~1.4 million loans and $19.6 billion. ↩
  32. Subcommittee ¶¶ 454–455. ↩
  33. JAMS Corrected Final Award (June 26, 2024) ¶ 44 (the Order Form's third-party providers: "Plaid, Docusign, LexisNexis, Teslar, Inscribe, Ocrolus, AWS Mechanical Turk, Mindee, Persona, Twilio, Sendgrid"), ¶ 50 (government-ID photo, tax filings and "selfie" uploads), ¶ 53 (SendGrid, Twilio, Google Maps, Persona, Inscribe, Mindee, Ocrolus and Plaid; "Womply paid these third-party service providers for their technology"). ↩
  34. SBA PPP loan-level data (Sept. 30, 2024 release), Oto Analytics, Inc.: loan 5187557106, $3,103,440, approved Apr. 13, 2020, and loan 4959988403, $1,999,997, approved Feb. 7, 2021, both Harvest Small Business Finance, LLC; jobs reported 108 and 97. ↩
  35. SBA motions to dismiss and Frulla declarations, OHA appeals of loans 5187557106 / 4959988403 — decisions withdrawn Dec. 16, 2022 after Oto supplied the requested documents; dismissal sought because no final decision remained. The Sept. 1, 2022 Loan Review Decisions and their grounds (first-draw: eligibility documentation insufficient; second-draw: derivative ineligibility) are reproduced in the House production. Forgiveness amount/date blank for both loans in the SBA public-use file (Sept. 30, 2024 vintage). ↩
  36. House Select Subcommittee on the Coronavirus Crisis, "We Are Not the Fraud Police," Section III.C (Dec. 1, 2022) — ¶¶ 453–466 (the prior and § 103.4(f)), ¶¶ 507–525 (own loans; Chasm LLC; Capoccia loans). ↩
  37. JAMS Corrected Final Award (June 26, 2024): Benworth 'has paid Womply $464,991,487 in fees' (¶61); Womply's Demand sought 'at least $151,673,382' (¶9); at the 70% tier Womply 'was owed $529,876,104 in Technology Fees' (¶118); unpaid principal awarded $86,299,892 ($4,348,275 referral + $17,067,000 API + $64,884,617 technology). $616.7M billed = paid + demanded (computed). Demand filed Aug. 25, 2021. ↩
  38. JAMS 1210038203, Corrected Final Award (June 26, 2024). ↩
  39. Cross-petitions, N.D. Cal. 24-cv-03975 / 24-cv-04840 (filed June 2024; dismissed with prejudice by stipulation Jan. 2, 2025); collection action D.P.R. 3:23-cv-01034 — original: https://www.courtlistener.com/docket/66754913/oto-analytics-llc-v-benworth-capital-partners-pr-llc/; FRBSF v. Benworth consolidated fraudulent-transfer record, opinion denying MTD (Apr. 2, 2025) and Sept. 10, 2025 settlement. The $171 million: Womply letter to the arbitrator, Dec. 21, 2022 (Dkt. 163-1), pp. 3–5, quoting Navarro's Dec. 16, 2022 deposition; JAMS Order No. 5, Jan. 17, 2023 (Dkt. 163-2), p. 2; Womply complaint, Jan. 24, 2023 (Dkt. 1), ¶¶ 2, 176. The Reserve Bank's figures: FRBSF complaint, July 10, 2024 (24-cv-01313, Doc. 1), ¶¶ 57–58. ↩
  40. Oto Analytics, Inc. v. Capital Plus Financial, LLC, N.D. Tex. 3:21-cv-02636-B; the May 11, 2022 order (Doc. 82; counts 1, 2, 3, 9 survive, counts 4–8 dismissed without prejudice with leave to amend). ↩
  41. Doc. 82 (May 11, 2022, Boyle, J., 29 pp.): denies the motion as to counts 1, 2, 3 and 9 (declaratory judgment, tortious interference, fraud, civil conspiracy) and dismisses without prejudice counts 4–8 (negligent misrepresentation, promissory estoppel, unjust enrichment, breach of contract, quantum meruit), with thirty days to amend — Memorandum opinion and order on motion to dismiss — Womply v. Capital Plus (N.D. Tex. No. 3:21-cv-02636); administrative closure Nov. 14, 2022; dismissal with prejudice Jan. 5, 2023. Blueacorn and Calhoun were dismissed earlier on personal-jurisdiction grounds (Doc. 68, Apr. 2022). ↩
  42. Fountainhead SBF, LLC v. OTO Analytics, Inc., Seminole County (Fla.) No. 2021CA002143 — termination (May 26, 2021), file request (June 16), § 6.3 turnover theory (complaint Aug. 27, 2021; verified/amended petitions Sept. 8–10, 2021). Womply's JAMS demand against Fountainhead (No. 1100-111-808, commenced June 15, 2021, $90 million+ claimed) per Womply's Sept. 13, 2021 motion to compel arbitration (docket entry 13). ↩
  43. Hurn affidavit (Sept. 7, 2021), Fountainhead v. OTO Analytics: "paid Womply greater than 80% of the amount Womply claims it is owed." ↩
  44. Full 31-entry docket, Fountainhead v. OTO Analytics: Order to Show Cause (Oct. 7, 2021, "no merits determination"); no injunction entered; voluntary dismissal with prejudice (Nov. 18, 2022), each side bearing its own costs. The Subcommittee's secondhand "temporary restraining order" line is ¶ 479. ↩
  45. Atlas award $27,174,614.43 plus interest (AAA Interim Award July 10, 2023; Del. Ch. 2023-0900 confirmation petition Sept. 1, 2023); Payment from the SRS escrow has not been independently confirmed; the confirmation order has not been located. ↩
  46. Atlas Technology Group, LLC v. Oto Analytics, LLC (fka Oto Analytics, Inc. and d/b/a Womply), Del. Ch. No. 2023-0900, Verified Petition to Confirm Arbitration Award (Sept. 1, 2023), via JusMundi: En Atlas Technology Group Llc v. Oto Analytics Llc Fka Oto Analytics In (original: https://jusmundi.com/en/document/pdf/other/en-atlas-technology-group-llc-v-oto-analytics-llc-fka-oto-analytics-inc-and-dba-womply-verified-petition-to-confirm-arbitration-award-friday-1st-september-2023) ↩
  47. FTC v. OTO Analytics, Inc. d/b/a Womply and Toby Scammell, N.D. Cal. 3:24-cv-01661-WHO — complaint (Doc. 1), proposed stipulated order (Doc. 2), entered stipulated order (Doc. 10, Apr. 3, 2024). FTC press release (Mar. 18, 2024) — original: FTC, "FTC Actions Against Companies Making Deceptive Pandemic Loan Promises…" March 2024 (original: ftc.gov · stored capture); on this site: FTC Actions Against Companies Making Deceptive Pandemic Loan Promises Lead to Record $59 Million in Damages; FTC-hosted complaint and signed order archived on 2026-09-17. The companion case was FTC v. Biz2Credit (unaffiliated). ↩
  48. FTC complaint ¶¶ (funnel counts: 3.25M consumer-initiated applications, 1.99M never funded; waterfall memo; "You should ignore them"); the complaint pleads four counts — I and II (FTC Act: false, misleading or unsubstantiated claims regarding obtaining PPP loans; regarding application time) and III and IV (COVID-19 Consumer Protection Act: misrepresentations associated with a government benefit regarding obtaining loans; regarding application processing time); the word "fraud" does not occur in its text (Complaint — FTC v. Oto Analytics (N.D. Cal.)). ↩
  49. Subcommittee report, Section III.C (Womply), Dec. 1, 2022; full report PDF — original: https://coronavirus-democrats-oversight.house.gov/sites/evo-subsites/coronavirus-democrats-oversight.house.gov/files/2022.12.01%20How%20Fintechs%20Facilitated%20Fraud%20in%20the%20Paycheck%20Protection%20Program.pdf local copy The House report is a partisan staff document released by the Democratic majority's staff in the final weeks of the 117th Congress, with no public hearing and no sworn testimony; an arbitrator refused it as "rank hearsay" that relied on companies then in arbitration with Womply, and a federal judge declined to take judicial notice of its findings (about the report). ↩
  50. SBA statement (Dec. 8, 2022): SBA, "Statement on the House Select Subcommittee on the Coronavirus Crisis Report" Dec. 8, 2022 — "full investigation... (original: sba.gov · stored capture) (now served from legacy.sba.gov), captured verbatim 2026-09-17; Banking Dive (Dec. 8, 2022), incl. the Goldfeder quotes: Document from bankingdive.com (original: Banking Dive, "SBA bars Womply, Blueacorn; investigates Cross River, Celtic, Customers" Dec. 9, 2022 — Hurn cooperati... (original: bankingdive.com · stored capture)). ↩
  51. SAM.gov exclusions search (keyword, all words) for "Oto Analytics," "Womply" and "Toby Scammell," run Sept. 28, 2026: no results for any of them: https://sam.gov/search/?index=ex&sfm%5BsimpleSearch%5D%5BkeywordRadio%5D=ALL&sfm%5Bstatus%5D%5Bis_active%5D=true. ↩
  52. Search of DOJ public PPP-fraud press releases and dockets, June 15, 2026: no criminal or False Claims Act case names Womply, Oto Analytics or Scammell. ↩
  53. Subcommittee ¶¶ 503–505 (2021 net revenue $2.09B; gross profit $1.8B, 87.6% margin; opex $160M; net income > $1.3B); accrual-vs-cash reconciliation. ↩
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