The DOJ wants 5 years of records. Can you produce them?
Every SCRA consent decree requires a retroactive audit: years of transaction records cross-referenced against military status. civrel does in days what takes consulting firms months.
Why retroactive audits matter
When the DOJ settles an SCRA case, the consent decree requires the company to look backwards. Not just "stop violating the SCRA going forward," but "find every servicemember you've already harmed and compensate them."
In the Greystar case, the lookback covered all military lease terminations from July 2018 to present. The company had to produce tenant names, property addresses, unit numbers, charge amounts, and amounts paid, with copies of account ledgers, for every affected servicemember.
In the Santander case, the audit covered 760 servicemembers whose vehicles were illegally repossessed. Each had to be identified, their damages calculated, and compensation of $10,000 plus lost equity paid to each affected servicemember.
These retroactive audits are typically managed by an independent consultant approved by the DOJ. The consultant pulls years of records, cross-references them against DMDC military status data, identifies every violation, calculates exposure, and produces a court-ready report. It takes months and costs hundreds of thousands of dollars.
How civrel's retroactive audit works
Upload historical records
Upload your transaction data (lease records, loan accounts, payment histories, fee assessments) in CSV or Excel format. civrel accepts records going back as far as you have them.
Batch military status verification
civrel cross-references every individual in your historical records against the DMDC. For each person, we determine: were they on active duty at the time of the transaction? If so, what SCRA protections applied?
Violation detection
The system automatically flags potential violations: fees charged during active duty periods, interest rates above the 6% cap, adverse actions taken without court orders, lease termination charges that violated SCRA rights. Each flag includes the specific SCRA section, the date range, and the financial impact.
Exposure calculation
For every identified violation, civrel calculates the exposure: the amount overcharged, the required refund, and the potential penalty. Consent decree compensation formulas vary by case. civrel supports configurable multipliers.
DOJ-ready reporting
Generate the report format the DOJ expects: servicemember identification, transaction details, violation type, SCRA section cited, financial impact, and recommended remediation. Exportable as PDF for court filing or CSV for your independent consultant to review.
Community and portfolio rollup
For multi-property operators or multi-branch lenders, civrel rolls up audit results by community, branch, or portfolio, showing where violations are concentrated and which locations have the highest exposure.
Two ways to use it
Before the DOJ comes knocking
Run a proactive audit on your own terms. Upload your last 3-5 years of records. See if you have exposure before a regulator finds it. If you do, remediate voluntarily. The DOJ views self-identification and voluntary remediation favorably.
After a consent decree
If you're already under a consent decree, the retroactive audit is mandatory. civrel accelerates the process: what takes a consulting firm 3-6 months to produce manually, civrel produces in days. Your independent consultant reviews the results instead of building them from scratch. Time saved is money saved, and the DOJ has hard deadlines.
The math
| Approach | Timeline | Cost | Output |
|---|---|---|---|
| Manual (consulting firm) | 3-6 months | $200K-500K+ (based on industry estimates) | Paper report, manual calculations |
| civrel | Days to weeks depending on portfolio size | Included in subscription | Digital report, automated calculations, exportable |
| civrel + consulting firm | 2-4 weeks | Consulting fee + subscription | Consultant validates civrel output instead of building from scratch |
The best approach for companies under consent decree: use civrel to produce the initial audit, then have your independent consultant validate the results. The consultant spends weeks reviewing, not months building. Your cost drops. Your timeline compresses. The DOJ gets their report faster.
Find out what's in your records
You can wait for a regulator to look, or you can look first. civrel scans your historical records and shows you every potential SCRA violation, before anyone else does.
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