Womply

• Type: SMB software company that became PPP's largest technology agent and lender-service platform — never a lender of record.
• Brand vs. entity: Womply is the brand; OTO Analytics, Inc. is the Delaware corporation behind it (formed February 22, 2011; California foreign registration C3363590, March 7, 2011, agent Toby Scammell, 548 Market Street #73871, San Francisco).¹ The corporation converted to Oto Analytics, LLC with the December 2021 sale; the cleanest caption of record is Delaware Chancery's "Oto Analytics, LLC (fka Oto Analytics, Inc. and d/b/a Womply)."²
• Founded: 2011, San Francisco, by Toby Scammell.
• Role in PPP: built PPP Fast Lane (launched February 23, 2021) — borrower intake, pre-qualification, and routing to partner CDFI and non-bank lenders, who made the credit decisions, held the SBA guarantees, collected the SBA processing fees, and paid Womply out of them.³

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How Womply handled layoffs →

Fundraising history

Womply raised about $65 million in equity: $50 million by the end of 2016, by its own count, and about $15 million from Rakuten in 2019.⁴⁵ The rounds were a seed round in 2011;⁶ a Series A in 2014, including a $20 million round in August led by Merus Capital and Streamlined Ventures;⁷ a $30 million Series B led by Sageview Capital in November 2016;⁸ and the 2019 Series C, which Rakuten led. It also borrowed $10 million from Trinity Capital in 2018, a loan off Trinity's books by March 2021.⁹ It was never an SEC registrant.¹⁰

Team

Toby Scammell was Founder & CEO; Cory Capoccia served as President. Womply reported 108 jobs on its first PPP loan, approved in April 2020, and 97 on its second, in February 2021.¹¹

Pre-pandemic business (2011–early 2020)

Womply 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.⁶ By early 2013 it had turned to software for the merchants themselves, and for the rest of the decade it was a good, unglamorous software business: CRM, marketing, reputation management, and payments analytics for restaurants, salons, and Main Street retail — the "Womply Commerce Graph," built on partnerships, starting with TSYS in late 2013, with dozens of card processors and other financial-services companies, whose card-transaction data it received and whose merchants, about half a million, it served directly.¹²¹³¹⁴ It called itself the leading software partner to the merchant-processing industry and lost about $11 million in its last pre-pandemic year.¹⁵ News organizations cited its small-business sales data repeatedly: by early 2020 its press page listed about 200 outside stories built on it, from local business journals to Marketplace, USA Today, Bloomberg, CBS News and Fox Business.¹⁶¹⁷ What it owned was real-time visibility into small-business revenue across the country.

Early pandemic (2020)

From April 2020 the Federal Reserve used Womply's data; a Chicago Fed working paper posted April 17 thanked Womply for access. The Board's June Monetary Policy Report said "[d]ata from Womply, a provider of credit card transaction processing services, suggest that spending at small restaurants was down 80 percent (versus a year earlier) by early April and was still down 50 percent in early June," and at that month's Federal Open Market Committee meeting New York Fed president John Williams said "based on data from Womply, revenues at New York small businesses are still 40 percent below January levels." Womply figures also ran in a Chicago Fed Letter, the New York Fed's Liberty Street Economics, a Dallas Fed analysis, two Board staff working papers and the staff briefing book for the December meeting. The Opportunity Insights tracker built by Raj Chetty's team, which Fed staff also drew on, used Womply for its small-business revenue series. One of the Board papers called Womply "[a]nother popular source of data on small business experiences in 2020," adding that its "representativeness and coverage properties … have not been thoroughly explored."¹⁸

Womply's first PPP year was modest: referral agreements with ten lenders and platforms, about 7,000 loans referred, roughly $360 million funded, just under $3 million in fees.¹⁹ It leaned on its processor relationships: in April 2020 the acquirers Clearent (now Xplor Pay), Fattmerchant (now Stax), and Electronic Merchant Systems each announced they were routing merchants to Womply's PPP platform, each stressing that Womply was a registered SBA loan agent, not a lender.²⁰ The average PPP loan in that first round ran above $50,000, because the program was built around payroll — which meant employers, which meant businesses banks already knew. The one-person business was still at the back of the line, and Womply spent the year building for it: in November 2020 it acquired Insurgent, Inc. d/b/a FundRocket for ~$15 million in stock, adding loan-file management and fraud-detection technology.²¹

PPP Fast Lane (January–April 2021)

The Economic Aid Act reopened PPP in December 2020, and on February 22, 2021 the White House allowed Schedule C filers to qualify on gross receipts — turning tens of millions of sole proprietors, contractors, and single-person businesses into eligible borrowers overnight.²² It also created an operational problem no bank wanted: millions of tiny, documentation-light loans yielding about $1,300 in SBA fee income each, for customers with no banker to call. The looser rules also raised the risk of fraud at volume, and lenders said so. The SBA's own rule conceded that using gross income "may, in some cases, increase the risk of waste, fraud, or abuse." Its Inspector General later found that lenders "sometimes directly reported to and discussed with SBA elevated fraud risks, particularly regarding loans made to certain borrowers who used IRS Form 1040, Schedule C," and that the change produced "a significant increase in loans, the majority being made by non-bank lenders."²³ By February 3 Womply had announced 250,000 businesses served across both years, with a 2021 average loan of $22,000, a third of its 2020 average, as sole proprietors moved in.²⁴ On February 23, 2021, one day after the rule change, it launched PPP Fast Lane with Fountainhead SBF as first announced partner. Benworth Capital followed March 3, then SEDCO (April 16), Harvest (April 20), and TMC Financing (April 21); the published network page listed Harvest, Benworth, Capital Plus, Fountainhead, DreamSpring, Sunshine State EDC, and TMC as Fast Lane lenders, with Cross River, Celtic, Kabbage, Fundbox, OnDeck, and Funding Circle taking referrals alongside.²⁵

The contracts, signed "OTO Analytics, Inc. d/b/a Womply," had three layers: a referral fee of 1% of principal, expressly subject to the SBA's agent-fee cap; a $250-per-funded-loan API fee under the Developer Order Form; and a tiered Technology Fee reaching 80% of the lender's SBA processing fee at the 60,001–300,000-loan tier. Every dollar depended on a loan funding — no retainer, no minimum — while Womply, which had lost money the year before, paid for the platform, staff and advertising.²⁶ Womply's costs came first: it paid for the verification checks that ran on every application, whether or not the loan funded and a fee came due. The lenders' costs came later, in servicing the loans and processing forgiveness, which one public PPP lender, Ready Capital, called "pretty minimal."²⁷ Both later bore the cost of fraud investigations and subpoenas: Womply says it answered legal process from 48 agencies between 2021 and 2024, and Harvest, one of its partner lenders, was subpoenaed in a 2025 False Claims Act case over a hotel's PPP loans.²⁸²⁹

3.7 million applications were submitted through Womply in 2021; 2.58 million were referred to lenders after pre-qualification; about 1.3 million funded. In March 2021 alone, 889,275 applications went to lenders; in April, more than 1.2 million, with 375,000 in a single week.³⁰ Loan-level attribution across seven identifiable lenders puts Womply's full book, on full-program partner-lender totals, at ~1.41 million loans and ~$24.2 billion — the largest facilitator loan book of the program, larger by count than any single PPP lender of record.³¹

The average Womply-channel loan was about $17,000, against $100,000-plus program-wide in April 2020, because these were the people the program's first year had skipped. The named-platform gig workforce went from 40,461 PPP loans in 2020 to 409,313 in 2021 — a ten-fold jump concentrated in exactly the months Fast Lane operated.³² The peer-reviewed record settled what that meant: Howell, Kuchler, Snitkof, Stroebel and Wong, in the Journal of Finance, found that Black-owned firms obtained PPP loans primarily from automated fintech channels, and that automation itself — smaller loans, wider geography, no loan officer's discretion — is what closed the gap.³³

Political advocacy (2020–2021)

Before the CARES Act (March 2020)

When the shutdowns began, Womply used its data to measure the damage to Main Street and spent the second week of March 2020 publicizing it. A March 20 Business Wire release set out its plan: using existing card-processing systems, the government would deposit each merchant's average daily card sales from December 1, 2019 to February 29, 2020 into its business bank account every day until the crisis passed, and later recoup the money through "a small percentage of the prior day’s sales—say 5%," as grants or loans. Scammell said the approach would be "lower-risk, more auditable, and—critically—much faster" than existing options.³⁴ A sixteen-slide deck, "The Economic Apocalypse," and the live Stimulus2020.com made the same case with the company's own collapse data.³⁵ The same day as the release, Scammell briefed Citi's payments analysts on the record. Deutsche Bank and Wells Fargo followed in April. The data went to government and press for free.³⁴

On March 24, 2020, Scammell signed the fintech coalition letter asking congressional leadership to give Treasury flexibility to move "upwards of $500 billion" to small businesses through non-bank channels; Womply was one of only two companies to publish it — on its own press page, alongside OnDeck's.³⁶ Three days later, CARES became law with the non-bank-lender provision the letter had asked for.³⁷

The PPP extension (March 2021)

The program was due to stop taking applications on March 31. On March 1 Womply sent Speaker Pelosi and Leaders Schumer, McConnell and McCarthy a letter that it said spoke for "more than 500 trade organizations, business groups, and small businesses," asking Congress to extend PPP "until at least June 30th, 2021." "Some of the undersigned lenders already have hundreds of thousands of backlogged PPP applications," the letter said, and there was "simply not enough time in the next month for the SBA and ~5,000 lenders to convert rule changes into technical, content, support, and compliance updates and then get new applicants processed, approved, and funded."³⁸ Forbes Advisor reported that Scammell wrote the letter and quoted him: "Our point has been that there's enough money in this program, there's just not enough time."³⁹ Capoccia asked fellow members of YPO, the chief executives' network, to press Congress for the same.⁴⁰ The PPP Extension Act moved the deadline to May 31 and gave the SBA until June 30 to process applications; it passed the House 415–3 on March 16 and the Senate 92–7 on March 25, and was signed on March 30.⁴¹ April, which the old deadline would have cut off, became Fast Lane's busiest month.³⁰

#fairPPP (May 2021)

On May 4, 2021, nearly four weeks before the May 31 deadline, the SBA said PPP's general funding was exhausted and stopped taking new applications from most lenders; what was left, about $8 billion by the American Bankers Association's count, was reserved for community development and minority lenders.⁴² Womply's response was to lobby for the borrowers, loudly: the #fairPPP campaign — a fairppp.com petition and 414 tweets aimed at roughly 385 Members of Congress over sixteen days in May — told members how many businesses they represented had been "turned away because PPP suddenly ran out of funds" and asked Congress to add funding. Congress didn't; the program closed to applications on May 31 with roughly a million applications still queued.⁴³

Anti-fraud efforts (2021–2024)

Every Fast Lane applicant had to upload a photo of a government ID, tax filings and a "selfie," and the checks behind them came from outside vendors that Womply paid for: SendGrid for email addresses, Twilio for phone numbers, Google Maps for addresses, Persona for identity, Inscribe, Mindee and Ocrolus for documents, and Plaid for bank accounts.⁴⁴ The House Select Subcommittee on the Coronavirus Crisis later identified Scammell as the highest-ranking executive with "responsibilities related to the KYC process and anti-fraud measures implemented by Womply for the Fast Lane Program."⁴⁵

The checks tightened as the volume grew. In its April 2022 response to the Subcommittee, Womply said DocuSign's knowledge-based ID Check, powered by LexisNexis, handled identity verification from about February to early April 2021. From early April every applicant, including those already sent to lenders, had to pass a Persona inquiry: name, date of birth and Social Security number checked against OFAC and other sanctions lists and the motor-vehicle administrators' database, a "video selfie," and an ID check. Twilio screened out VoIP numbers, and Womply came to block anonymous and non-U.S. IP addresses, proxies, VPNs and Tor. The same response lists a threat-intelligence vendor, Flashpoint, reporting on "how to defraud Womply and the PPP program"; limits on how many applications and Social Security numbers could share one bank account; and a reportfraud@womply.com inbox, kept until "the SBA discouraged Womply from collecting these reports" and Womply sent tipsters to the SBA instead.⁴⁶

Womply's emails to Benworth show the change as it happened. On April 8, 2021 it described more manual review, a warning screen shown to every borrower, and emails telling applicants "they should not attempt to commit fraud through PPP Fast Lane," which it expected would "minimize casual fraud." In the first days of May it wrote that it had moved "from sampling approved KYC reports on an ad hoc basis to manually reviewing hundreds of thousands of approved KYC reports and manually canceling fraudulent loans," had hired a full-time team of KYC specialists, expected "nearly 100% of funded loans going forward" to be reviewed by hand, had given the SBA its list of approved but fraudulent loans ("some funded, most not"), and, "with help from the SBA," had sent freeze instructions to Chime, Chase, Green Dot, Wells Fargo and Bank of America for accounts that still held the money.⁴⁷ Benworth's CEO replied on May 7: "What happened to the systems you had in place that you were so quick to remind me of yesterday?"⁴⁸ In 2022 Womply estimated that its work with banks had returned about $6 million in fraudulently obtained loan proceeds.⁴⁶

Womply's website, now an archive it calls The Record, says Womply "was among the private partners working hardest to stop PPP fraud," that it "added biometric selfie matching and liveness checks that SBA rules did not specifically prescribe," and that its screening "stopped more than 1.1 million suspicious or ineligible applications before they reached a lender." It adds a dated account of what it says it reported to the government, citing correspondence it describes as withheld. By that account it urged the SBA in February 2021 to verify income against IRS records instead of applicant-supplied tax forms, proposed screening applicants against identity databases in early March, and reported the first organized fraud ring it had detected in mid-March. On April 30 it sent the SBA, its Inspector General and the Department of Homeland Security a file of about 5,000 fraudulent applications tied to organized rings, "the first of many such files," and opened a working relationship with the FBI. On May 5 it gave DHS a 258 MB export of 2,893,890 identity and IP records covering 1,474,108 applications. In May it gave the SBA a list of 13,798 loans tied to compromised identities, filed a formal complaint with the Inspector General, ran analyses for the Inspector General at its request, and proposed requiring IRS Form 4506-T from every applicant, since without IRS verification of self-certified income "a well-made fake and a genuine document can look identical."²⁸

The site also reproduces a May 2021 memo to the SBA, the FBI and other agencies, "Steps to reduce fraud," which warned that "[t]housands of these applications have been approved by SBA, indicating that the processes used by SBA to detect and prevent identity fraud are having minimal impact." Its 17 recommendations include blocking foreign and anonymous IP addresses, VoIP numbers, temporary, paper and foreign IDs, and online-only banks; requiring video selfies with manual review, ACH deposits into named bank accounts and a balance of more than $20; and limits on devices per applicant and tax IDs per bank login. Among Schedule C and F filers, it says, about 95 percent of confirmed fraud came within $500 of the maximum loan, $20,833 on a first draw.⁴⁹ The site publishes the reproduction, with vendor names replaced, not the original.

For 2021 to 2024 the site says Womply answered legal process from at least 48 federal, state and local agencies, among them the FBI, the Justice Department, the IRS, the Secret Service, Homeland Security, the SBA Inspector General, the Federal Reserve and the Senate Permanent Subcommittee on Investigations, in more than 370 productions, each with a sworn certificate of authenticity. It says its records helped convict defendants in 14 or more federal prosecutions in more than ten districts, that no defendant successfully challenged them, and that in one trial its login and upload logs disproved a defendant's sworn testimony that he "didn't fill out anything."²⁸

Some of this appears in records outside the site. The ID photo, the selfie and the paid vendors are findings of the Benworth award; the April and May 2021 emails and the 2022 response are in the Subcommittee's own document release; and the Subcommittee's figures leave a gap of about 1.1 million, the size of Womply's screening claim, with more than 3.7 million applications submitted in 2021 and 2.58 million, 70 percent, sent on to lenders.³⁰ The April 30 file, the 13,798-loan list, the DHS export, the memo's original and the prosecutions rest on Womply's own account, drawn from records it says it is withholding.

Aftermath and exit (2021–2022)

Friction with lenders and the government

The complaints had started arriving in March. DreamSpring wrote in March and April about "rampant fraud" in some Florida-routed batches. Benworth's CEO wrote Scammell and Capoccia in May about "rampant fraud" in the 200,000-plus applications Benworth had funded. Lendistry's CEO flagged fraud inquiries on Harvest-routed volume in June. Fountainhead's CEO would later tell congressional staff the platform was "kind of put together with duct tape and gum."⁴⁸ The complaints were written by lenders who had collected hundreds of millions of dollars in SBA processing fees on Womply-routed loans and were disputing, withholding or renegotiating Womply's contractual share. None of these characterizations was ever tested before a neutral fact-finder and survived. In the one proceeding where a lender put fraud in issue, the Benworth arbitration, Benworth dropped its promissory-fraud defense before the hearing when ordered to produce its list of fraudulent loans or say whether it would keep the defense; the award that followed attributes no fraudulent loan to Womply.⁵⁰

The friction with the government was real too. From May 2021, Fountainhead and SBA's Inspector General asked Womply for borrower data and loan files for fraud investigations; Scammell's June 10 reply said Womply would not do the research work without a contract, under an "a la carte" fee list — legally defensible, since Womply had no contract with SBA and was not the lender of record, and harder-edged than its position required in the middle of a fraud wave. On June 11, 2021, SBA wrote that Womply appeared to still be accepting applications after the program closed and called its homepage "misleading."⁵¹

2021 results and the sale

The money mostly arrived. Womply's 2021 internal financials, which the company shared with Congress, showed net revenue of $2.09 billion, gross profit of $1.8 billion, and net income above $1.3 billion.⁵² In December 2021 the equity was sold for approximately $1.09 billion to a newly formed buyer entity owned by Scammell, with the 200-plus shareholders cashed out through an SRS Acquiom escrow; Womply reported $1.413 billion in cash on its balance sheet just before closing, and $630.72 million was set aside in a secondary escrow for claims tied to the PPP investigations; the corporation converted to Oto Analytics, LLC in the transaction.⁵³ Atlas Technology Group, which had worked on Womply's fundraising, later won a ~$27 million arbitration award over its transaction fee on the sale; whether it was paid from the SRS escrow has not been confirmed.⁵⁴ The FTC's 2024 order provides for payment of its $26 million judgment from funds defense counsel placed in escrow at signing, without identifying their source.⁵⁵

Womply's own PPP loans

Womply was also a PPP borrower: ~$5.1 million across two loans through Harvest, its largest partner, the second at $1,999,997 — three dollars under Treasury's announced audit threshold. Both were approved before Womply made money from PPP Fast Lane, which launched on February 23, 2021: the first on April 13, 2020, the second on February 7, 2021. In all of 2020 its PPP referrals had earned it just under $3 million in fees.¹¹¹⁹ Its core business sold software to small merchants, the same businesses whose sales its own data showed collapsing; the Fed's June 2020 Monetary Policy Report cited Womply data showing spending at small restaurants "down 80 percent (versus a year earlier) by early April."¹⁸ SBA denied forgiveness on both in September 2022 on eligibility grounds; Oto appealed, and SBA withdrew both decisions that December after Oto supplied the requested documents. The withdrawal established neither forgiveness nor repayment; SBA's September 2024 public loan file discloses no forgiveness for either loan.⁵⁶ The agency's own filings from those proceedings are among the documents Womply now publishes on The Record.⁵⁷ Scammell separately received forgiveness through his single-member Chasm LLC; Capoccia's own businesses received two PPP loans, one through Womply's platform.⁵⁸

The congressional report and the SBA suspension

On December 1, 2022, a month before the Select Subcommittee dissolved, Chairman Clyburn's staff published "We Are Not the Fraud Police": How Fintechs Facilitated Fraud in the Paycheck Protection Program, with Womply as Section III.C.⁵⁹ Its three lines of attack: the partner-lender fraud characterizations quoted above; a May 2022 privacy-policy notice permitting transfer of applicant data to Scammell and Capoccia's new venture, Solo Global;⁶⁰ and Scammell's past. In 2009, in his early twenties, Scammell had traded ahead of the Disney/Marvel merger; he pleaded guilty in 2014 and was sentenced to three months, and the SEC barred him from the securities industry, a bar it narrowed in 2019 to investment advisers alone.⁶¹⁶² The trading was more than 10 years old when the pandemic hit. The report made it the spine of the Womply chapter anyway, the only company section in the report built around a founder's personal history, and argued from 13 C.F.R. § 103.4(f) that SBA "may have" had grounds to remove Womply from the program. No agency ever adopted that theory; no tribunal ever examined it.

Seven days later, before anyone had tested anything, SBA suspended Womply and Blueacorn from working with the agency "in any capacity," said it "will be investigating appropriate action against their management, owners, and successor companies," and announced investigations of eight partner lenders. Cross River's Phil Goldfeder asked the agency, pointedly, to "differentiate between those who truly helped during the pandemic and those who didn't do enough."⁶³ What the suspension changed is unclear. PPP had stopped taking applications in May 2021; Womply had been sold that December and says it wound down its operations in 2022; and the SBA's own statement called it a non-lender that "worked with PPP lenders." Womply says it was never a party to any agreement with the SBA and received no payments from the government.⁶⁴ The report foregrounded the 2014 conviction while the contract accusations remained untested. Of the same report's other subjects, Blueacorn's founders were convicted of actual fraud — ten years each; Kabbage's estate settled a False Claims Act case for $120 million and DOJ intervened against its former executives. Womply, handed the same headlines, was never charged with anything.⁶⁵

Post-pandemic litigation (2021–2025)

Three of the seven Fast Lane lenders on Womply's network page — Fountainhead, Capital Plus and Benworth — withheld some or all of Womply's fees on loans the SBA had already paid them for: all of them at Capital Plus, the last ~14% at Benworth.²⁵

Fountainhead (2021–2022)

Womply terminated its Fountainhead agreement on May 26, 2021, citing breach; on June 15 it began a JAMS arbitration (No. 1100-111-808) claiming more than $90 million in unpaid fees, and it held back Fountainhead's loan files until paid.⁶⁶ On August 27, 2021, Fountainhead sued in Florida state court for the files; its CEO's affidavit conceded Fountainhead had "paid Womply greater than 80% of the amount Womply claims it is owed."⁶⁷ Womply says, citing the parties' October 19, 2021 joint motion (docket entry 22), that it delivered the files on a hard drive on October 7.⁵⁷

In November 2022, before the congressional report, Fountainhead dismissed its suit with prejudice. The report's staff described it as a TRO "so they can't destroy these [PPP loan] documents," but the 31-entry docket shows no injunction was ever entered: it was a loan-file turnover dispute under § 6.3 of the referral agreement, with an Order to Show Cause issued with "no merits determination."⁶⁸

Capital Plus (2021–2023)

On September 9, 2021, Womply sued Capital Plus in Dallas for $76.7 million in fees withheld on 86,521 funded loans, which had earned Capital Plus $186.9 million in SBA fees.⁶⁹ Capital Plus argued that the SBA's 1% agent-fee cap voided the contracts. Judge Boyle's May 11, 2022 order kept Womply's declaratory-judgment, tortious-interference, fraud and civil-conspiracy counts — the court "does not find the SBA regulation clearly precludes the collection of a Technology Fee" at the pleading stage — and dismissed five others with leave to amend. The illegality theory never reached a merits ruling: the parties settled on confidential terms, and the case was dismissed with prejudice on January 5, 2023.⁷⁰

Benworth (2021–2025)

On August 25, 2021, Womply filed a JAMS arbitration against Benworth. Benworth had paid $465.0 million of the $616.7 million Womply billed and withheld the other $151.7 million. The arbitrator applied the contract's lower 70% technology-fee tier, which put Womply's entitlement at $551.3 million, and found $86.3 million in referral, API and technology fees unpaid.⁷¹ It was the only one of the three disputes to reach a full hearing: seven days before Arbitrator Alexander L. Brainerd in March 2023. Ordered that February to produce its list of fraudulent loans or say whether it would pursue its promissory-fraud defense, Benworth dropped the defense. Benworth, which had produced documents to the Select Subcommittee for its report, moved to admit the report as evidence; the arbitrator ruled its content "rank hearsay." The corrected final award of June 26, 2024 gave Womply about $117.9 million — the $86.3 million in fees, $25.4 million in finance charges at 10% and $6.3 million in attorneys' fees and costs — and denied all of Benworth's counterclaims, including a ~$420 million illegality claim, except a non-monetary order to provide borrowers' loan files. It found that Womply "was not an LSP" and "was not performing underwriting services"; that without its technology Benworth could not "have successfully processed billions of dollars in PPP loan applications"; that Benworth's LSP argument was "a creative effort to raise a legal issue where no legal issue actually existed"; and that its claim to have received no benefit was "wholly disingenuous and a complete distortion of the evidence."⁵⁰⁴⁷ Collection moved to Puerto Rico, where Womply sued in January 2023 to unwind a transfer of about $171 million from Benworth to an affiliate owned by its founder, Bernardo Navarro, and his wife, Claudia. The Federal Reserve Bank of San Francisco intervened in July 2024 with its own suit, alleging that Benworth sent more than $50 million to the affiliate and paid Navarro at least $49 million in dividends. Womply and Benworth settled on terms not made public; both cases were dismissed with prejudice on January 2, 2025. The Reserve Bank's case settled on September 10, 2025.⁷²

FTC (2024)

On March 18, 2024, the Federal Trade Commission sued Womply and Scammell over Fast Lane's advertising and filed a negotiated settlement the same day. The complaint said Womply told small businesses they could "[g]et maximum PPP stimulus" of up to $41,000 through an application taking "as little as five minutes," reviewed within 24 hours, when more than 1.99 million of the 3.25 million applications consumers started, 61 percent, were never funded. It cited a document Scammell prepared for a lender showing where applications fell away — nearly a third could not be processed, more than a quarter of the rest were not sent to lenders, and almost a fifth of lender-approved files were rejected by the SBA. It also said that when Scammell was asked whether applicants who were seeking help by messaging a Fast Lane contractor's employees on LinkedIn should be referred to Womply's customer service, he replied, "You should ignore them." Its four counts, under the FTC Act and the COVID-19 Consumer Protection Act, concerned only advertising claims: the complaint does not use the word "fraud," challenge Womply's fees or address the lenders' part in the unfunded applications.⁷³ Womply says most unfunded applications were never completed or were declined by a lender or the SBA.⁷⁴ Womply and Scammell settled without admitting or denying the allegations; the April 3, 2024 order imposed a $26 million judgment, payable from funds held in escrow, a permanent injunction against misrepresenting financial products, and ten years of compliance reporting for the company and Scammell. The FTC announced it, fifteen months after the congressional report, with a separate $33 million Biz2Credit settlement as "Record $59 Million in Damages."⁵⁵

Outcomes

No criminal charges have been brought against the company, its founder or its president, and no court, arbitrator or agency adjudication has found fraud. Of the three lender disputes, Womply won the Benworth arbitration, Capital Plus settled after its motion to dismiss failed to end the case, and Fountainhead dropped its suit with prejudice. The FTC case, built on Womply's own documents and marketing, was settled for $26 million without admission.

The Blueacorn lawsuits on one timeline: Blueacorn in court, 2021–2026.

2026: five years on

Womply's small-business software products wound down after the program closed; no WARN notice or headcount disclosure exists in the public record.⁷⁵ Solo Global, Scammell and Capoccia's payments venture for the same self-employed audience (formed January 31, 2022), appears dormant — solo.co offline, no app-store listing.⁷⁶ The December 2022 SBA suspension was announced in a press release and has never been confirmed, modified or lifted by any published SBA decision; SAM.gov, the federal government's exclusions list, shows no active exclusion for Oto Analytics, Womply or Scammell.⁷⁷ Oto Analytics, LLC persists in litigation captions and in the FTC's ten-year compliance regime. womply.com has been relaunched as "The Record," the company's own account of these years. The site includes a page listing each legal matter by court and docket number, a Trustpilot review archive and a borrower-help page. It says Womply wound down in 2022 and has no active products or staff, and that its borrowers were charged with fraud at among the lowest rates of any major PPP lender, citing company records it says are withheld. Its loan totals (~1.4 million loans; $19.6 billion on the homepage, $21.15 billion on its "Impact" page) differ from each other and from the attribution here (~1.41 million loans, $24.2 billion net).⁵⁷

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Related profiles

• Toby Scammell — founder / CEO
• Cory Capoccia — President
• Solo Global — 2022 successor venture (same principals; not a subsidiary)
• Benworth — partner lender; JAMS counterparty
• Capital Plus / Crossroads — partner lender; N.D. Tex. counterparty
• Fountainhead — inaugural Fast Lane lender; Florida turnover suit
• Harvest Small Business Finance — largest 2021 partner; approved Womply's own PPP loans
• Lendistry — partner-adjacent lender in the mid-2021 email record
• Blueacorn — the report's other facilitator, with the opposite ending
• Sabrina Howell — the Journal of Finance access evidence
• William H. Orrick III — entered the FTC consent order
• OTO Analytics entity pointer — legal-entity names and captions
• Peek — travel and hospitality software company that announced a PPP partnership with Womply on April 9, 2020 and told its operators to apply "through our partner Womply."
• Dan Stevens — founder of Kickbox, the email-verification service that Womply's complaint against Benworth says its Technology Platform used.
• Wonderschool — announced a January 2021 partnership with Womply offering its directors support in completing PPP applications.
• Joe Ehrhardt — founder of Teslar Software (3E Software), whose system the N.D. Texas opinion in the Womply–Capital Plus litigation says Womply's lender-facing portal was built with.

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. 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) ↩
3. Womply, "Womply Launches PPP Fast Lane" (Feb. 23, 2021). ↩
4. 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: businesswire.com). 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. ↩
5. 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/). ↩
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. Crunchbase, "Venture Round - Womply" (Aug. 1, 2014; $20 million; leads Merus Capital and Streamlined; also Google Ventures, DCVC, Asset Management Ventures, Rising Tide and others), viewed Sept. 28, 2026: https://www.crunchbase.com/funding_round/womply-series-unknown--dbba519c; an earlier 2014 round (Jan. 1, 2014; lead Streamlined): https://www.crunchbase.com/funding_round/womply-series-unknown--b3f311bb; Merus Capital portfolio (Womply, "Acquired"): Merus Capital portfolio (Womply, "Acquired") (original: https://www.meruscap.com/portfolio). Crunchbase labels both 2014 rounds "Series Unknown." ↩
8. Sageview Capital, portfolio page "Womply" ("Date of Investment: November 2016"; "Exit Date: December 2021"; "Led Series B and participated in subsequent capital raise") — original: https://www.sageviewcapital.com/portfolio/womply/; womply.com homepage timeline ("A 2016 growth-equity round helped Womply expand to a second office in Utah and grow to hundreds of employees — part of about $50 million in equity the company raised from Seed to Series C"), Sept. 17, 2026. ↩
9. Trinity Capital Inc. (CIK 1786108), schedules of investments for Trinity Capital Fund III, L.P. and Trinity Capital Inc., Dec. 31, 2018 – Dec. 31, 2021 — Form 10 (Jan. 2020) — original: https://www.sec.gov/Archives/edgar/data/1786108/000110465920004792/tv534325_10-12g.htm; Form 10-K for 2020: Trinity Capital Inc., Form 10-K for the fiscal year ended December 31, 2020 (original: https://www.sec.gov/Archives/edgar/data/1786108/000155837021002383/tcpp-20201231x10k.htm); Form 10-Q for Mar. 31, 2021: Trinity Capital Inc., Form 10-Q for the quarter ended March 31, 2021 (original: https://www.sec.gov/Archives/edgar/data/1786108/000155837021006267/tcpp-20210331x10q.htm); Form 10-K for 2021: Trinity Capital Inc., Form 10-K for the fiscal year ended December 31, 2021 (original: https://www.sec.gov/Archives/edgar/data/1786108/000155837022002797/tcpp-20211231x10k.htm). Oto Analytics, Inc.: senior secured loan, fixed interest 11.5%, end-of-term payment 6.0%, maturity Mar. 1, 2023, principal $10.0 million through Mar. 31, 2020 and $7.294 million at Dec. 31, 2020, not listed at Mar. 31, 2021; warrant for 1,018,718 Series B preferred shares at $0.79, expiring Aug. 31, 2028, not listed at Dec. 31, 2021. ↩
10. SEC EDGAR company search, Sept. 28, 2026: no filer named "Oto Analytics" or "Womply" — no registration statement, periodic report or Form D notice: https://www.sec.gov/cgi-bin/browse-edgar?company=oto+analytics&action=getcompany. ↩
11. 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. ↩
12. Womply, "Womply Launches PPP Fast Lane…" (Business Wire, Feb. 23, 2021), boilerplate: Womply helps "make local commerce happen for over 500,000 American businesses" — original: https://www.businesswire.com/news/home/20210223005805/en/Womply-Launches-PPP-Fast-Lane-to-Help-Under-Served-Businesses-Access-the-Paycheck-Protection-Program-PPP GlobeNewswire, "Fountainhead Partners with Womply" Feb. 23, 2021 and BusinessWire, "Womply Launches PPP Fast Lane" Fe... (stored capture); Crunchbase, "Toby Scammell" ("approximately 500,000 software customers"): Crunchbase, Toby Scammell person profile (Internet Archive copy of Oct. 10, 2024) (original: https://www.crunchbase.com/person/toby-scammell). ↩
13. 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. ↩
14. Partner announcements reproduced on Womply's press page, Internet Archive copies: Calpian Commerce (SecurePay Insights), May 7, 2014 — original: https://web.archive.org/web/20190917225757/https://www.womply.com/press/calpian-commerce-launches-securepay-insights-merchant-analytics-platform-powered-womply/; Net Element / Unified Payments, May 7, 2014: Net Element and Womply Partner to Offer Merchants an Analytical Toolbox (original: web.archive.org); Anovia Payments, Sept. 23, 2014: Anovia and Womply Partner to offer Insights, the Industry-Leading Analytics, Benchmarking and Competitive Intelligence Solution, to Merchants (original: web.archive.org); Wind River Financial, Apr. 15, 2015: Wind River Financial (WRF) and Womply Partner to Offer Wind River Insights (original: https://web.archive.org/web/20160719134357/http://www.womply.com/press-12/2016/4/19/wind-river-financial-wrf-and-womply-partner-to-offer-wind-river-insights); UMS Banking, May 3, 2015: UMS Banking and Womply Partner to Offer UMS Insights (original: https://web.archive.org/web/20160719134807/http://www.womply.com/press-12/2016/4/19/ums-banking-and-womply-partner-to-offer-ums-insights); Electronic Merchant Systems, July 11, 2015: Electronic Merchant Systems Partners with Womply to Offer EMS Insights (original: https://web.archive.org/web/20160719134540/http://www.womply.com/press-12/2016/4/19/electronic-merchant-systems-partners-with-womply-to-offer-ems-insights); SignaPay, July 21, 2015: SignaPay Partners with Womply to Offer SignaPay Insights (original: https://web.archive.org/web/20160719133625/http://www.womply.com/press-12/2016/4/19/signapay-partners-with-womply-to-offer-signapay-insights); Eliot Management Group, July 24, 2015: Eliot Partners with Womply to Offer "Eliot Insights" for Merchants (original: web.archive.org); Axia Payments, Aug. 25, 2015: Axia Payments Partners with Womply to Offer Axia Insights (original: https://web.archive.org/web/20160719133935/http://www.womply.com/press-12/2016/4/19/axia-payments-partners-with-womply-to-offer-axia-insights); First American Payment Systems, Sept. 2, 2015: First American Payment Systems Partners with Womply to Offer Merchants 1stPayInsights (original: https://web.archive.org/web/20160719134700/http://www.womply.com/press-12/2016/4/19/first-american-payment-systems-partners-with-womply-to-offer-merchants-1stpayinsights); US Merchant Systems (undated): US Merchant Systems and Womply Partner to Offer USMS Insights (original: web.archive.org); Merchants' Choice Payment Solutions (undated): Merchants' Choice Payment Solutions (MCPS) and Womply Partner to Offer Foundry Business Insights (original: web.archive.org); North American Bancard, Apr. 4, 2016: North American Bancard Partners with Womply to Offer Insights (original: https://web.archive.org/web/20190716100448/https://www.womply.com/press/north-american-bancard-partners-womply-offer-insights/); iPayment, Apr. 6, 2016: iPayment, Inc. Announces Partnership with Womply (original: https://web.archive.org/web/20190821185538/https://www.womply.com/press/ipayment-inc-announces-partnership-womply/); Moneris Solutions, Apr. 19, 2016: Moneris Partners with Womply to Offer Business Analytics Solution to Merchants (original: web.archive.org); Atlantic Pacific Processing Systems, June 23, 2016: Atlantic Pacific Processing Systems Partners with Womply to Offer Insights (original: https://web.archive.org/web/20160719133416/http://www.womply.com/press-12/2016/6/28/atlantic-pacific-processing-systems-partners-with-womply-to-offer-insights); Payscape, May 1, 2017: Payscape Partners With Womply to Bring the Power and Efficiency of Big Data to SMBs (original: https://web.archive.org/web/20190917224141/https://www.womply.com/press/payscape-partners-womply-bring-power-efficiency-big-data-smbs/); Total Merchant Services (Groovv Insights), May 22, 2017: Total Merchant Services Partners with Womply to Offer Groovv Insights (original: https://web.archive.org/web/20170604151503/http://womply.com/press-12/2017/5/22/total-merchant-services-partners-with-womply-to-offer-groovv-insights); Integrity Payment Systems, June 5, 2017: Integrity Payment Systems Partners With Womply to Empower Merchants With Big Data and Analytics Platform (original: https://web.archive.org/web/20190720141951/https://www.womply.com/press/integrity-payment-systems-partners-womply-empower-merchants-big-data-analytics-platform/); Titanium Payments, May 22, 2018: Titanium Payments Partners With Womply to Arm Merchants With Technology to Attract, Retain, and Engage More Customers (Business Wire) (original: https://web.archive.org/web/20191014151803/https://www.womply.com/press/titanium-payments-partners-with-womply-to-arm-merchants-with-technology-to-attract-retain-and-engage-more-customers-press-release/); National Merchants Association, Sept. 6, 2018: National Merchants Association Partners With Womply to Help Merchants Attract, Retain, and Engage Customers With Technology (original: web.archive.org); Elavon, Feb. 13, 2019: Womply Partners With Elavon to Help Small Businesses Transform Customer Acquisition, Retention and Engagement (BUSINESS WIRE) (original: https://web.archive.org/web/20190720135613/https://www.womply.com/press/womply-partners-with-elavon-to-help-small-businesses-transform-customer-acquisition-retention-and-engagement/). The earlier examples (TSYS, Vantiv, Celero) and the "50+" figure are in the note above. ↩
15. 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. ↩
16. 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. ↩
17. "In Houston, small business revenue was back on track a week after Harvey," Marketplace (Oct. 4, 2017) — original: https://www.marketplace.org/2017/10/04/business/houston-small-business-revenue-was-back-track-week-after-harvey; Zlati Meyer, "Why some small restaurants hate Valentine's Day," USA Today (Feb. 14, 2018): Zlati Meyer, "Why some small restaurants hate Valentine's Day," USA Today (Feb. 14, 2018) (original: https://www.usatoday.com/story/money/2018/02/14/why-some-small-restaurants-hate-valentines-day/319611002/); Kate Krader, "Valentine's Day Is Not as Good for Restaurants as You'd Think," Bloomberg (Feb. 12, 2020): Kate Krader, "Valentine's Day Is Not as Good for Restaurants as You'd Think," Bloomberg (Feb. 12, 2020) (original: https://www.bloomberg.com/news/articles/2020-02-12/valentine-s-day-is-not-as-good-for-restaurants-as-you-d-think); Kate Gibson, "Do restaurants get less love on Valentine's Day than one might think?," CBS News (Feb. 14, 2020): Kate Gibson, "Do restaurants get less love on Valentine's Day than one might think?," CBS News (Feb. 14, 2020) (original: https://www.cbsnews.com/news/valentines-day-restaurants-less-love-business/); Ann Schmidt, "The top days for local restaurant sales: Report," Fox Business (Feb. 13, 2020): Ann Schmidt, "The top days for local restaurant sales: Report," Fox Business (Feb. 13, 2020) (original: https://www.foxbusiness.com/lifestyle/top-days-local-restaurant-sales). ↩
18. 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). ↩
19. Subcommittee ¶¶ 397–398 (ten referral agreements; ~7,000 loans; ~$360M; just under $3M in 2020 fees). ↩
20. PPP-referral processor partnerships (April 2020) — Clearent/Xplor Pay (Apr. 17, 2020) — original: https://xplorpay.com/insights/clearent-partners-with-womply/; Fattmerchant/Stax (Apr. 22, 2020, GlobeNewswire): Fattmerchant and Womply Partner to Help Small Businesses Streamline Paycheck Protection Program Applications (original: https://www.globenewswire.com/news-release/2020/04/22/2020109/0/en/Fattmerchant-and-Womply-Partner-to-Help-Small-Businesses-Streamline-Paycheck-Protection-Program-Applications.html); Electronic Merchant Systems (Apr. 24, 2020, PR Newswire): Electronic Merchant Systems Partners with Womply to Help SMBs Find PPP Lenders (original: https://www.prnewswire.com/news-releases/electronic-merchant-systems-partners-with-womply-to-help-smbs-find-ppp-lenders-301046440.html). ↩
21. OTO Analytics complaint, Oto Analytics, LLC v. Benworth Capital Partners PR LLC, D.P.R. 3:23-cv-01034, ¶ 72. ↩
22. 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). ↩
23. SBA, "Business Loan Program Temporary Changes; Paycheck Protection Program—Revisions to Loan Amount Calculation and Eligibility" (interim final rule), 86 Fed. Reg. 13149, 13151 (Mar. 8, 2021) — original: https://www.govinfo.gov/content/pkg/FR-2021-03-08/html/2021-04795.htm; SBA Office of Inspector General, "SBA's Oversight of Non-Bank Lenders and Third-Party Service Providers Associated with PPP Loans," Report 25-04 (Nov. 13, 2024). ↩
24. BusinessWire, "Womply Passes 250,000 Small Businesses Served" (Feb. 3, 2021) — 100,000 loans in 2020 at $59,000 average; 150,000 in 2021 at $22,000. ↩
25. Partnership releases: Benworth (Mar. 10, 2021); Harvest (Apr. 20, 2021); published lender network page, Internet Archive copies Apr. 17 and Aug. 5, 2021. ↩
26. 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. ↩
27. JAMS Corrected Final Award — the Womply-paid vendor stack (Twilio, Persona, Plaid, Ocrolus, Inscribe, Mindee) and the per-funded-loan API/Technology fees. Lender side: Ready Capital Q2 2021 earnings call ("The upfront costs to produce the PPP loans are embedded in that discount … there'll be some ancillary variable costs related to forgiveness processing … but pretty minimal"). ↩
28. womply.com pages "PPP fraud controls," "PPP KYC process," "Government cooperation" and "Government data sharing" (last modified Sept. 6, 2026), homepage source notes 2–27, and the one-page "Government investigation support" PDF (June 2026), as of Sept. 17, 2026 (womply-com_ppp-fraud-controls, womply-com_ppp-kyc-process, womply-com_government-cooperation, womply-com_government-data-sharing, womply-com_index-source-notes) and Womply Government Investigation Support; the June 27, 2026 copies, including the fuller data-sharing page. Quoted wording checked against the live pages on Sept. 27, 2026. Each source note describes the underlying correspondence as withheld. ↩
29. United States ex rel. Quesenberry v. SPE MB Atlantic Palms LLC, N.D. Ga. 1:25-cv-00337 (filed Jan. 24, 2025; stayed Jan. 14, 2026), Doc. 31, Ex. A (subpoena to Harvest Small Business Finance) and Doc. 42 (revised Harvest subpoena). ↩
30. Subcommittee ¶¶ 403–408 (3.7M submitted; 2.58M referred; ~1.3M funded; March/April/weekly figures); ¶ 401 (five Fast Lane lenders issued over one million loans totaling more than $16 billion in 2021). ↩
31. 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). ↩
32. (named-platform gig loans 40,461 → 409,313; the March 2021 gross-income IFR as the enabling change). ↩
33. Howell, Kuchler, Snitkof, Stroebel & Wong, "Lender Automation and Racial Disparities in Credit Access," Journal of Finance 79:2 (2024): Jofi 13303 Chrome (original: onlinelibrary.wiley.com). ↩
34. 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/. Analyst briefings: Citi Research "FinTech Spotlight Series: Womply" (Mar. 20, 2020; Part II May 1, 2020); Deutsche Bank payments expert call (Apr. 5, 2020); Wells Fargo "Trends in Small Business" (Apr. 13, 2020). ↩
35. Womply, "The Economic Apocalypse" / Stimulus2020 deck (March 2020, 16 slides): source document. ↩
36. Coalition "Letter to Congress" (Mar. 24, 2020), verbatim text, alphabetical signature block, and provenance/organizer notes. Hosted at ondeck.com/press-releases/congress-letter and womply.com/press/letter-to-congress/. ↩
37. CARES Act, Pub. L. 116-136 (signed Mar. 27, 2020), § 1102 (authorizing additional lenders for PPP). ↩
38. 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. ↩
39. 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/). ↩
40. Catherine Quagliana Parker, "Womply's PPP Fast Lane Helps Self-Employed Apply for COVID-19 Loans," YPO (Mar. 4, 2021) — original: https://www.ypo.org/2021/03/womplys-ppp-fast-lane-helps-self-employed-apply-for-covid-19-loans/. ↩
41. 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). ↩
42. 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/. ↩
43. 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. ↩
44. 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"). ↩
45. Subcommittee ¶¶ 454–455. ↩
46. Oto Analytics, Inc. d/b/a Womply, Response to Certain Requests for Information in the House Select Subcommittee on the Coronavirus Crisis' Document and Information Request Letter dated November 22, 2021 and Follow-Up Requests dated January 31, 2022 and April 8, 2022 (Apr. 14, 2022), "Response to Follow Up to Information Request Nos. 5 and 7" ("Anti-Fraud Measures"; "KYC Process"; the document calls itself a preliminary response), enclosed with the letter of Womply's counsel Zeh S. Ekono (Willkie Farr & Gallagher LLP) to Chairman Clyburn of the same date; in the Select Subcommittee's Dec. 1, 2022 Womply document release. ↩
47. Womply emails to Benworth of April 8, 2021 ("Fraud deterrence"; BWSSCCResp0000045–46) and early May 2021 (manual review, the SBA list, bank freeze instructions; BWSSCCResp0000039–41), with the reply from Benworth's CEO of May 7, 2021, in Benworth's production to the Select Subcommittee, part of its Dec. 1, 2022 Womply document release; Subcommittee ¶¶ 443–446. ↩
48. Subcommittee ¶¶ 422–449 (DreamSpring emails, Mar. 20–Apr. 13, 2021; Benworth CEO emails, May 7 and 10, 2021; Lendistry email, June 8, 2021; Fountainhead "duct tape and gum" staff interview). ↩
49. womply.com, "What Womply Told the SBA & FBI: May 2021 Fraud-Prevention Memo" (original title "Steps to reduce fraud"; the site says names of vendors and a country list are replaced by bracketed descriptions and that no recommendation was added, removed or altered); Sept. 17, 2026 copy. ↩
50. JAMS No. 1210038203, hearing Mar. 20–28, 2023; Interim Award Dec. 21, 2023; Final Award May 30, 2024; Corrected Final Award June 26, 2024 (components: $86,299,892 fees + $25,363,697.68 finance charges as of May 30, 2024 + $5,883,708.58 attorneys' fees + $372,956.46 costs = $117,920,254.72; the May 30, 2024 Final Award carried $25,387,670.50 in finance charges as of May 31, 2024, which is the figure that yields the $117,944,228 total stated by Womply's counsel and on womply.com; counterclaims denied except Counterclaim I(iv), a file-access item, which was granted; the promissory-fraud affirmative defense was voluntarily dismissed after a February 6, 2023 production order; "wholly disingenuous and a complete distortion of the evidence" refers to Benworth's no-benefit argument, ¶ 87). ↩
51. Subcommittee ¶¶ 467–489 (data-request correspondence; Scammell June 10, 2021 reply; SBA June 11, 2021 letter citing 13 C.F.R. part 103). ↩
52. 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. ↩
53. 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. ↩
54. 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. ↩
55. FTC v. OTO Analytics, Inc. and Toby Scammell, N.D. Cal. 3:24-cv-01661-WHO — complaint (Doc. 1, Mar. 18, 2024) and entered stipulated order (Doc. 10, Apr. 3, 2024); FTC press release (Mar. 18, 2024): FTC Actions on Deceptive Pandemic Loan Promises: $59 Million (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; case page: FTC, Womply, FTC v. case page (original: ftc.gov · stored capture). FTC-hosted complaint and signed order archived on 2026-09-17: Complaint — FTC v. Oto Analytics (N.D. Cal.), Stipulated Order — FTC v. Oto Analytics (N.D. Cal.) (the order: judgment $26,000,000 payable within 7 days from funds counsel held in escrow; "neither admit nor deny"; 10-year compliance reporting; signed April 3, 2024). ↩
56. 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). ↩
57. 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. ↩
58. Subcommittee ¶¶ 507–525 (the two OTO loans via Harvest incl. the $1,999,997 loan; Sept. 1, 2022 forgiveness denials; Chasm LLC; Capoccia's personal loans). ↩
59. 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 ↩
60. Subcommittee ¶ 531 (May 2022 privacy-policy notice); Solo Global, Inc., Delaware file 6583768, formed Jan. 31, 2022, per the state-registry pull cited there. ↩
61. 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); Subcommittee ¶¶ 453–466 (the § 103.4(f) argument). ↩
62. SEC Admin. Proc. File No. 3-15271: Opinion of the Commission, Advisers Act Release No. 3961 (Oct. 29, 2014), barring him from association with any broker, dealer, investment adviser, municipal securities dealer, municipal advisor, transfer agent or NRSRO: https://www.sec.gov/files/litigation/opinions/2014/ia-3961.pdf; Order Vacating Broker, Dealer, Municipal Securities Dealer, Municipal Advisor, Transfer Agent, and Nationally Recognized Statistical Rating Organization Bars, Advisers Act Release No. 5272 (July 2, 2019), because they rested on conduct before July 22, 2010 (citing Bartko v. SEC, 845 F.3d 1217 (D.C. Cir. 2017)): https://www.sec.gov/files/litigation/opinions/2019/ia-5272.pdf; docket: https://www.sec.gov/enforcement-litigation/administrative-proceedings/3-15271. ↩
63. 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)). ↩
64. SBA statement, Dec. 8, 2022 ("The SBA has immediately suspended non-lenders Blueacorn and Womply, companies that worked with PPP lenders"), as quoted on Womply's case-record page; the same page: Womply "was not a party to any agreement with the SBA; and it received no payments from the government": The legal record: Womply's litigation and enforcement matters. The wind-down: womply.com, as in the anti-fraud notes above. ↩
65. Blueacorn: convictions and ten-year sentences of Stephanie Hockridge (jury verdict June 20, 2025; sentenced Nov. 21, 2025; restitution over $63 million) and Nathan Reis (guilty plea Aug. 2025; sentenced Dec. 18, 2025; restitution over $66 million): Stephanie Hockridge Sentenced for $63M COVID-19 Relief Fraud, Nathan Reis Sentenced for $65M COVID-19 Relief Fraud Scheme, and the case records cited there. Kabbage/KServicing: $120M FCA settlement (May 2024) and DOJ intervention against former executives (Dec. 2024). ↩
66. 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). ↩
67. Hurn affidavit (Sept. 7, 2021), Fountainhead v. OTO Analytics: "paid Womply greater than 80% of the amount Womply claims it is owed." ↩
68. 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. ↩
69. Oto Analytics, Inc. v. Capital Plus Financial, LLC, N.D. Tex. 3:21-cv-02636-B (filed Dallas County Sept. 9, 2021; removed Oct. 25, 2021); $76.7M / 86,521 loans / $186,882,948 in SBA fees per the Bloom declaration, Doc. 46-1. ↩
70. 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). ↩
71. 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. ↩
72. 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. ↩
73. 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.)). ↩
74. womply.com, "The FTC settlement" ("applications stopped because the applicant didn't finish, didn't pass identity and anti-fraud checks, or were declined by a lender or the SBA"), as of Sept. 17, 2026. ↩
75. Layoff record: How 41 Companies Handled Pandemic Layoffs: Womply. ↩
76. solo.co offline (SSL error, checked June 2026); no current App Store / Google Play listing: Profile: Solo Global, Inc. ↩
77. 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. ↩

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Consolidated profile covering both the Womply brand and the OTO Analytics / Oto Analytics legal entity. Rewritten 2026-07-04; source-checked against womply.com and the case documents on 2026-09-17.