SCRA Compliance Training: What the DOJ Expects and Why Every Consent Decree Requires It

Every major SCRA consent decree in the past decade includes the same requirement: mandatory staff training.

Greystar, PRG Real Estate, Morningstar, CarMax, Santander, Westlake Financial: all were required to develop SCRA training programs, submit them to the DOJ for approval, and train all personnel who interact with servicemember accounts. This is not coincidental. The DOJ views inadequate training as a root cause of SCRA violations, not just a symptom.

If your organization handles lending, leasing, or property management, understanding what the DOJ expects from SCRA training is no longer optional. It is the difference between a defensible compliance program and a consent decree.

Why the DOJ Mandates Training

SCRA violations rarely happen because someone decides to break the law. They happen because front-line staff do not know the law exists.

A leasing agent charges an early termination fee because that is what the software tells them to do. A collections specialist initiates a repossession because the account is delinquent and no one flagged the borrower’s military status. A loan officer applies a standard interest rate because no one told them about the 6% cap.

The DOJ’s Servicemembers and Veterans Initiative has seen this pattern enough times to treat training as a compliance infrastructure requirement, not a nice-to-have. In every recent consent decree, the training mandate includes specific requirements:

Greystar (2025). Required to train all leasing agents on SCRA lease termination rights, early termination fee prohibitions, and military status verification procedures. Training materials must be submitted to the DOJ for approval. Five-year monitoring period.

PRG Real Estate (2019). Required SCRA training plus credit repair for all 127 affected servicemembers. PRG’s violations included 152 unlawful default judgments obtained through deficient military status affidavits, and training on affidavit requirements was specifically mandated.

Santander (2015). Required to develop and submit SCRA-compliant policies, procedures, and staff training materials for DOJ approval. Training had to cover repossession procedures, SCRA relief processing, and military status verification. The investigation was triggered by a single complaint from an Army Specialist whose car was repossessed during basic training.

Westlake Financial (2017, 2022). The original 2017 consent decree required training. When Westlake violated the agreement again in 2022 by failing to apply the 6% rate cap retroactively, the DOJ found that inadequate training was a contributing factor. Being under a consent decree does not mean compliance is solved. It means the DOJ is watching to see if your training actually works.

CarMax (2026). Required to implement SCRA training as part of a four-year consent decree. CarMax’s violations (28 illegal repossessions over five years) reflected a systemic gap in how staff handled military status verification before adverse actions.

What Effective SCRA Training Covers

Based on the training requirements embedded in recent consent decrees, every organization subject to a consent decree compliance framework must build a training program that covers at minimum:

1. Who the SCRA Protects

The SCRA applies to active-duty members of all branches of the armed forces, activated members of the National Guard and Reserve, and in some cases, dependents and spouses. The population that qualifies for protection can change at any time. A borrower or tenant who was civilian last month may be active duty today.

Training should cover:

• Active duty vs. reserve/Guard status and when protections apply
• How activation orders trigger SCRA protections
• That protections begin on the date of military orders, not the date of notification to the institution
• Dependent and spouse coverage under specific provisions

2. Core SCRA Protections by Sector

For lenders:

• 6% interest rate cap on pre-service debts (Section 3937)
• Prohibition on repossession without court orders (Section 3952)
• Default judgment protections and military status affidavits (Section 3931)
• Stay of proceedings for servicemembers who cannot appear (Section 3932)

For property managers:

• Lease termination rights with no early termination fees (Section 3955)
• Eviction prohibition without court order (Section 3951)
• Security deposit return obligations
• Military status verification before any default proceeding

For all sectors:

• That filing a false military status affidavit is a federal crime
• Current civil penalty amounts: $79,380 first offense, $158,761 subsequent (July 2025 inflation-adjusted)

3. Military Status Verification

Staff must know how to verify whether a borrower or tenant is on active duty before taking any adverse action. Training should cover:

• What the Defense Manpower Data Center (DMDC) is and how verification works
• That a single point-in-time check is insufficient for reservists and Guard members
• Documentation requirements for every verification
• What constitutes an acceptable verification before adverse action

4. Procedures When Military Status Is Confirmed

The most dangerous moment in SCRA compliance is when a staff member confirms that a borrower or tenant is on active duty and does not know what to do next. Training must include:

• Specific procedures for each protection (rate cap application, eviction hold, fee reversal)
• Who to escalate to and how quickly
• Documentation requirements at every step
• That failing to act on known military status is worse than not checking

5. Record-Keeping and Audit Trail Requirements

Every recent consent decree requires detailed documentation. Training should cover:

• What must be documented for each verification
• How to create records that will withstand a DOJ audit
• Quarterly reporting obligations (for organizations under consent decrees)
• Data retention requirements

How Often to Train

Consent decrees typically require:

• Initial training for all existing personnel within 60-90 days
• Training for all new hires within 30 days of start date
• Annual refresher training
• Additional training when policies or procedures change

The DOJ reviews training materials and may require modifications. Organizations under consent decrees must document attendance, maintain records of who was trained and when, and make training records available during audits.

The Cost of Not Training

The math is straightforward. Civil penalties per SCRA violation start at $79,380. A single untrained leasing agent who charges one early termination fee to one servicemember has created a potential liability that exceeds the cost of training your entire staff.

Greystar’s $1.4 million settlement could have been prevented by training leasing agents to check military status before applying fees. Santander’s $9.35 million settlement could have been prevented by training collections staff to verify military status before initiating repossession.

Training does not eliminate all risk. But the absence of training guarantees that the DOJ will find violations, and the consent decree that follows will require the training you should have done in the first place.

Building a Training Program

If your organization does not have an SCRA training program, here is a practical starting point:

Identify who needs training. Any employee who interacts with servicemember accounts, processes adverse actions (evictions, repossessions, collections), handles interest rate adjustments, or manages lease terminations.

Map your SCRA exposure. Which specific SCRA provisions apply to your business? Property managers face different requirements than auto lenders. Training should be tailored to the actual compliance obligations your staff encounters.

Build procedures, not just knowledge. Staff need to know what to do, not just what the law says. Clear, documented procedures for each scenario (tenant presents military orders, borrower requests rate cap, repossession queue includes unverified accounts) are more effective than legal lectures.

Document everything. Track who was trained, when, on what material, and by whom. This is the evidence the DOJ will ask for.

Test and refresh. Annual refresher training is the minimum. Scenario-based testing (presenting staff with realistic situations and evaluating their responses) identifies gaps before the DOJ does.

civrel.io offers half-day SCRA compliance workshops tailored to your industry: property management, lending, or auto finance. Each workshop covers the specific statutory requirements, recent enforcement cases, and hands-on scenarios relevant to your staff’s daily work. $5,000 per workshop (up to 25 attendees), included with Enterprise plans.

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The DOJ doesn’t care that you have a compliance policy. They care whether your people follow it. Every major SCRA enforcement action shares one finding: staff didn’t know the rules.

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