The Most Common SCRA Violations, Ranked by What DOJ Made Companies Pay

This is a data page built from the 64 records in this site’s SCRA enforcement ledger, each transcribed from the Justice Department’s press release or case page, retrieved July 11, 2026 with the last addition on August 4, 2026. The ledger tags every case with one violation type. This page counts those tags, lists who is under each, states the largest resolution in each type exactly as DOJ printed it, and sums what can be summed.

Method, in one sentence: the “exact figures summed” column adds only dollar amounts DOJ stated without a hedge (compensation, settlement funds, and civil penalties, including per-person amounts times a stated count), and any figure DOJ printed as “at least,” “approximately,” “over,” or “up to” is shown in the type’s section but left out of the sum, so each sum is a floor built from the exact figures, not a total for the category.

The ranking

Ordered by the largest single resolution in the type. Counts are ledger records, not servicemembers.

Not ranked: three professional-license portability matters under 50 U.S.C. § 4025a against state licensing bodies (Georgia’s 42 boards, up to $3 million, 2026; Porteé v. Morath, a private win; New Mexico, pending), which are not company violations of the sections above. Two private class actions in the rate cap count (Espin v. Citibank, Padao v. American Express) carry no dollar figure and are counted but not summed.

1. Foreclosure without a court order (§ 3953)

Mechanism. A mortgage that originated before military service cannot be foreclosed, sold, or seized during service or within one year after without a court order granted first (§ 3953(c)). Non-judicial foreclosure states let a servicer skip the courtroom for everyone else; the servicer skipped it for servicemembers too, because nobody checked military status before the referral. The section does not require the borrower to say anything.

Who. Bank of America / Countrywide (2011, over $36.8 million, $116,785 minimum per person), Saxon Mortgage (2011, over $2.5 million), the National Mortgage Settlement SCRA review of Chase, Wells Fargo, Citi, GMAC/Ally, and Bank of America (2015, over $311 million, $125,000 each plus lost equity), Northwest Trustee Services (2017 to 2018, up to $750,000 for 28 homes), and PHH Mortgage (2019, $750,000 for six homes).

Why it ranks first. Compensation is set per servicemember at a six-figure floor rather than divided from a pool; six homes cost PHH $750,000. Only PHH’s figure is unhedged, so the summed column understates this type by more than $350 million.

2. Rate cap denied, delayed, or applied to one account (§ 3937)

Mechanism. Three failure shapes. The cap is denied or the request is lost. The cap is applied to the one account named in the letter while affiliates keep billing full rate on the rest, the trap the Capital One consent order closed by requiring one request to cover every account. Or the cap is granted but not backdated to the call-to-service date, or approved slowly enough that months of excess interest accrue, which is what Westlake’s 2022 addendum paid $185,460 to 250 servicemembers for.

Who. Capital One (2012, approximately $12 million across rate cap, foreclosure, repossession, and judgment conduct), Sallie Mae / Navient (2014, $60 million to about 60,000 servicemembers, $55,000 penalty), Conn Credit (2020 to 2021, refunds plus $500 each to at least 184 servicemembers, $50,000 penalty), BayPort Credit Union (2022, $69,443.10 to 24, $40,000 penalty), Westlake (2022, above), and the two private class actions, Espin v. Citibank and Padao v. American Express, where the United States filed Statements of Interest on the right to proceed as a class.

Sum. $60,439,903.10 in exact figures; Capital One’s “approximately $12 million” and Conn Credit’s uncounted refunds are excluded. The lender-side controls are on SCRA compliance for lenders and servicers; the servicemember’s letter is on the rate cap guide.

3. Repossession without a court order (§ 3952)

Mechanism. A vehicle (or other property) on a contract with a deposit or installment paid before service cannot be repossessed for breach during service without a court order (§ 3952(a)). Every case here is a lender or dealer sending the tow truck on a delinquent pre-service loan without a DMDC check. Santander’s consent order made DMDC checks mandatory before any future repossession.

Who. Santander Consumer USA (2015, at least $9.35 million, 1,112 vehicles), Wells Fargo Dealer Services (2016 to 2017, $10,183,950 for more than 860, $60,000 penalty), HSBC Auto Finance (2016, $434,500, 75 vehicles), COPOCO Community Credit Union (2016 to 2017, $37,500 to four, $5,000 penalty), CitiFinancial (2017, $907,000, 164 vehicles), Westlake and Wilshire (2017, $700,000, $60,788 penalty, 70 vehicles), California Auto Finance (2018 to 2019, $30,000, $50,000 penalty), Hudson Valley FCU (2018, $65,000 to seven, $30,000 penalty), Nissan Motor Acceptance (2019, $2,937,971 plus $62,029, 113 vehicles plus lease refunds), GM Financial (2022, $3,534,171 plus $65,480, 71 vehicles plus more than 1,000 mishandled lease terminations), New City Funding (2025, at least $60,000, $60,000 penalty), CarMax (2026, at least $420,000, $79,380 penalty, 28 vehicles), and Holmes Motors (2026, $77,348, $60,000 penalty, three vehicles plus five lease deposits).

Sum. $19,440,117.00 exact. Santander’s floor, CarMax’s floor, and New City’s floor are excluded; add them and the type clears $29 million. Per-vehicle compensation clusters at $10,000 plus lost equity.

4. Lease exit charges and kept money (§ 3955)

Mechanism. A servicemember terminates a residential or vehicle lease on qualifying orders; the lessor then charges an early termination fee the statute forbids (§ 3955(e)), claws back a move-in concession, keeps the security deposit against rent that will never accrue (§ 3955(h)), or, on vehicle leases, keeps the capitalized cost reduction and other amounts paid in advance that § 3955(f) says come back within 30 days. Greystar’s version was automated: DOJ alleged the billing software imposed the fee without regard to military status.

Who. Twelve residential landlords and managers: Crowe (2017, $1,425 plus $475), Belshaw (2018, $2,595 plus $1,595), United Communities at Joint Base McGuire-Dix-Lakehurst (2018, $45,001.78 plus $17,500), Twin Creek Apartments (2018, $75,615 plus $20,000), Levenson (2020, $3,000 plus $500), Western Rim Investors (2020, over $71,000 plus $64,715), Integrity Asset Management (2022, $45,325 plus $62,029), FPI Management (2023, $51,587 plus $22,500), JAG Management (2023, $41,581.95 plus $20,000), RedSail (2024, $10,225.65 plus $3,000), Greystar (2025, $1.35 million set aside with triple damages, $77,370 penalty), and JWB Property Management (2025, $39,168.50 plus $25,000). Three vehicle lessors: BMW Financial Services (2018, $2,165,518.84 to 492 plus $60,788), American Honda Finance (2021, $1,585,803.89 to 714 plus $64,715), and Chrysler Capital (2021, $94,282.62 to ten plus $40,000, refused terminations).

Sum. $5,991,317.23 exact; Western Rim’s “over $71,000” is excluded. Landlord-side rules are on SCRA for landlords and property managers; the vehicle-lease rules are on terminate a car lease under the SCRA.

5. Default judgments on false or missing affidavits (§ 3931)

Mechanism. A plaintiff must file an affidavit about the defendant’s military status before a court enters a default judgment, and if the defendant is serving the court appoints counsel first (§ 3931(b)). The violation is filing nothing, filing “not in military service” without checking, or filing it knowing it is false, which is a crime (§ 3931(c)). The judgment then supports garnishment, eviction, or vehicle disposal against someone who never knew about the case.

Who. PRG Real Estate Management (2019, up to $1,490,000 for 127 servicemembers plus $34,920 for termination fees, $62,029 penalty), New Jersey Higher Education Student Assistance Authority (2021, $30,000 to two, $20,000 penalty), Chesapeake Coveside Lane Apartments (2022, $225,000 total, judgments vacated), Goines Towing (2023 to 2024, $66,805.06 plus $30,000, vehicles disposed of under bad judgments), and Rental Marketing Solutions (2026, $60,000 plus $6,000, one false affidavit against one sailor). Sallie Mae’s 2014 case and Capital One’s 2012 case also included improper judgments but are counted under rate cap.

Sum. $534,754.06 exact; PRG’s “up to $1,490,000” is excluded. What the affidavit must say, and how to reopen a judgment, is on the military affidavit page and the default judgment shield.

6. Service contract early termination charges (§ 3956)

Mechanism. Mobile phone, landline, internet, TV, gym, and home security contracts can be ended on relocation orders of 90 days or more to a place that does not support the contract, with no early termination charge and a refund of advance payments within 60 days (§ 3956). The violation is a notice rule or fee the contract carries for everyone, applied to servicemembers anyway.

Who. Teleguam Holdings (GTA) (2025, $450,000 with double damages to over 1,300 servicemembers, $50,000 penalty) and ADT (2026, up to $1,260,000 to at least 3,400 servicemembers over a 30-day notice requirement, $79,380 penalty). Sum. $579,380.00 exact; ADT’s “up to” figure is excluded. Your side of the rule is on cancel phone, cable, and internet on orders.

7. Storage liens and towing auctions (§ 3958)

Mechanism. A lien for storage, repair, cleaning, or any other reason on a servicemember’s property cannot be enforced during service and for 90 days after without a prior court order (§ 3958(a)). The cases are towing companies, storage operators, and three cities’ towing contractors auctioning cars and belongings while the owner was deployed.

Who. Honolulu and All Island Towing (2018, $55,857.95 to three plus a $150,000 fund, $60,788 penalty), Shur-Way Moving (2019, $20,000 plus $10,000), Target Recovery Towing (2020, $17,500 plus $2,500), Father & Son Moving & Storage (2020 to 2021, $60,000 plus $5,000), City of San Antonio (2020, $259,000 total), ASAP Towing (2020, $99,500 plus $20,000, 33 vehicles), United Tows (2020 to 2021, $40,000 to five plus $10,000), Black and White Towing (2021, $22,000 plus $5,000), Steve’s Towing (2022 to 2023, $90,000 total), El Paso and its two contractors (2023 to 2025, $57,935 and $140,000 funds, $64,980 in penalties across three settlements, at least 176 vehicles), Todisco Towing (2023, $5,000 plus $1,000), Morningstar Storage (2024, $90,000 to three plus $40,000), Vehicle Management Solutions (2026, $220,000 plus $60,000, about 93 vehicles), and S & K Towing (2026, $160,000, as many as 148 vehicles).

Sum. $1,766,089.95 exact. Small money per case, but the second most frequent violation in the record, and two of the 2026 settlements are towing cases. The pre-deployment steps are on the storage lien page.

The penalty schedule

Section 4041(b)(3) authorizes a civil penalty of up to $55,000 for a first violation and $110,000 for any subsequent violation, and DOJ adjusts those figures for inflation at 28 CFR 85.5. The eCFR table, read August 15, 2026 and current through August 13, 2026, prints two columns: $77,370 and $154,741 for penalties assessed after February 12, 2024, and $79,380 and $158,761 for penalties assessed after July 3, 2025. The ledger tracks the change exactly: Greystar’s June 24, 2025 penalty was $77,370, and the CarMax (February 23, 2026) and ADT (April 14, 2026) penalties were $79,380, which DOJ’s ADT release calls “the maximum penalty for a first violation.” Holmes Motors and VMS took $60,000 in 2026; the three individual landlords paid $475, $500, and $1,595. The penalty is a ceiling scaled to the case, not a measure of how many people were harmed, and it is always on top of compensation.

How to report an SCRA violation

Four routes, all verified live on August 15, 2026.

1. Installation legal assistance first. DOJ’s own page says: “If you believe your rights under the SCRA have been violated, please contact your local military legal assistance office.” The locator is legalassistance.law.af.mil. It is free, and the Santander, Wells Fargo, and Crowe cases all began as legal assistance referrals.
2. DOJ Civil Rights Division. If you are not eligible for military legal assistance and want DOJ to evaluate the claim, submit it through the Civil Rights Division portal at civilrights.justice.gov/report. DOJ states it cannot investigate every complaint and cannot form an attorney-client relationship with an individual servicemember; it sues in the name of the United States. Its Servicemembers and Veterans Initiative contact is servicemembers@usdoj.gov.
3. CFPB. For a bank, card issuer, mortgage servicer, auto lender, student loan servicer, or debt collector, file at consumerfinance.gov/complaint or (855) 411-2372. The Bureau lists mortgages, credit cards, vehicle loans or leases, student loans, and debt collection among the products it takes complaints on; residential landlords are not on the list.
4. State attorney general. Many states have their own servicemember relief statutes and consumer protection acts, and a landlord dispute usually belongs there. Find yours through usa.gov/state-attorney-general.

The fifth route is your own suit under § 4042: damages, equitable relief, costs and a reasonable attorney fee, and class treatment notwithstanding an arbitration clause, with § 4043 preserving consequential and punitive damages under other law. The mechanics are on how to sue a lender for SCRA violations and the SCRA lawyers page. Whatever route you take, the file is the same: your orders, the notice you sent and proof it arrived, every statement, and the DMDC certificate showing your status on the date it mattered.

The law behind this: 50 U.S.C. §§ 4041, 4042, 4043

Enforcement by the Attorney General; private right of action; preservation of remedies: read the statute.