You Just Got a DOJ Consent Decree for SCRA Violations.
Here's What You Need to Do.
A step-by-step guide to meeting every requirement in your DOJ SCRA settlement agreement. Policies, training, retroactive audits, victim compensation, and ongoing reporting, with deadlines mapped and solutions for each.
10-90 days
Typical deadline window for initial deliverables
3-5 years
Duration of ongoing reporting requirements
7 requirements
Standard deliverables in every consent decree
A consent decree isn't a suggestion. It's a court-enforceable agreement with hard deadlines, mandatory deliverables, and the threat of contempt proceedings if you miss them. The DOJ reviews every deliverable you submit.
What Every SCRA Consent Decree Requires
Based on our analysis of DOJ SCRA settlement agreements (Greystar, Santander, Wells Fargo, CarMax, FPI Management, and others), every consent decree contains these requirements.
SCRA Policies and Procedures
Typical deadline: 30 days
You must develop new SCRA-specific policies and procedures covering your exact violation area: lease terminations, interest rate caps, repossession procedures, or foreclosure protections. These policies must be submitted to the DOJ for review and approval. The DOJ typically responds within 30 days. If they object, you negotiate until approved. Implementation begins within 10 days of DOJ approval.
What this means in practice
Your legal team or outside counsel drafts the policies. A compliance consultant may design the operational procedures. But the policies are only as good as the systems that enforce them, which is why most consent decrees also require technology changes.
How civrel handles this
Our platform includes SCRA policy templates mapped to every section of the SCRA (§§3931, 3932, 3937, 3951, 3952, 3953, 3955). These templates have been reviewed by legal counsel and align with the operational requirements DOJ consent decrees specify. We don't replace your legal team. We give them a starting framework that's already built for compliance.
Technology and Process Changes
Typical deadline: 6 months
The DOJ increasingly requires companies to change the technology systems that caused the violation. In the Greystar case, the consent decree explicitly required transitioning all properties to software platforms that do not automatically impose prohibited charges on servicemembers.
What this means in practice
You need either: (a) your existing vendor to build SCRA compliance into their platform, or (b) a specialized SCRA compliance layer that sits alongside your existing systems.
How civrel handles this
civrel integrates with your existing property management, lending, or servicing platform. We flag SCRA-protected individuals before any adverse action is taken: lease termination charges, repossessions, foreclosures, interest rate violations. No rip-and-replace required. Same-day implementation.
Employee Training
Typical deadline: 30 days after policy approval; ongoing annually
All employees involved in the relevant activity (leasing, collections, servicing, repossessions) must receive SCRA compliance training. New hires must be trained within 30 days. Training curriculum and materials must be submitted to the DOJ for review. Every employee must sign a digital acknowledgment.
What this means in practice
You need a training program that covers the specific SCRA sections relevant to your business, can be delivered to hundreds or thousands of employees, tracks completion with signed acknowledgments, and satisfies DOJ review.
How civrel handles this
Our SCRA training video library includes 19 compliance training modules organized by vertical (property management, auto lending, banking). Each module is 2-5 minutes, covers specific SCRA requirements with enforcement examples, and is designed for frontline staff. Digital acknowledgment tracking is on our near-term roadmap.
Retroactive Audit (Lookback Review)
Typical deadline: Consultant proposed within 30 days; review completed within 90 days
You must engage an independent consultant (approved by the DOJ) to review all relevant transactions going back several years, sometimes 5-7 years. The consultant produces a detailed report identifying every affected servicemember, the violation, and the amount owed.
What this means in practice
You need to pull years of transaction records, cross-reference them against military status databases, identify every violation, calculate compensation owed, and produce a court-ready report. This is exactly the kind of work that takes months when done manually, or days when automated.
How civrel handles this
Our retroactive audit module was built specifically for consent decree compliance. Upload historical records, and civrel automatically cross-references against DMDC military status data, flags potential violations, calculates exposure, and generates a DOJ-ready report with full documentation.
Victim Identification and Compensation
Typical deadline: 45-90 days after audit; compensation at 3x charges paid
Once the audit identifies affected servicemembers, you must compensate them. Typical consent decrees require compensation at three times the amount of any improper charge paid, plus the full amount of any charge imposed but not yet paid. You must retain an Independent Settlement Administrator to manage the distribution.
What this means in practice
This is a claims administration process. You need accurate victim identification, current contact information, standardized compensation calculations, DOJ-approved correspondence, and detailed accounting reported to the DOJ every six months.
How civrel handles this
Our audit report generates the victim identification list with calculated compensation amounts. Address verification for skip tracing is on our near-term roadmap. Compensation letters can be generated from DOJ-approved templates. Full accounting and reporting is tracked in the platform for your semi-annual DOJ submissions.
Ongoing Monitoring and Reporting
Typical deadline: Quarterly, for the duration of the agreement (3-5 years)
For the entire term of the consent decree, you must retain all records, report every SCRA-related complaint to DOJ counsel quarterly, inform the DOJ of complaint resolutions within 30 days, provide semi-annual accounting of compensation distributions, and make all records available to the DOJ on request.
What this means in practice
You need a system that logs every SCRA interaction, tracks complaints from intake to resolution, generates quarterly and semi-annual reports in the format the DOJ expects, and retains records for 5+ years with full audit trail.
How civrel handles this
Continuous portfolio monitoring automatically re-screens your accounts for military status changes. Every SCRA action, complaint, and resolution is logged with timestamps and audit trail. Quarterly DOJ reports and semi-annual compensation accounting are generated directly from the platform.
Civil Penalty Payment
Typical deadline: 10-14 days
You must pay a civil penalty to the United States Treasury and deposit compensation funds into an escrow account. Amounts range from $77,370 (Greystar) to $9.35 million (Santander), depending on the scope and severity of violations.
What this means in practice
Handled by your finance team and outside counsel.
Typical Consent Decree Compliance Timeline
- Pay civil penalty and deposit escrow funds
- Engage outside counsel or compliance consultant
- Begin drafting SCRA policies and procedures
- Identify and propose independent consultant to DOJ
- Submit policies and training materials to DOJ for approval
- Begin independent consultant review (retroactive audit)
- Start technology evaluation and implementation
- DOJ reviews and approves (or revises) policies
- Train all employees within 30 days of policy approval
- Collect signed training acknowledgments
- Independent consultant completes lookback review
- Victim identification and compensation distribution begins
- Technology transition completed
- First quarterly DOJ report submitted
- Annual training for all employees
- Quarterly complaint reporting to DOJ
- Semi-annual compensation accounting
- Ongoing record retention and DOJ access
- Continuous monitoring for new SCRA-protected accounts
Two Paths Forward
Consulting Firm + Manual Processes
Hire a compliance consulting firm to design your policies and manage the lookback. Use manual processes for ongoing compliance.
Pros
Established firms with DOJ credibility. Hands-off for your team during initial setup.
Cons
Expensive ($200K-$500K+). Lookback takes months. No technology for ongoing monitoring, so you're back to manual processes after the consultant leaves.
civrel.io: Technology + Managed Service
Implement civrel for automated SCRA compliance: verification, monitoring, documentation, training, and reporting. Use our Compliance Desk managed service for hands-off operations.
Pros
Retroactive audit in days, not months. Ongoing monitoring prevents future violations. Training library ready for DOJ review. Fraction of the cost.
Cons
You still need outside counsel for legal review. We complement your legal team, we don't replace them.
The Best Approach: Both
Many organizations under consent decree use a compliance consultant for initial policy design and DOJ relationship management, then implement civrel for the technology, monitoring, and ongoing operations. The consultant leaves after 6 months. civrel stays for the full 5-year term.
Related Resources
Compliance Desk
Managed SCRA compliance service. We operate civrel on your behalf.
Training Library
19 SCRA compliance training modules for frontline staff
Enforcement Database
Every SCRA enforcement action since 2011 — 36 cases, $484M+ recovered
Free Resources
SCRA self-assessment checklist, state protections guide, and more
See How civrel Maps to Your Consent Decree
Every consent decree is different. Tell us which requirements you're facing, and we'll show you exactly how civrel addresses each one, including a timeline for implementation.
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