If you manage residential properties near a military installation, or anywhere in the United States, the Servicemembers Civil Relief Act applies to you. It applies whether you manage 50 units or 500,000. Whether you use Yardi, RealPage, Entrata, or spreadsheets. Whether your tenants have told you they’re military or not.
The consequences of non-compliance are not theoretical. In the past two years, the DOJ has imposed settlements totaling over $3 million on property management companies for SCRA violations. Greystar, the nation’s largest property manager, is under five-year DOJ monitoring. PRG Real Estate paid $1.59 million after filing 152 false affidavits with Virginia courts.
This guide covers every SCRA obligation relevant to property managers, the enforcement actions that define the DOJ’s expectations, state laws that go beyond the federal baseline, and how to build a compliance program that meets consent decree standards.
Who the SCRA Protects
The SCRA protects the following individuals during their period of active-duty service:
- Active-duty members of the Army, Navy, Air Force, Marines, Coast Guard, and Space Force
- Activated National Guard and Reserve members (protection begins when they receive orders to report for duty)
- Commissioned officers of the Public Health Service and NOAA
- Dependents of servicemembers in certain circumstances (lease termination rights extend to co-tenants)
Protection begins on the date a servicemember enters active duty and generally ends on the date of discharge or release, though some provisions extend protections for a period after discharge.
A critical detail for property managers: you cannot determine SCRA eligibility by looking at a tenant. Reservists and National Guard members cycle between civilian and active-duty status. A tenant who was not protected last month may be protected today. This is why verification, not assumption, is the foundation of compliance.
The Four Core Obligations
1. Eviction Protection (50 U.S.C. Section 3951)
The rule: You cannot evict an active-duty servicemember or their dependents without a court order. This applies even in states that permit non-judicial eviction for non-military tenants.
What this requires in practice:
Before filing any eviction, you must verify the tenant’s military status through the Defense Manpower Data Center (DMDC) database at scra.dmdc.osd.mil. If the tenant is on active duty, you must petition the court for permission to proceed. Self-help eviction (changing locks, removing belongings, shutting off utilities) is prohibited.
When you petition the court, the judge may:
- Stay (pause) the eviction for at least 90 days if military service materially affects the servicemember’s ability to pay rent
- Adjust the terms of the obligation
- Appoint an attorney to represent the servicemember if they cannot appear due to military service
The servicemember has the right to appear and be heard before the court makes any decision.
Where companies get this wrong:
PRG Real Estate Management obtained 152 default judgments against 127 servicemembers in Virginia courts from 2006 to 2017. In each case, PRG either stated that the tenant was not in the military or failed to accurately disclose the tenant’s military status. The courts entered default judgments based on this inaccurate information. PRG paid $1.59 million, the largest SCRA settlement ever against a property management company at the time.
The fix: verify military status through DMDC before every court filing. Attach the DMDC result to the military status affidavit. This is how you demonstrate good faith to the court and avoid filing a false affidavit.
2. Lease Termination Rights (50 U.S.C. Section 3955)
The rule: Servicemembers who receive qualifying military orders can terminate their lease early with no penalties.
Qualifying orders include:
- Permanent Change of Station (PCS) orders
- Deployment orders of 90 days or more
- Orders to move into government-provided quarters
- Separation or retirement orders (when the lease was signed during military service)
The termination process:
The servicemember provides written notice to the landlord along with a copy of their military orders. The lease terminates on the last day of the month following the month in which the notice is delivered (per Section 3955(d)(1)).
You may charge rent through the termination date, prorated as needed. You may not charge:
- Early termination fees
- Lease-break penalties
- Liquidated damages
- Rent for any period after the termination date
- Charges for remaining lease term
Security deposits must be handled per your state’s standard timeline. You cannot offset the deposit with post-termination rent or penalties.
Co-tenants (spouse, dependents) are also released from the lease under the same terms.
Where companies get this wrong:
Greystar Management Services’ property management software automatically charged early termination fees to all tenants who broke their lease. Staff were supposed to manually waive the fees for military tenants. The manual override failed systematically. The DOJ found that Greystar “relied on software that it knew would automatically impose early termination charges on SCRA-protected servicemembers” and “failed to implement adequate controls to ensure compliance.”
Greystar paid $1,427,370 and is under DOJ monitoring for five years.
The fix: your systems must identify military tenants before fees are applied, not after. Automated verification, not manual overrides.
3. Default Judgment Protection (50 U.S.C. Section 3931)
The rule: Before any court can enter a default judgment, the plaintiff must file an affidavit stating whether the defendant is in military service.
What this requires:
Every time you file for eviction, pursue a money judgment, or take any court action against a tenant, you must file a military status affidavit. This affidavit must state whether the defendant is or is not in military service, based on actual verification, not guesswork.
If the defendant is on active duty, the court must appoint an attorney to represent them before entering any judgment.
The criminal risk:
Filing a false military status affidavit is a federal offense under 50 U.S.C. Section 3931(c). This is not a civil penalty. It is criminal liability. If you state that a tenant is not in the military and they are, you have filed a false affidavit with a court. PRG Real Estate filed 152 of them.
The DMDC check is your protection. Run the check, document the result, reference it in your affidavit. This is how you ensure accuracy and demonstrate good faith.
4. Interest Rate Cap (50 U.S.C. Section 3937)
The rule: Interest on debts incurred before military service cannot exceed 6% per year during the period of service.
While this obligation primarily affects lenders, it applies to property managers in certain situations, specifically when a lease agreement includes financing terms, payment plans for past-due rent, or any arrangement where interest is charged on a pre-service obligation.
If a servicemember requests the rate cap, you must reduce the interest rate to 6% and forgive (not defer) the excess interest. The cap applies retroactively to the date the servicemember entered active duty.
Enforcement Actions Against Property Managers
The DOJ has brought enforcement actions against property management companies of all sizes. Here are the major cases:
| Company | Year | Settlement | Violation |
|---|---|---|---|
| Greystar Management Services | 2025 | $1,427,370 | Automated software charged illegal early termination fees |
| PRG Real Estate Management | 2019 | $1,590,000 | Filed 152 false affidavits, obtained 152 unlawful default judgments |
| Hideaway at Greenbrier / Chase Arbor | 2022 | $225,000 | False affidavits, unlawful evictions |
| Lincoln Military Housing | 2016 | $200,000 | Filed false affidavits denying tenants were active-duty military |
| FPI Management | 2023 | $74,087 | Early lease termination charges |
| JWB Property Management | 2025 | $64,169 | Early termination charges on 6 military tenants |
| Freedom Village (DE) | 2014 | $35,000 | Unlawful eviction of deployed servicemember |
Total property management settlements: $3.6 million+
For detailed analysis of each case, visit our SCRA Enforcement Tracker at civrel.io/enforcement.
The Common Pattern
Every case follows the same pattern:
- The company’s workflow did not include military status verification before adverse action
- Staff either didn’t check, or checked incorrectly, or relied on manual processes that failed at scale
- The DOJ investigated, often triggered by complaints from military legal assistance offices
- The settlement required the same remedies: DMDC verification, written policy, training, monitoring, restitution
The root cause is always structural, not individual. No enforcement action was caused by a single bad employee. Every one was caused by a process that didn’t account for the SCRA.
State Laws Beyond Federal SCRA
The federal SCRA sets a nationwide floor, but many states have enacted additional protections that go beyond the federal baseline. Under 50 U.S.C. Section 3920, states may provide greater protections but cannot reduce them. When federal and state law differ, the more protective standard applies.
Key state provisions for property managers:
Virginia (Section 55.1-1235): Prohibits charging liquidated damages when a servicemember terminates a lease under military orders. This goes beyond the federal prohibition on early termination fees, specifically addressing liquidated damages clauses common in Virginia lease agreements.
California (Military & Veterans Code Section 409): Extends protections beyond federally covered servicemembers to include state-activated Guard members. Prohibits charging any fees, costs, or penalties related to early lease termination by servicemembers.
New York (Military Law Section 310): Provides broader coverage than the federal SCRA, extending protections to additional categories of military personnel and permitting the state Attorney General to bring enforcement actions.
Texas (Property Code Section 92.017): Allows servicemembers to terminate leases without penalty upon receiving qualifying orders, with 30 days’ written notice.
Washington (RCW 59.18.220): Requires 20 days’ written notice for lease termination with specific move-distance triggers for military relocations.
Florida (Section 250.5201): Expands protections to include governor-ordered National Guard call-ups that exceed a specified duration threshold.
If you manage properties in multiple states, your compliance team must track both federal and state requirements. The stricter standard always applies. For a comprehensive state-by-state breakdown, see our State SCRA Protections Guide at civrel.io/resources.
Building a Compliance Program
Every DOJ consent decree imposed on a property management company has required the same six components. You can build them voluntarily, or the DOJ can require them after an enforcement action. The components are the same either way.
1. Written SCRA Policy
A written policy that covers:
- When military status verification is required (before every eviction, fee assessment, court filing, and adverse action)
- How to process lease termination requests from servicemembers
- Prohibition on early termination fees and penalties for protected tenants
- How to handle tenant self-identification as military
- Record retention requirements
Reviewed and updated at least annually. Accessible to every leasing agent and property manager.
2. Staff Training
Training for every role that can trigger an adverse action against a tenant: leasing agents, property managers, maintenance staff who handle lockouts, anyone involved in the eviction process.
Training must cover:
- SCRA protections relevant to property management
- How to verify military status through DMDC
- What to do when a tenant identifies as military
- Lease termination processing for servicemembers
- Documentation requirements
Frequency: at hire and annually thereafter. Document who was trained, when, and what was covered.
3. Military Status Verification Workflow
Build DMDC verification into your workflow at every decision point:
- Before filing any eviction
- Before charging any early termination fee
- Before filing any court action
- Before applying any penalty to a tenant account
- When a tenant self-identifies as military
Automated verification is better than manual verification because it cannot be skipped. If the check depends on someone remembering to run it, it will eventually be forgotten.
4. Documentation & Record Retention
Retain:
- Every DMDC verification (date, result, who ran it)
- Lease termination requests and military orders
- Court filings and affidavits
- Communications with tenants about military status
- Training records
Minimum retention: 3 years (DOJ consent decree standard). Recommended: 5-7 years to cover the statute of limitations for private SCRA lawsuits.
5. Monitoring & Self-Assessment
- Audit a sample of evictions and terminations quarterly
- Verify that DMDC checks were performed before every adverse action
- Review how lease termination requests from servicemembers were processed
- Conduct a comprehensive annual self-assessment
- Use our SCRA Self-Assessment Checklist (civrel.io/resources) as a starting framework
6. Escalation Procedures
Define a clear chain:
- Leasing agent identifies a tenant as active-duty (via DMDC or self-identification)
- Account flagged: all adverse actions halted immediately
- Compliance officer or property manager reviews within 24 hours
- Legal counsel consulted if court action is needed
- Every step documented and filed
The Cost of Non-Compliance vs. Compliance
The math is straightforward:
Non-compliance costs:
- $1.59 million (PRG Real Estate, 2019)
- $1.43 million (Greystar, 2025)
- 5 years of DOJ monitoring (Greystar)
- Credit repair obligations for all affected servicemembers
- Reputational damage in military housing markets
- Legal fees for DOJ investigation and settlement
Compliance costs:
- DMDC verification: free
- Written policy: staff time to draft and review
- Training: 1-2 hours per employee annually
- Automated compliance tools: a fraction of a single settlement
Every company that paid millions to the DOJ would have preferred to spend thousands on prevention.
Next Steps
- Assess your current compliance: Download our free SCRA Self-Assessment Checklist (civrel.io/resources), covering 49 items across 8 compliance areas
- Train your staff: Watch our free 8-video SCRA training series for property managers (civrel.io/training)
- Review enforcement actions: See every DOJ settlement on our SCRA Enforcement Tracker (civrel.io/enforcement)
- Automate verification: civrel.io replaces manual DMDC lookups with automated, continuous military status verification integrated into your workflow
Sources: DOJ Press Releases (justice.gov/servicemembers/cases); 50 U.S.C. Sections 3901-4043; CFPB Servicemember Resources; State statutes as cited.
This guide is for educational purposes only and does not constitute legal advice. Consult qualified legal counsel for guidance specific to your organization.
© 2026 civrel.io. All rights reserved.
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