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

This is a data page built from the 66 records in this site’s SCRA enforcement ledger, each transcribed from the Justice Department’s own published record: its press releases, its case pages, and the orders and agreements they link. The ledger was retrieved July 11, 2026, and its most recent addition is dated October 10, 2026. The ledger tags every case with one violation type. This page counts those tags, lists who is under each in the ledger’s own terms, states the largest resolution in each type, and adds up the figures the ledger states as fixed amounts.

Method. A dollar figure goes into a type’s sum only when the ledger record states it as a fixed amount. That leaves out any figure qualified by “up to,” “at least,” “over,” “about,” “approximately,” or “a minimum of”; any settlement fund, escrow deposit, or amount set aside, because the order sets what is available rather than what is paid; and any formula with an open-ended part, such as “$10,000 plus lost equity.” A fixed amount per person counts only when the record states the head count exactly, and the multiplication is shown. A stated total that contains a left-out part is not used, though its fixed parts are. Where a record gives an earlier figure and a later update for the same money, only the later one is judged. Civil penalties are fixed amounts and are included. Each type’s Sum line lists every figure added, case by case, and then every figure left out, so each sum is a floor for the type, not its total.

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, 2023; New Mexico, a pending complaint, 2026), 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 to 2013: a $20 million settlement that DOJ’s 2013 update grew to over $36.8 million for 297 servicemembers, a minimum of $116,785 each plus lost equity with interest), Saxon Mortgage (2011 to 2013: over $2.5 million to 19 servicemembers, a minimum of $130,555.56 each plus lost equity with interest), the National Mortgage Settlement SCRA review of Chase, Wells Fargo, Citi, GMAC/Ally, and Bank of America (2015: over $311 million for 2,413 servicemembers and co-borrowers, $125,000 each plus lost equity with interest), Northwest Trustee Services (2017 to 2018: up to $750,000, at least 28 homes), and PHH Mortgage (2019: $750,000, $125,000 per servicemember, six servicemembers).

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

Sum: $750,000. PHH $750,000. Not summed: Bank of America’s “over $36.8 million” (the update that replaced its 2011 $20 million); Saxon’s “over $2.5 million” (the update that replaced its 2011 $2.35 million); the National Mortgage Settlement’s “over $311 million”; Northwest Trustee’s “up to $750,000.”

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 date the orders were issued, 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, about $7 million in damages and a $5 million rate-cap fund, across rate cap, foreclosure, repossession, and judgment conduct), Sallie Mae / Navient (2014: $60 million in compensation, about 60,000 servicemembers estimated to receive payments, $55,000 penalty), Conn Credit (2020 to 2021: all overcharged interest refunded plus $500 to each servicemember, at least 184 servicemembers, $50,000 penalty), BayPort Credit Union (2022: $69,443.10 in escrow for 21 servicemembers on the rate cap and three repossessions, $40,000 penalty), Westlake (2022: above, plus a $40,000 penalty), 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: $60,370,460. Sallie Mae $60,000,000 + $55,000; Conn Credit $50,000; BayPort $40,000; Westlake $185,460 + $40,000. Not summed: Capital One’s “approximately $12 million” (with its “about $7 million” in damages and its $5 million fund); Conn Credit’s interest refunds, whose amount the record does not state, and its $500 each, because the record counts the servicemembers only as “at least 184”; BayPort’s $69,443.10 escrow (DOJ’s case page says $69,443.10 to 24 servicemembers); Espin and Padao, which carry no dollar figure. 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 taking a protected servicemember’s vehicle without that order. Santander’s settlement made Defense Department database checks mandatory before any future repossession.

Who. Santander Consumer USA (2015: at least $9.35 million for 1,112 vehicles, $10,000 plus lost equity with interest to each of 760 and $5,000 to each of 352), Wells Fargo Dealer Services (2016 to 2017: $10,183,950 for more than 860 servicemembers, $60,000 penalty), HSBC Auto Finance (2016: $434,500, 75 vehicles), COPOCO Community Credit Union (2016 to 2017: $10,000 to each of three, less any unpaid past-due amount and plus lost equity with interest; $7,500 to one whose car was returned the next day, $5,000 of it credited to his and his wife’s loan principal; a $5,000 penalty), CitiFinancial (2017: $907,000 deposited in an interest-bearing escrow account, with undistributed money going to the Treasury, 164 accounts, no civil penalty), Westlake and Wilshire (2017: $700,000 deposited in escrow to pay $10,000 per repossession plus lost equity, with more to be added if needed, $60,788 penalty, at least 66 vehicles plus at least four by Wilshire), California Auto Finance (2018 to 2019: $30,000 to one servicemember, $50,000 penalty), Hudson Valley FCU (2018: $65,000 deposited in escrow to pay $10,000 to each of six and $5,000 to one, each plus lost equity with interest, $30,000 penalty), Nissan Motor Acceptance (2019: $2,937,971 plus a $62,029 penalty, $3 million in total, 113 servicemembers’ vehicles plus lease refunds), GM Financial (2022: $3,534,171 deposited in an interest-bearing escrow account, an amount the order let change after GM Financial’s data review, plus a $65,480 penalty, 71 vehicles plus more than 1,000 mishandled lease terminations), Hyundai Capital America (2024: $10,000 for each servicemember-owner on each of 26 accounts plus lost equity with interest on retail accounts, $74,941 penalty), 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 vehicle leases).

Sum: $16,038,887. Santander 352 × $5,000; Wells Fargo Dealer Services $10,183,950 + $60,000; HSBC $434,500; COPOCO $7,500 + $5,000; CitiFinancial $0; Westlake $60,788; California Auto Finance $30,000 + $50,000; Hudson Valley $30,000; Nissan $2,937,971 + $62,029; GM Financial $65,480; Hyundai $74,941; New City $60,000; CarMax $79,380; Holmes Motors $77,348 + $60,000. Not summed: Santander’s “at least $9.35 million” and its $10,000 plus lost equity to each of 760; Wells Fargo’s earlier “over $4.1 million” and “additional $5.4 million,” which the $10,183,950 total replaces; COPOCO’s $10,000 to each of three, less any unpaid past-due amount, plus lost equity with interest; CitiFinancial’s $907,000 escrow; Westlake’s $700,000 escrow; Hudson Valley’s $65,000 escrow, which pays $10,000 to each of six and $5,000 to one, each plus lost equity with interest; GM Financial’s $3,534,171 escrow; Hyundai’s $10,000 per servicemember-owner plus lost equity, because the record does not state how many owners; New City’s “at least $60,000”; CarMax’s “at least $420,000.” 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 in escrow for 13 plus $17,500), Twin Creek Apartments (2018, $76,516 in escrow for 65 plus $20,000), Levenson (2020, $3,000 plus $500), Western Rim Investors (2020, $71,149.50 in escrow for at least 41 charged and at least four denied, plus $64,715), Integrity Asset Management (2022, $45,325.59 in escrow plus $62,029), FPI Management (2023, $51,587 in escrow for nine plus $22,500), JAG Management (2023, $41,581.95 in escrow plus $20,000), RedSail (2024, $10,225.65 plus $3,000), Greystar (2025, $1.35 million set aside, including triple damages to those who paid, plus a $77,370 penalty), and JWB Property Management (2025, $39,168.50 to six plus $25,000). Three vehicle lessors: BMW Financial Services (2018, $2,165,518.84 to 492 plus $60,788), American Honda Finance (2021, up to $1,585,803.89 for 714, a cap on total payments, plus $64,715), and Chrysler Capital (2021, $94,282.62 to ten plus $40,000, rejected terminations).

Sum: $2,796,402.61. Crowe $1,425 + $475; BMW $2,165,518.84 + $60,788; United Communities $17,500; Twin Creek $20,000; Belshaw $2,595 + $1,595; Levenson $3,000 + $500; Western Rim $64,715; American Honda $64,715; Chrysler Capital $94,282.62 + $40,000; Integrity $62,029; FPI $22,500; JAG $20,000; RedSail $10,225.65 + $3,000; Greystar $77,370; JWB $39,168.50 + $25,000. Not summed: United Communities’ $45,001.78 escrow; Twin Creek’s $76,516 escrow (DOJ’s case page prints $75,615); Western Rim’s $71,149.50 escrow (DOJ’s case page says “over $71,000”); Integrity’s $45,325.59 escrow; JAG’s $41,581.95 escrow; FPI’s $51,587 escrow; American Honda’s “up to $1,585,803.89”; Greystar’s $1.35 million set aside. 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. San Diego Family Housing and Lincoln Military Property Management (2016: $200,000 in total, $35,000 to each of four servicemembers and a $60,000 penalty, plus motions to vacate the default judgments; DOJ called it the first case it had filed alleging the unlawful eviction of servicemembers), PRG Real Estate Management (2019: up to $1,498,000 for 152 default judgments against 127 servicemembers, which DOJ’s own page gives as up to $1,490,000, plus $34,920.39 to 10 servicemembers charged termination fees and a $62,029 penalty), New Jersey Higher Education Student Assistance Authority (2021: $15,000 to each of two, $20,000 penalty), Chesapeake Coveside Lane Apartments (2022: $225,000 in total per DOJ, a $162,971 settlement fund and a $62,029 penalty, plus motions to set aside the judgments), Goines Towing (2023 to 2024: $35,305.06 for seven servicemembers and $1,500 plus a returned car for an eighth, with the eight’s funds capped at $36,805.06, plus $30,000, vehicles disposed of under judgments obtained without proper military affidavits), 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: $541,783.45. San Diego Family Housing $140,000 + $60,000; PRG $34,920.39 + $62,029; New Jersey Higher Education 2 × $15,000 + $20,000; Chesapeake Coveside $62,029; Goines $35,305.06 + $1,500 + $30,000; Rental Marketing Solutions $60,000 + $6,000. Not summed: PRG’s “up to $1,498,000”; Chesapeake’s $162,971 settlement fund and the $225,000 total that contains it; Goines’s $36,805.06 cap on the eight servicemembers’ funds, which is the two Goines figures added above, and the “$66,805.06 in relief” on DOJ’s case page and release, which the consent order does not state. 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 advance payments for time after the termination refunded within 60 days, except for the rest of the billing period in which service ends (§ 3956(e)(1), (f)). The violation is a notice rule or fee the contract carries for everyone, applied to servicemembers anyway.

Who. Teleguam Holdings (GTA) (2025: $450,000 in compensation, including double damages to those who paid, plus a $50,000 penalty, where DOJ alleged early termination charges on over 1,300 servicemembers) and ADT (2026: $1,260,000 deposited in an interest-bearing escrow fund to compensate the servicemembers, which ADT must add to as necessary and whose unpaid balance goes to the Treasury after four years, plus a $79,380 penalty, where DOJ alleged a 30-day notice requirement imposed on at least 3,400 servicemembers).

Sum: $579,380. Teleguam $450,000 + $50,000; ADT $79,380. Not summed: ADT’s $1,260,000 escrow fund. 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 and their towing contractors auctioning or otherwise disposing of cars and belongings, often while the owner was deployed.

Who. Honolulu and All Island Automotive Towing (2018: $55,857.95 to three servicemembers, a $150,000 fund for others with any remainder returning to Honolulu, and a $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 in four installments plus $5,000), City of San Antonio (2020: $29,000 and $18,000 to two servicemembers, a $150,000 settlement fund, and a $62,029 penalty), ASAP Towing (2020: up to $99,500 for at least 33 servicemembers, with total checks capped at that figure, plus $20,000), United Tows (2020 to 2021: $20,000 to one airman and up to $20,000 shared by four more, plus $10,000), Black and White Towing (2021: $22,000 plus $5,000), Steve’s Towing (2022 to 2023: $90,000 in total, $67,500 in damages, up to $12,500 for servicemembers not yet identified, and a $10,000 penalty), El Paso and its two contractors (2023 to 2025: settlement funds of $57,935 from United Road Towing and $140,000 from Rod Robertson Enterprises, penalties of $24,980, $20,000, and $20,000 across three settlements, at least 176 vehicles), Todisco Towing (2023: $5,000 plus $1,000), Morningstar Storage (2024: $80,000 to one servicemember and $5,000 each to two more, plus $40,000), Vehicle Management Solutions (2026: $20,000 to one sergeant and a $200,000 settlement fund, which DOJ’s case page describes as $220,000 to compensate the servicemembers, plus $60,000, approximately 93 vehicles), and S & K Towing (2026: $160,000 deposited in a settlement fund and no civil penalty, as many as 148 vehicles).

Sum: $776,154.95. Honolulu $55,857.95 + $60,788; Shur-Way $20,000 + $10,000; Target Recovery $17,500 + $2,500; Father & Son $60,000 + $5,000; San Antonio $29,000 + $18,000 + $62,029; ASAP $20,000; United Tows $20,000 + $10,000; Black and White $22,000 + $5,000; Steve’s $67,500 + $10,000; El Paso $24,980 + $20,000 + $20,000; Todisco $5,000 + $1,000; Morningstar $80,000 + 2 × $5,000 + $40,000; Vehicle Management Solutions $20,000 + $60,000; S & K $0. Not summed: Honolulu’s $150,000 fund; San Antonio’s $150,000 settlement fund, and the $259,000 total on DOJ’s case page, which the consent order does not state and its four figures do not equal; ASAP’s “up to $99,500”; United Tows’ “up to” $20,000 for four servicemembers and the $40,000 total on DOJ’s case page that contains it; Steve’s “up to $12,500” and the $90,000 total that contains it; El Paso’s $57,935 and $140,000 settlement funds; VMS’s $200,000 settlement fund and the $220,000 that contains it; S & K’s $160,000 settlement fund. Small money per case, but towing ties repossession as 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’ penalties were $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 , or read § 4041 in plain English, with its enforcement record .