The documented record
Womply helped millions of American businesses survive the pandemic.
Womply spent a decade building software for hundreds of thousands of Main Street businesses. In 2021 it brought that technology to the Paycheck Protection Program, helping sole proprietors and 1099 workers apply, then handing the credit decision to its lender partners. What follows is the record: the numbers, and the documents behind them.
The record, in full
Who Womply served.
A decade of building, and one extraordinary year of relief, measured across everyone Womply touched.
A decade of customer software built for Main Street.
About 500,000 businesses used Womply's CRM, marketing, and reputation software in the decade before the pandemic, across 400-plus industries and nearly every ZIP code in America, giving the corner restaurant, the neighborhood salon, and the family retailer tools only big chains could afford.
The smallest businesses and underserved communities big banks turned away.
In 2021 Womply's technology helped process roughly 1.4 million PPP loans, averaging about $14,000, for sole proprietors and 1099 workers larger lenders would not serve. Fintech reached the minority-owned and underserved businesses traditional banks missed: it made just 17.4% of PPP loans overall, yet delivered 53.6% of all loans to Black-owned businesses.
The SBA-approved lenders who built on Womply's technology.
Womply was the technology layer, never the lender. Its Fast Lane software let SBA-approved lenders reach the sole proprietors and 1099 workers most banks would not serve, and in every case the lender, not Womply, underwrote, approved, and funded the loan. Partners included Harvest Small Business Finance, the nation's #1 PPP lender by loan count in 2021, and Lendistry, a minority-led Community Development Financial Institution built for these borrowers.
Fraud stopped at the door — and the records to prosecute the rest.
Before any application reached a lender, Womply screened out more than 1.1 million suspicious or ineligible ones — before taxpayer money could fund them. From 2021 to 2024 it gave 48 federal, state, and local agencies data on roughly 1.5 million applications across 370-plus productions, and proactively reported fraud, helping freeze about $6.3 million in fraudulent funds.
A team across the country, working day and night.
Womply grew to hundreds of employees, and when the 2020 lockdowns hit it repurposed its team toward relief rather than cutting staff. Across the country they worked day and night through 2021, building the technology, answering applicants, and chasing down fraud, all to get sole proprietors and the smallest businesses the relief they were owed. Many held equity that shared in the company's 2021 sale.
An exceptional return — on ~$50m in equity raised.
Womply raised about $50 million in equity across Seed, Series A, B, and C. In 2021 it returned $1.1 billion to shareholders in cash — more than 20 times the equity invested, a win for all shareholders.
Before PPP
A decade building software for Main Street.
Founded in 2011, Womply spent a decade building software for the smallest businesses in America. When the pandemic shut them down in 2020, it turned that same network toward relief.
- 2011
A company built for Main Street. Toby Scammell founded Womply (legally Oto Analytics, Inc.) in San Francisco to give the corner restaurant, the neighborhood salon, and the family retailer the customer software only big chains could afford.
- 2012+
The data engine. Womply signed more than thirty exclusive partnerships with credit-card processors and became the top software partner to the U.S. payments industry, analyzing millions of merchant transactions a day.
- 2014
A "front office" for owners with no IT department. That transaction data powered a self-populating CRM, plus online-reputation management, marketing automation, and analytics.
- 2016
Growth capital. 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.
- 2017–2019
Main Street at national scale. Womply served about 500,000 small businesses across 400-plus industries and nearly every ZIP code in America.
- Early 2020
The lockdowns, and a one-third revenue hit. When COVID-19 closed Main Street, it closed Womply's customers. By its own accounting, core software revenue fell more than 30% almost overnight.
- 2020
Relief, not layoffs. Rather than cut staff like much of the industry, Womply repurposed its team to help small businesses survive — pointing owners to SBA lenders and EIDL and PPP support.
- Feb 2021
Building Fast Lane as other tech companies pulled back. As other major technology companies stepped back from PPP, Womply launched PPP Fast Lane to reach sole proprietors and 1099 workers, handing the credit decision to its lender partners. The gross-income rule that followed in March 2021 made those loans far more valuable to the businesses Womply already served.
Womply & the government
Womply and the government during the PPP.
Womply worked hand in hand with the federal government to save America’s smallest businesses and combat fraud.1 It was a technology company, not a lender: it never underwrote, approved, or funded a loan. Under its contracts and the program's rules, that responsibility rested with SBA-approved lenders. Beyond the third-party identity and document checks built into its application flow,2 it coordinated with the SBA on program rules, engaged the Federal Reserve and Treasury on getting funds to the smallest borrowers, reported fraud to the SBA, its Inspector General, the FBI, and DHS, and supported federal law-enforcement investigations, including those of the DOJ, Federal Reserve, and others.345 The dated record is below.
Womply required every applicant to clear identity verification through Persona — SSN, date of birth, name, and address, plus a government ID matched against a live video selfie. Womply staff manually reviewed flagged selfies.
Womply verified each applicant's bank account through Plaid, alongside email and phone verification.
Womply ran real-time tax-document validation, flagging applications where the name and EIN checked out but the financial figures appeared falsified.
Womply could stop or invalidate the ACH transfer before disbursement, and ask the receiving bank to freeze funds when fraud surfaced late.
- Jan 2021
The PPP reopened, and Womply coordinated with the SBA. After lapsing in 2020, the PPP reopened in January 2021 under Congress's late-December reauthorization — the SBA began accepting First and Second Draw applications from community financial institutions on January 11 and all lenders on January 19. Womply coordinated directly with SBA senior leadership on second-draw rules and operations, and co-hosted education sessions where SBA leaders answered borrower questions on Womply-hosted livestreams.67
- Feb 2021
Flagged tax-document fraud to the SBA. Womply alerted the SBA that small-borrower tax-document discrepancies were a likely source of fraud, and urged verifying self-certified income against IRS records.89
- Mar 2021
Proposed identity screening and reported the first organized fraud ring. In a working session with the SBA, Womply proposed screening applicant data against identity databases to detect identity fraud. It also reported the first coordinated fraud ring it had identified (applications that each passed the rules alone but together revealed organized fraud) and pressed the SBA to cross-check applicant tax data against IRS records.1011
- Apr 2021
Engaged the Federal Reserve and Treasury, warned applicants, and delivered the first fraud files. Womply raised operational constraints keeping funds from the smallest borrowers: how the SBA's loan-cancellation window interacted with the Federal Reserve's PPP Liquidity Facility, and daily ACH limits at small lenders.12 From late April it posted formal notices that attempted PPP fraud was rising, that falsified tax documents would be "easy to catch" if the government used IRS data, and that Womply was cooperating with federal law enforcement and would deny or cancel fraudulent applications.13 On April 30 it sent the SBA, its Inspector General, and DHS a file of roughly 5,000 fraudulent applications tied to organized rings, described as "the first of many such files," and opened a working relationship with the FBI on PPP fraud.14151617
- May 2021
Flagged thousands more, helped freeze funds, and briefed the SBA. Womply reported the pattern of organized exploitation it had observed and gave the SBA a list of 13,798 loans tied to compromised identities, to block those identifiers from reuse across COVID-relief programs.181920 Working with receiving banks, it helped freeze more than $6 million in suspected-fraud disbursements, filed a formal complaint with the SBA's Office of Inspector General, and ran additional fraud analyses at the government's request.212223 On May 12 it walked senior SBA officials through how it detects and routes fraud and made recommendations on how to stop fraud across other relief programs.24
- Jun 2021
Recommended program-wide safeguards. Womply again proposed requiring an IRS Form 4506-T (this time from every loan recipient prior to forgiveness) and offered a direct channel for transmitting suspected-fraud data to the SBA and its Inspector General.252627
Across these months Womply flagged fraud rings, helped freeze funds, and repeatedly pressed for the one safeguard it could not impose itself — verifying self-certified income against IRS records. Without that check, a well-made fake and a real document can look identical.
The record
What the documents show.
Much has been written about Womply's role in the PPP. Here is what the primary sources show: court rulings, the arbitration award, the SBA's own data, and Womply's production files.
No company stopped more PPP fraud at the front door than Womply.
More than 1.1 million applications were screened out before they ever reached a lender.
No court, and no government agency, has ever found Womply liable for PPP fraud.
The "facilitating fraud" accusations came from only two places: a 2022 congressional staff report and a single lender's fee dispute. An arbitrator who weighed the full record excluded the report as "rank hearsay," and the lender withdrew its fraud claim (never argued) once it was ordered to produce the loans it had blamed on Womply's technology. No federal agency ever charged Womply with PPP fraud, and on the underlying fee question Womply prevailed in both arbitration and federal court.28
JAMS arbitration award →The lenders made every credit decision.
Womply built the application and screening technology; its lender partners underwrote, approved, funded, and submitted every loan to the SBA. The arbitrator found the lender, not Womply, was the underwriter of record — and Womply's contracts said so all along, stating it "is not a lender or lender service provider" and placing underwriting and good-faith review on the lender.
Arbitration award →Every applicant had to clear multi-vendor identity verification before an application reached a lender.
Womply layered multiple best-in-class identity vendors with OFAC screening, a live selfie matched to a government ID, and a manual human-review team checking for deepfakes. Its identity stack included Persona and DocuSign Knowledge Based Answers (KBA), powered by LexisNexis. No KYC system is perfect, but Womply’s requirements always exceeded PPP rules and it invested heavily as bad actors relentlessly attacked the program.
How Womply screened for fraud →Womply's borrowers were charged with fraud at among the lowest rates of any major PPP lender.
Of the roughly 1.4 million loans Womply's technology helped process, only a small fraction have been tied to a federal fraud case. Measured against SBA loan-origination data, that is among the lowest prosecutions-per-loan of any major PPP originator.
DOJ fraud-prosecution data → SBA PPP loan data →An arbitrator upheld Womply's fees and awarded it $117.9 million.
The fees were private technology contracts with its lenders. When one lender tried to claw back roughly $420 million by calling them illegal "agent" fees, the arbitrator rejected the theory and awarded Womply $117,944,228.
The $117.9M award → Full page: the $117.9M arbitration →The FTC's 2024 action was about marketing, not fraud.
It concerned how Womply advertised speed and the likelihood of funding for "PPP Fast Lane." Womply and its CEO settled for $26 million with no admission of wrongdoing, no finding that Womply facilitated loan fraud, and no criminal referral.
Full page: the FTC settlement →Federal courts treated Womply's records as reliable evidence.
Prosecutors in more than ten districts introduced Womply's records as certified business records, authenticated alongside the SBA and major banks, and no defense challenged their reliability. In one trial, the login and upload logs disproved a defendant's sworn testimony that he "didn't fill out anything."
PPP prosecutions →Womply gave investigators data on roughly 1.5 million applications.
From 2021 to 2024 it answered legal process from at least 48 federal, state, and local agencies, including the FBI, DOJ, IRS, Secret Service, Homeland Security, and the SBA Inspector General, in more than 370 productions of court-admissible records. In one export on May 5, 2021, it proactively gave DHS 2.9 million identity and IP records covering about 1.47 million applications, to help investigators identify and stop further fraud.
Government data-sharing fact sheet →Womply was a technology provider to lenders — it never worked for the SBA, contracted with the government, or was paid by the government.
Its customers were its lender partners, not the SBA, and it was never paid a dollar by the government. PPP processing fees were paid by the SBA to the lenders; Womply was paid by those lenders under private technology, API, and referral contracts. When lenders refused to pay, Womply sued the lenders, not the government — and won in multiple cases, including a $117.9 million arbitration award and a federal-court ruling that upheld its fees.
The $117.9M award →Womply was a software company providing vital technology, not an SBA lender.
Womply built the technology that let small lenders process PPP applications at scale; it never underwrote, approved, funded, or submitted a loan. A federal court and an arbitrator both found that "Womply is not a lender or lender service provider," and it had no contract or agency relationship with the SBA — though the SBA barred it "from working with the SBA" in December 2022.
Arbitration award →When the SBA denied forgiveness on Womply's own loans, Womply appealed — and the SBA withdrew the denial.
The decisions turned on documentation, not fraud. Womply appealed both loans to the SBA's Office of Hearings and Appeals. On December 16, 2022 the SBA withdrew them and the appeals were dismissed; a sworn SBA declaration states it did so because Womply “provided SBA with all documents requested to determine eligibility.” Womply stands by the loans.
SBA appeal filings — loan #4959988403 → SBA appeal filings — loan #5187557106 →The documents
The record is public. Read the details for yourself.
Every number and quote on this page traces to a primary source: federal court filings, the SBA's own loan data, the arbitration award, and Womply's production files.
How to read this record
The SBA made race and ethnicity optional, so they are blank on roughly 80% of all PPP loans (Center for Public Integrity); every demographic figure here reports its coverage rate or uses geography instead. Independent research on fintech and minority access is in NBER w29364 (Journal of Finance). Government data-sharing figures are counted from Womply's own production files and reported in aggregate only, to respect grand-jury secrecy (Fed. R. Crim. P. 6(e)) and borrower privacy. Court documents are identified by case name, court, and docket number so they can be pulled from the public record.
Sourcing
Notes on the government record.
Each note above corresponds to a distinct, dated communication with a federal agency, a public notice, or a public decision. Names, titles, and addresses are omitted; privileged legal advice, applicant personal data, and law-enforcement-sensitive specifics are withheld.
Show the 28 source notes
- Draws on Womply's contemporaneous 2020–2021 correspondence with federal agencies, its public applicant notices, and the public litigation record. No confidential content is reproduced; applicant personal data, privileged legal advice, and law-enforcement-sensitive specifics are withheld throughout. ↩
- Womply's platform relied on established third-party identity- and bank-account-verification services, including a government-ID-plus-video-selfie check that, as Womply advised the government, went beyond what most program participants required. ↩
- Cooperation with a federal grand-jury subpoena in 2020, the program's first year. Specifics are law-enforcement-sensitive and withheld. ↩
- A dedicated law-enforcement intake channel and responses to federal subpoenas and information requests in 2021 (including grand-jury subpoenas and DOJ inquiries, with an initial production to the DOJ in late 2021), coordinated with specialized outside counsel. Specifics are law-enforcement-sensitive and withheld. ↩
- Cooperation with later Federal Reserve inquiries (2022–2023), in which the requesting investigator confirmed Womply was not the subject of the investigation. Specifics are law-enforcement-sensitive and withheld. ↩
- January 2021 communications with the SBA on second-draw rules and operations (including treatment of first-draw loan numbers and unused first-draw funds), which the SBA confirmed it was routing to its policy teams. ↩
- Joint education sessions in January 2021 in which SBA leadership answered borrower PPP questions on Womply-hosted livestreams. ↩
- Communication with the SBA, February 2021, that small-borrower tax-document problems were a likely source of document fraud, urging the SBA to verify income directly against IRS records (accepting IRS transcripts in place of applicant-supplied paper 1040/Schedule C forms) rather than rely on self-reported tax documents. ↩
- Further February 2021 correspondence with the SBA analyzing program data and access for the smallest borrowers. ↩
- A working session and communications with the SBA in early March 2021 proposing applicant data be screened against identity databases to detect identity fraud. ↩
- Correspondence with the SBA, mid-March 2021, reporting the first organized fraud ring Womply had detected and proposing applicant tax documents be cross-checked against IRS data. ↩
- An April 2021 discussion with a Federal Reserve contact (who also held a Treasury role) on PPP operational constraints affecting the smallest borrowers — including how the SBA's 20-day loan-cancellation rule interacted with the Federal Reserve's PPP Liquidity Facility, and daily ACH limits at small lenders. ↩
- Public-facing notices to applicants in 2021, including a formal warning that attempted PPP fraud was rising, that falsified tax documents would be "easy to catch" if the government used IRS data, and that Womply was cooperating with federal law enforcement and would deny or cancel fraudulent applications — an explicit effort to deter fraud before submission. ↩
- Calls with the SBA in late April 2021 coordinating on document fraud and work with receiving banks. ↩
- Communication to the SBA, its Office of Inspector General, and DHS, April 30, 2021, transmitting a file of approximately 5,000 fraudulent applications tied to organized rings and described as "the first of many such files." Applicant identifiers withheld. ↩
- Opening of a working relationship with the FBI on PPP loan fraud, late April 2021. ↩
- Coordination with the FBI and DHS in late April 2021 on fraud-warning messaging. ↩
- A May 2021 report to the SBA on the timing and pattern of organized exploitation Womply had observed. ↩
- Communication with the SBA, May 2021, recommending ways to detect and prevent fraud across COVID-relief programs and identifying categories of compromised identifiers to block. ↩
- A May 2021 submission to the SBA listing more than thirteen thousand loans tied to compromised identities, so they could be blocked from reuse. Applicant identifiers withheld. ↩
- Correspondence with the SBA, May 2021, confirming coordination with receiving banks had frozen more than $6 million in suspected-fraud disbursements. ↩
- A formal complaint filed with the SBA Office of Inspector General, May 2021. Reference number and underlying loan-level data withheld. ↩
- Analyses run for the SBA Office of Inspector General in May 2021 at its request, examining indicators linking fraudulent applications. Case details withheld. ↩
- A briefing to the SBA, May 2021, covering Womply's fraud-detection and -reporting methods. Internal meeting notes are privileged and not reproduced. ↩
- A May 2021 exchange in which a federal investigator endorsed having applicants provide IRS Form 4506-T — reinforcing the IRS-verification approach Womply had already urged on the SBA. ↩
- A written proposal to the SBA, May 2021, that the program require IRS Form 4506-T from applicants to support fraud detection. ↩
- Correspondence with the SBA in May–June 2021 proposing a standardized format and direct channel for transmitting suspected-fraud data to the SBA and its Inspector General. ↩
- Womply's role in the PPP was later examined and upheld in its PPP-related litigation (federal court, 2022; arbitration final award, 2024), which found Womply a technology provider, not a lender or loan underwriter, with no adverse findings against it. ↩
Prepared from primary records held by Womply. Every note corresponds to a real, dated communication or notice.