SCRA compliance isn't a small problem.
You just can't see most of it.
2.1 million servicemembers. Every lease, loan, and credit account they hold. Four independent enforcement authorities. This page shows the full picture, not just the DOJ cases that make the news.
Last updated: March 2026
The Scope of the Law
Every active duty, reserve, and National Guard member is protected. Their number changes daily. You must verify, not assume.
Mortgages, auto loans, credit cards, leases, insurance policies, storage units. If a servicemember has a financial obligation with you, SCRA applies.
Protections activate the moment a servicemember enters active duty. They don't need to request protection. You need to check.
The SCRA isn't a niche regulation that affects a handful of companies. It's a federal law that governs how every financial institution and property manager in the United States interacts with military servicemembers. The question isn't whether you have servicemembers in your portfolio (you do). The question is whether you're verifying their status before taking adverse action.
Four Ways Violations Get Caught
DOJ consent decrees are the most visible, but they're not the only, or even the most common, enforcement mechanism.
DOJ Civil Rights Division
The Department of Justice actively investigates SCRA violations through its Civil Rights Division, Servicemembers and Veterans Initiative. Enforcement is bipartisan: 24 actions under Trump, 27 under Biden. The DOJ pursues violations regardless of company size, from $64K (JWB) to $35M+ (Bank of America).
Federal Regulators (CFPB, OCC, NCUA, FDIC)
Banking regulators examine SCRA compliance during routine supervisory exams. The CFPB found that fewer than 10% of eligible loans receive SCRA interest rate reductions, meaning 90%+ of covered servicemembers are losing benefits they're legally entitled to. The NCUA found 15% of federal credit unions had consumer compliance violations.
State Attorneys General
All 50 state AGs have independent authority to enforce SCRA protections. State-level enforcement is increasing, particularly for property management violations (evictions, lease terminations). State actions can proceed simultaneously with federal enforcement.
Private Litigation & Class Actions
Servicemembers can sue directly under SCRA, and class actions aggregate individual violations into massive liability. USAA paid $64.2M to settle a single class action over improper insurance practices. Private litigation doesn't require a government investigation. Any affected servicemember can initiate it.
The Gap Between the Law and Reality
Most institutions are technically violating SCRA right now. They just haven't been caught yet.
of eligible servicemembers aren't getting rate reductions
The CFPB found that fewer than 10% of eligible loans receive the 6% interest rate cap required by SCRA. The vast majority of lenders with servicemembers in their portfolio are in technical violation.
of credit unions have compliance violations
NCUA examination data shows that 15% of federally insured credit unions have consumer compliance violations. SCRA is consistently among the most common findings.
Most companies verify only when asked
SCRA requires verification before adverse action, not after a complaint. If your process depends on servicemembers self-identifying, you're already non-compliant. The obligation to verify is on the institution.
DOJ Enforcement Database
| Company | Year | Settlement |
|---|---|---|
| Greystar Management Services | 2025 | $1,427,370 |
| PRG Real Estate Management | 2019 | $1,590,000 |
| Hideaway at Greenbrier / Chase Arbor | 2022 | $225,000 |
| FPI Management | 2023 | $74,087 |
| JWB Property Management | 2025 | $64,169 |
| Lincoln Military Housing | 2016 | $200,000 |
| Twin Creek Apartments | 2018 | $95,615 |
| United Communities LLC | 2018 | $62,501 |
The Real Cost of an Enforcement Action
| Cost Category | Typical Range |
|---|---|
| Settlement / restitution | $64K - $35M+ |
| Outside counsel | $500K - $5M+ |
| Compliance program buildout | $200K - $2M |
| Ongoing compliance operations | $150K - $500K/yr |
| Independent monitor | $300K - $1M/yr |
| Staff training | $50K - $200K/yr |
| Reputational damage | Unquantifiable |
A company that pays a $200K DOJ settlement will spend $2M-$5M+ over the life of a consent decree on compliance operations, legal fees, and monitoring. The settlement is the cheapest part.
What Every Consent Decree Requires
Every DOJ SCRA consent decree imposes the same six core requirements. These are the minimum standard the DOJ considers adequate.
Written SCRA Compliance Policy
The company must develop and submit a written SCRA compliance policy to the DOJ for approval.
Staff Training
All employees involved in adverse actions must receive SCRA training at hire and annually thereafter.
DMDC Verification
Military status must be verified through DMDC before every eviction, repossession, foreclosure, or court filing.
Documentation & Retention
Every DMDC check, communication, and decision must be documented and retained for 3-5 years.
Monitoring & Self-Assessment
Quarterly compliance audits and annual self-assessments. Some decrees require independent monitors.
Restitution & Credit Repair
Full restitution to affected servicemembers, repair of credit records, and reversal of adverse actions.
These are not punitive extras. They are the minimum standard. Companies can build these components voluntarily, or the DOJ can require them after an enforcement action.
Enforcement Trends
Enforcement Is Bipartisan and Accelerating
SCRA enforcement is bipartisan and intensifying. The DOJ brought 24 enforcement actions under the Trump administration and 27 under the Biden administration. The 2025-2026 cases against Greystar, JWB, New City, and CarMax demonstrate that enforcement continues regardless of political administration.
No Company Is Too Small or Too Large
The smallest case in this database is JWB Property Management (6 servicemembers, $64,169). The largest is Bank of America (265+ servicemembers, $35 million+). The DOJ pursues violations at every scale.
Private Litigation Is the Bigger Risk
DOJ settlements get headlines, but private class actions drive bigger payouts. USAA's $64.2M class action settlement dwarfs most DOJ actions. As servicemember awareness increases and plaintiff law firms specialize in military consumer protection, private litigation risk is growing faster than regulatory risk.
Detailed Case Studies
PRG Real Estate Management
PRG Real Estate filed 152 false affidavits against 127 servicemembers, paying $1.59 million in the largest DOJ SCRA settlement against a property manager.
Westlake Services
Westlake Services paid $925K across two DOJ settlements for illegal vehicle repossessions and interest rate cap failures affecting 320 servicemembers.
Wells Fargo Dealer Services
Wells Fargo Dealer Services repossessed 863 servicemembers' vehicles without court orders, paying $9.5 million across two DOJ settlements.
Santander Consumer USA
Santander Consumer USA paid $9.35 million for illegally repossessing vehicles from over 1,100 servicemembers without court orders, in what was the largest SCRA auto lending settlement at the time.
Bank of America
Bank of America paid over $35 million for unlawfully foreclosing on active-duty servicemembers' homes and violating interest rate cap provisions, as part of the 2012 National Mortgage Servicing Settlement.
Capital One
Capital One paid $12 million for SCRA violations across foreclosures, repossessions, default judgments, and interest rate cap failures.
JPMorgan Chase
JPMorgan Chase paid $31 million for unlawfully foreclosing on servicemembers' homes and overcharging interest on mortgage loans, as part of the 2012 National Mortgage Servicing Settlement.
Free Resources
Download our SCRA Self-Assessment Checklist, State Protections Guide, and Enforcement Database.
Training Videos
Free SCRA training video library covering the same topics the DOJ tests during investigations.
SCRA Compliance Desk
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DOJ data sourced from press releases and court filings at justice.gov/servicemembers/cases. Regulatory data from CFPB Supervisory Highlights and NCUA Annual Reports. Class action data from public court records. Cost estimates based on public consent decree terms and industry benchmarks. This page is for educational purposes only and does not constitute legal advice. Updated March 2026. civrel.io maintains this tracker as a public resource for compliance professionals.
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