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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

_____________________________________

UNITED STATES OF AMERICA,

Plaintiff,

v.

AMERICREDIT FINANCIAL 

SERVICES, INC. dba GM FINANCIAL,

Defendant.

CIVIL ACTION NO. 4:22-cv-887-P

CONSENT ORDER

I. INTRODUCTION

1. This Consent Order resolves the allegations contained in the United 

States’ Complaint that Defendant AmeriCredit Financial Services, Inc. 

dba GM Financial (“GM Financial”) violated the Servicemembers Civil 

Relief Act (“SCRA”), 50 U.S.C. § 3901, et seq., by: (1) rejecting 

requests from qualified servicemembers to terminate their motor 

vehicle leases early pursuant to the SCRA, see 50 U.S.C. § 3955; (2) 

failing to correctly process, in accordance with 50 U.S.C. § 3955, the 

early termination of servicemembers’ motor vehicle leases that were 

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accepted; and (3) repossessing motor vehicles from servicemembers 

without court orders, see 50 U.S.C. § 3952.

2. AmeriCredit Financial Services, Inc. is a Texas corporation, with its 

headquarters at 801 Cherry Street, Suite 3500, Fort Worth, Texas, in the 

Northern District of Texas. It does business as GM Financial and as 

AmeriCredit.

3. This Consent Order covers all requests for SCRA early lease 

terminations for motor vehicle leases entered into by, or assigned to, 

GM Financial or any subsidiaries, predecessors, acquired companies, or 

successor entities from January 1, 2015 through the effective date of 

this Consent Order.

4. This Consent Order covers all motor vehicle repossessions occurring 

from January 1, 2015 through the effective date of this Consent Order 

in connection with contracts originated, acquired, and/or serviced by 

GM Financial, or any subsidiaries, predecessors, acquired companies, 

or successor entities.

5. The United States and GM Financial (collectively, the “Parties”) agree 

that the Court has jurisdiction over the subject matter of this case 

pursuant to 28 U.S.C. § 1331, 28 U.S.C. § 1345, and 50 U.S.C. § 4041.

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6. The Parties agree that, to avoid costly and protracted litigation, the 

claims against GM Financial should be resolved without further 

proceedings or an evidentiary hearing. Therefore, as indicated by the 

signatures appearing below, the Parties agree to the entry of this 

Consent Order. GM Financial neither admits nor denies any of the 

allegations in the United States’ Complaint or this Consent Order. 

7. The effective date of this Consent Order will be the date on which it is 

approved and entered by the Court.

It is hereby ORDERED, ADJUDGED and DECREED:

II. INJUNCTIVE RELIEF1

8. GM Financial and its affiliates, subsidiaries, officers, employees, 

agents, and representatives (including contractors and vendors acting on 

behalf of GM Financial) shall be required to: 

a. allow servicemembers who meet the requirements of 50 U.S.C. § 

3955 to terminate their motor vehicle leases early without penalty 

upon receipt of qualifying military orders;

1 Nothing in this Consent Order shall preclude GM Financial from offering greater protections to 

servicemembers than those afforded by the Consent Order or the SCRA.

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b. process motor vehicle lease terminations and refund lease 

amounts paid in advance within 30 days of the effective date of 

the termination; and

c. comply fully with all relevant provisions of the SCRA 

prohibiting the repossession of motor vehicles of “SCRAprotected servicemembers”2 without a court order, while the 

servicemember is in military service, provided the 

servicemember paid a deposit on the motor vehicle or installment 

on the loan while not in military service.

III. SCRA POLICIES AND PROCEDURES 

A. Motor Vehicle Lease Terminations

9. GM Financial has provided to the United States SCRA policies and 

procedures for motor vehicle lease terminations in compliance with 

Section 3955 of the SCRA, 50 U.S.C. § 3955. These policies and 

procedures have been reviewed by the United States. No additional 

2 For purposes of the repossession-related relief in this Consent Order, the term “SCRA- protected servicemember” includes servicemembers as defined in 50 U.S.C. § 3911(1) and (2) 

who made a deposit or at least one installment payment before entering military service. See 50 

U.S.C. § 3952(a). The SCRA grants additional periods of protection for reservists ordered to 

report for military service and persons ordered to report for induction. 50 U.S.C. § 3917. 

Therefore, for purposes of this Consent Order, these “early alert” periods shall be included in the 

periods of protection for servicemembers at the time of repossession. However, since such 

periods are not included in the definition of “military service” in 50 U.S.C. § 3911, they are not 

considered military service at the time of payment of a deposit on the motor vehicle or 

installment on the loan.

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modifications to GM Financial’s policies are required by this Consent 

Order. GM Financial’s policies and procedures include provisions:

a. permitting servicemembers to terminate their motor vehicle 

leases where:

i. the lease is executed by or on behalf of a person who thereafter 

and during the term of the lease enters military service under a 

call or order specifying a period of not less than 180 days (or 

who enters military service under a call or order specifying a 

period of 180 days or less and who, without a break in service, 

receives orders extending the period of military service to a 

period of not less than 180 days), see 50 U.S.C. § 

3955(b)(2)(A);

ii. the lessee, while in military service, executes a lease and 

thereafter receives military orders for a permanent change of 

station3 from a location in the continental United States to a 

location outside the continental United States or from a location 

in a State (as defined in 50 U.S.C. § 3911(6)) outside the 

3 The term “permanent change of station” includes separation or retirement from military service.

See 50 U.S.C. § 3955(i)(3). In the case of a separation or retirement, a servicemember shall be 

entitled to terminate their motor vehicle lease if they are being separated or retired from a 

location in the continental United States to a home of record outside the continental United 

States or from a location in a State outside the continental United States to any home of record 

outside that State.

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continental United States to any location outside that State, see

50 U.S.C. § 3955(b)(2)(B)(i); 

iii. the lessee, while in military service, executes a lease and 

thereafter receives military orders to deploy with a military unit, 

or as an individual in support of a military operation, for a 

period of not less than 180 days, see 50 U.S.C. § 

3955(b)(2)(B)(ii); or

iv. the lessee dies or incurs a catastrophic injury or illness (in this 

case, the spouse or dependent of the lessee may terminate the 

lease within one year after the death or catastrophic injury or 

illness), see 50 U.S.C. § 3955(a)(3)-(4); 

b. approving terminations of leases based on delivery to GM 

Financial or GM Financial’s agent of written notice of 

termination and a copy of military orders (to include any 

notification, certification, or verification from the 

servicemember’s commanding officer), or other document 

prepared exclusively by a branch of the military or the 

Department of Defense demonstrating that the lessee is eligible 

for lease termination under 50 U.S.C. § 3955(b)(2), including by 

hand delivery, private business carrier, U.S. Mail, e-mail, text 

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message, or other electronic means reasonably calculated to 

ensure actual receipt;

c. permitting eligible servicemembers to terminate their motor 

vehicle leases at any time after their entry into military service 

under the circumstances set forth in subparagraph (a)(i), or the 

date of their qualifying military orders as set forth in 

subparagraph (a)(ii) and (a)(iii), see 50 U.S.C. § 3955(a)(1);

d. setting the effective date of the lease termination as the date on 

which the servicemember has completed both delivery of the 

notice of termination and return of the vehicle to GM Financial 

or GM Financial’s agent, see 50 U.S.C. § 3955(d)(2);

e. limiting any charges that must be paid upon termination to those 

permitted by Section 3955(e)(2) of the SCRA; 

f. refunding, within 30 days after the effective date of termination, 

all lease amounts paid in advance (including cash payments and 

trade-in value applied as capitalized cost reduction (“CCR”)) for 

a period after the effective date of termination, see 50 U.S.C. § 

3955(f); and

g. designating customer service representatives who have been 

specifically trained on the protections of the SCRA with respect 

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to motor vehicle leases and who are responsible for the intake of 

and response to servicemembers’ inquiries regarding the SCRA. 

GM Financial shall ensure that it has a telephone number and 

designated electronic mail address at which servicemembers may 

reach a designated SCRA customer service representative, who 

will address questions or concerns regarding the SCRA. GM 

Financial shall also include a page on its website detailing 

eligibility for, and relief provided by, the SCRA, and providing 

the telephone number and designated electronic mail address to 

obtain SCRA relief or raise questions or concerns regarding such 

relief.

B. Motor Vehicle Repossessions

10. GM Financial has provided to the United States SCRA policies and 

procedures for motor vehicle repossessions in compliance with Section 

3952(a) of the SCRA, 50 U.S.C. § 3952(a). These policies and 

procedures have been reviewed by the United States. No additional 

modifications to GM Financial’s SCRA policies are required by this 

Consent Order. GM Financial’s SCRA policies and procedures include 

provisions:

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a. To determine whether the borrower4 or lessee is an SCRAprotected servicemember, GM Financial shall (1) search the 

Defense Department’s Defense Manpower Data Center 

(DMDC) database, located at https://scra.dmdc.osd.mil/, for 

evidence of SCRA eligibility by either last name and social 

security number or last name and date of birth, and (2) review 

any military service information (including orders) they have 

received from borrowers, at the following times:

(i) no more than two (2) business days before it refers a motor 

vehicle loan for repossession; 

(ii) no more than two (2) business days after it (or its agents, 

including contractors and vendors) obtains possession of the 

motor vehicle; and 

(iii) no more than (2) business days before it (or its agents, 

including contractors and vendors) disposes of the motor 

vehicle.

b. If GM Financial is informed via military service information 

received from a borrower or lessee, or via the periodic 

electronic check of the DMDC described above, that the 

4 For purposes of this Consent Order, the term “borrower” includes co-borrowers.

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borrower is an SCRA-protected servicemember, it shall neither 

refer the loan for repossession nor conduct the repossession 

itself without first obtaining a court order or a valid SCRA 

waiver pursuant to subparagraph (e).

c. If GM Financial discovers, from a check of the DMDC 

database or otherwise, after obtaining possession but before 

disposing of a motor vehicle, that the borrower or lessee is an 

SCRA-protected servicemember, it shall attempt to contact the 

borrower and offer to arrange to return the vehicle within two 

(2) business days and shall reverse on the borrower or lessee’s 

account all of the charges resulting from the repossession. GM 

Financial shall also correct any negative credit reporting related 

to the repossession. If GM Financial cannot make contact with 

the borrower or lessee within two (2) business days, GM 

Financial shall return the vehicle to the location where 

possession was taken, unless: (1) return to such location 

presents a significant risk of damage to the vehicle; (2) return to 

such location presents a significant risk that the vehicle will be 

impounded; (3) the borrower or lessee has previously informed 

GM Financial that the vehicle has been abandoned; or (4) the 

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vehicle was recovered under circumstances suggesting that the 

vehicle had been abandoned. If the vehicle is not returned 

immediately to the borrower, GM Financial shall make 

additional attempts to reach the borrower or lessee based upon 

contact information in its files, and shall return the vehicle 

within two (2) business days of a borrower or lessee’s request 

for return, without charging any repossession-related fees. GM 

Financial shall not sell or otherwise dispose of the vehicle until 

it has made all the contact attempts referenced in this 

subparagraph and has obtained a court order or valid SCRA 

waiver pursuant to subparagraph (e). 

d. If GM Financial files a complaint for repossession in court and 

the borrower does not make an appearance in the case, GM 

Financial will file an affidavit of military service with the court 

as required by Section 3931(b)(1) of the SCRA, 50 U.S.C. § 

3931(b)(1). Before seeking entry of default, GM Financial will 

search the DMDC database and review information in its 

possession or control to determine if the borrower or lessee is 

SCRA-protected. If GM Financial learns that the borrower or 

lessee is SCRA-protected, it will file an affidavit stating that 

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“the defendant is in military service,” attaching the most recent 

military status report from the DMDC or a copy of the military 

orders or other documentation to the affidavit.

e. If GM Financial seeks or obtains a waiver under a written 

agreement as provided in 50 U.S.C. § 3918, it shall use a notice 

and waiver in the form attached as Exhibit A.5

f. Upon receiving notice of impoundment by a non-related third 

party, GM Financial may take possession of the vehicle even if 

the borrower is protected by the SCRA, but must comply with 

any applicable state laws and must not dispose of the vehicle 

until it has made reasonable efforts to contact the 

servicemember and has obtained a court order or valid SCRA 

waiver.

C. Review and Approval of Policies and Procedures

11. If, at any time during the term of this Consent Order, GM Financial 

proposes to materially change its SCRA policies and procedures, it shall 

first provide a copy of the proposed changes to counsel for the United 

5 GM Financial shall not seek to obtain waivers from servicemembers with respect to their early 

lease termination rights under Section 3955 of the SCRA.

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States.6 If the United States does not deliver written objections to GM 

Financial within forty-five (45) calendar days of receiving the proposed 

changes, the changes may be implemented. If the United States objects 

to any part of GM Financial’s policies and procedures, the Parties shall 

confer to resolve their differences. If the Parties cannot resolve their 

differences after good faith efforts to do so, either Party may bring the 

dispute to this Court for resolution.

IV. TRAINING

12. GM Financial has provided to the United States the curriculum, 

instructions, and any written materials included in the training required 

by Paragraphs 13 and 14. The United States has no objection to these 

materials. 

13. GM Financial shall provide SCRA compliance training, within ninety 

(90) calendar days after the effective date of this Consent Order to any 

active employees who: (a) provide customer service to borrowers or 

lessees in connection with their motor vehicle loans or leases, (b) have 

significant involvement in motor vehicle leasing, including the ability 

6 All notices and materials required by this Consent Order to be sent to counsel for the United 

States shall be sent by private business carrier (non-USPS) delivery service addressed as follows: 

Chief, Housing & Civil Enforcement Section, Civil Rights Division, United States Department 

of Justice, 150 M Street, N.E., Washington, DC 20002, Attn: DJ 216-73-9, or as otherwise 

directed by the United States. Correspondence may also be sent via electronic mail to the U.S. 

Department of Justice, care of the undersigned counsel for the United States.

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to terminate motor vehicle leases for servicemembers; or (c) are 

involved in the repossession of motor vehicles. GM Financial shall 

provide to each covered employee: (a) training on the terms of the 

SCRA with respect to lease terminations and repossessions; (b) training 

on GM Financial’s SCRA policies and procedures (both those required 

pursuant to Paragraphs 9 and 10 and all others adopted by GM 

Financial) specific to the employee’s responsibilities associated with 

that employee’s position; (c) training on the terms of this Consent 

Order; and (d) the contact information for the SCRA customer service 

representatives described in Paragraph 9(g). GM Financial shall also 

follow these training procedures for any employee who subsequently 

becomes a covered employee within thirty (30) calendar days of their 

hiring, promotion, or transfer.

14. During the term of this Consent Order, GM Financial shall provide 

annual SCRA training, with the same content as described in Paragraph 

13, to covered employees with respect to their responsibilities and 

obligations under the SCRA, GM Financial’s SCRA policies and 

procedures, and this Consent Order.

15. The covered employees may undergo the training required by 

Paragraphs 13 and 14 via live training, computer-based training, webCase 4:22-cv-00887-P Document 5 Filed 10/03/22 Page 14 of 45 PageID 81
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based training, or interactive digital media. If the training is conducted 

in any format other than live training, GM Financial shall ensure that 

covered employees have the opportunity to have their questions 

answered by a company contact that GM Financial identifies as having 

SCRA expertise within two (2) business days of the training. Any 

expenses associated with the training program required by Paragraphs 

13 and 14 shall be borne by GM Financial.

16. GM Financial shall secure a signed statement in the form attached as 

Exhibit B, either in hard copy or by electronic certification, from each 

covered employee at the training required by Paragraphs 13 and 14

acknowledging that they have received, read, and understand the 

Consent Order and GM Financial’s SCRA policies and procedures 

specific to the employee’s responsibilities associated with the loan 

being serviced, has had the opportunity to have his or her questions 

about these documents answered, and agrees to abide by them. GM 

Financial shall also certify in writing to counsel for the United States 

that the covered employees successfully completed the training required 

by Paragraphs 13 and 14. For the duration of this Consent Order, 

copies of the signed statements shall be provided to the United States 

upon request. 

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V. COMPENSATION

a. Motor Vehicle Lease Termination Denials

17. The United States has reviewed accounts for which GM Financial 

denied early lease termination pursuant to the SCRA since January 1, 

2015. Based on this review, the United States has identified fourteen 

(14) instances where it believes GM Financial wrongfully denied SCRA 

early termination requests and has provided a list of those instances to 

GM Financial. 

18. GM Financial shall compensate the lessees identified pursuant to 

Paragraph 17 as follows:

a. The amount of any lease payments and other charges (other than 

taxes, summonses, title and registration fees, or other obligations 

and liabilities of the lessee in accordance with the terms of the 

lease, including reasonable charges to the lessee for excess wear 

or use and mileage, that are due and unpaid at the time of 

termination) paid by the servicemember after the earliest of (i) 

the date the lessee returned the vehicle; (ii) the date GM 

Financial denied the request for early termination; or (iii) fifteen 

(15) days after submission of written notice of termination and a 

copy of the servicemember’s military orders;

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b. Lease amounts paid in advance (including eligible CCR amounts 

using the formula set forth in Paragraph 22(c) below) for a period 

after the earliest of (i) the date the lessee returned the vehicle; (ii) 

the date GM Financial denied the request for early termination; 

or (iii) fifteen (15) days after submission of written notice of 

termination and a copy of the servicemember’s military orders; 

and

c. An additional payment of $5,000 for any servicemembers 

identified pursuant to Paragraph 17 who returned their vehicles.

The compensation described in subparagraphs (a) and (b) shall be 

distributed equally among the lessees (including non-servicemember 

co-lessees) named on the lease. The compensation described in 

subparagraph (c) shall be paid entirely to the servicemember. The 

United States has provided to GM Financial the names of and amounts 

owed under this paragraph to the servicemembers whose early 

termination requests it believes were wrongfully denied. In cases where 

GM Financial has already taken remedial actions with respect to a lease 

termination, the United States has considered such remedial actions and 

adjusted the compensation awarded to the servicemember or co-lessee.

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19. GM Financial must deliver payment to each servicemember and colessee, except for those servicemembers and co-lessees currently 

residing in Oregon, in the amount calculated pursuant to Paragraph 18

within forty-five (45) days of the effective date of this Consent Order. 

20. All compensation checks may include the phrase “Settlement in Full” in 

the memorandum section. All compensation checks shall be 

accompanied by a copy of a letter (the form of which is to be approved 

in advance by the United States) explaining that cashing or endorsing 

the check releases all claims related to the SCRA Section 3955 

violations alleged in the complaint. 

21. For servicemembers and co-lessees currently residing in Oregon, GM 

Financial shall send a letter (the form of which is to be approved in 

advance by the United States) containing a Release in the form attached 

as Exhibit C within forty-five (45) days of the effective date of this 

Consent Order. Within thirty (30) days of receiving a properly 

executed copy of the Release at Exhibit C, GM Financial shall issue and 

mail a compensation check to the servicemember or co-lessee in the 

amount calculated pursuant to this Consent Order. 

b. Motor Vehicle Lease Termination Approvals

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22. The United States has reviewed accounts for which GM Financial 

permitted early lease termination pursuant to the SCRA since January 1, 

2015. GM Financial shall refund to the lessees on these accounts the 

following amounts (to the extent not already refunded):

a. The amount of any lease payments and other charges (other than 

taxes, summonses, title and registration fees, or other obligations 

and liabilities of the lessee in accordance with the terms of the 

lease, including reasonable charges to the lessee for excess wear 

or use and mileage, that are due and unpaid at the time of 

termination) paid by the servicemember after the effective date of 

the lease termination that were not refunded within thirty (30) 

days of payment;

b. Non-CCR lease amounts paid in advance for a period after the 

effective date of the termination of the lease7

; and

c. CCR amounts, less the amount of any: 

i. manufacturer rebates or other rebates and incentives offered by 

GM Financial, an individual dealer, insurer, governmental 

7 As used in this sub-part, such payments are specifically limited to the periodic or monthly 

payments identified in the lease agreements and paid in advance of termination. When a lease 

termination occurs in the middle of a payment period, a refund must be provided on a pro rata

basis.

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entity, or other third party, or other credits not based on a cash 

payment or trade-in value;

ii. payoff of negative equity or prior lease balance amounts by the 

originating automobile dealer or other third party, to the extent 

included in the gross capitalized cost; 

iii. payment for maintenance or other vehicle- or lessee-protection 

agreements, to the extent included in the gross capitalized cost, 

if the servicemember is entitled to obtain a refund upon lease 

termination for unused periods covered by such agreements 

pursuant to state law or other agreement; 

iv. acquisition fee paid and included in the gross capitalized cost; 

and

v. tax, title and license fee included in the gross capitalized cost.

GM Financial shall refund CCR amounts on a pro rata basis by: (a) 

multiplying the CCR amount subject to refund (i.e., after subtracting 

the amounts in subparagraphs (b)(i)-(v)) by the amount of time 

remaining in the lease term at termination, (b) dividing the product by 

the total lease term, and then (c) subtracting (i) any monthly or other 

periodic payments incurred prior to the date of termination that remain 

unpaid, (ii) any reasonable charges for excess wear and mileage that 

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remain unpaid, and (iii) any refund of CCR amounts provided by GM 

Financial within thirty (30) days after the effective date of the 

termination of the lease.8

23. GM Financial shall compensate the individual lessees covered by this 

Consent Order by providing: (1) a refund of the amount calculated 

pursuant to Paragraph 22, plus interest, as calculated pursuant to 28 

U.S.C. § 1961; and (2) an additional payment of indirect damages in the 

amount of $500, or three times the amount calculated pursuant to 

Paragraph 22, whichever is larger. GM Financial is not, however, 

required to provide any compensation to individual lessees for whom 

the amount calculated pursuant to Paragraph 22 is less than $25. The 

compensation described in subsection (1) shall be distributed equally 

among the lessees (including non-servicemember co-lessees) named on 

the lease. The compensation described in subsection (2) shall be paid 

entirely to the servicemember (or servicemembers). In cases where GM 

Financial has already taken remedial actions with respect to a lease 

termination, the United States has considered such remedial actions and 

8 GM Financial shall not seek to collect any amounts deducted pursuant to this Paragraph – or 

any interest, late fees, penalties, or other charges related thereto – from the servicemember.

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agreed to allow GM Financial to adjust the compensation awarded to 

the servicemember or co-lessee.

24. GM Financial must deliver payment to each servicemember and colessee, except for those servicemembers and co-lessees currently 

residing in Oregon, in the amount calculated pursuant to Paragraph 23 

within forty-five (45) days of the effective date of this Consent Order. 

25. With respect to compensation required by Paragraph 23, GM Financial 

shall adhere to the process set forth in Paragraphs 20 and 21.

c. Motor Vehicle Repossessions

26. The United States has reviewed accounts for which GM Financial 

conducted motor vehicle repossessions without a court order since 

January 1, 2015. The United States has determined that GM Financial 

conducted seventy-one (71) motor vehicle repossessions since January 

1, 2015, that violated the SCRA. The United States has provided a list 

of those repossessions to GM Financial. 

27. For each account identified pursuant to Paragraph 26, GM Financial 

agrees to provide the following compensation:

a. An amount of $10,000;

b. Any lost equity in the repossessed motor vehicle, as calculated 

by: subtracting any outstanding principal, interest, and other 

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amounts owing by the borrowers (excluding any fees associated 

with the repossession), plus any liens at the time of repossession 

and any disbursements made to the servicemember or a thirdparty other than a lien holder from the proceeds of the 

repossession sale (exclusive of any fees associated with the 

repossession) from the retail value of the motor vehicle at the 

time of repossession as identified in the National Automobile 

Dealers Association (“NADA”) Guide; and

c. Interest accrued on this lost equity, calculated from the date of 

the repossession sale until the date payment is issued, at the rate 

set forth in 28 U.S.C. § 1961.

GM Financial shall provide the United States with all records used to 

make the payment calculations described in this Paragraph for the 

United States’ review and approval. In cases where GM Financial has 

already taken remedial actions with respect to a repossession that 

violated the SCRA, the United States shall consider such remedial 

actions and adjust the compensation to be awarded. In the event of a 

dispute regarding the compensation to be awarded, the Parties will meet 

and confer prior to bringing the matter to the Court.

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28. The amount described in Paragraph 27(a) shall be paid entirely to the 

SCRA-protected servicemember who is identified on the note securing 

the motor vehicle or lease. The amounts described in Paragraph 27(b) 

and (c) shall be distributed equally among all owners (including any 

non-SCRA-protected owners) on the title to the motor vehicle. 

29. For non-SCRA compliant repossessions identified pursuant to 

Paragraph 26, GM Financial shall notify each identified servicemember 

by letter (the form of which is to be approved in advance by the United 

States) within thirty (30) calendar days of the entry of this Consent 

Order. Each letter shall enclose the Declaration at Exhibit D and the 

Release at Exhibit E.

30. In order to receive any compensation under Paragraph 27, SCRAprotected servicemembers must complete the Declaration at Exhibit D 

and the Release at Exhibit E.

31. GM Financial must deliver payment to each servicemember and coowner, except for those co-owners currently residing in Oregon, in the 

amount calculated pursuant to Paragraphs 27 and 28, within twenty-one 

(21) days of receiving a signed Declaration and Release from the 

servicemember.

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32. All compensation checks may include the phrase “Settlement in Full” in 

the memorandum section. All compensation checks for co-owners not 

currently residing in Oregon shall be accompanied by a copy of a letter 

(the form of which is to be approved in advance by the United States) 

explaining that cashing or endorsing the check releases all claims 

related to the SCRA Section 3955 violations alleged in the complaint. 

33. For co-owners currently residing in Oregon, GM Financial shall send a 

letter (the form of which is to be approved in advance by the United 

States) containing a Release in the form attached as Exhibit E within 

twenty-one (21) days of receiving a signed Declaration and Release 

from the servicemember on the lease. Within thirty (30) days of 

receiving a properly executed copy of the Release at Exhibit E from the 

co-owner, GM Financial shall issue and mail a compensation check to 

the co-owner in the amount calculated pursuant to Paragraphs 27 and 

28. 

34. The servicemembers identified pursuant to Paragraph 26 shall have 

three and a half (3.5) years from the date of notification to provide the 

Declaration and Release. 

d. General Provisions

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35. Within fourteen (14) days of the effective date of this Consent Order, 

GM Financial shall deposit $3,534,171 into an interest-bearing escrow 

account for the purpose of fulfilling its obligations under Paragraphs 18, 

23, and 27. GM Financial shall provide written verification of the 

deposit to the United States within three (3) business days of depositing 

the funds described in this Paragraph. Any taxes, costs, or other fees 

incurred on the escrow funds shall be paid by GM Financial. GM 

Financial is in the process of conducting an internal review of account 

data, including data from legacy computer systems, which it anticipates 

will be complete within 30 days. This review may lead to 

recalculations of the compensation owed to certain servicemembers 

under Paragraph 23. If that review results in additional funds being 

owed to servicemembers under Paragraph 23, GM Financial shall add 

funds to the escrow account as necessary to meet its obligations under 

this Consent Order. If, on the other hand, that review results in a 

reduced amount of funds being owed to servicemembers under 

Paragraph 23, the United States will permit GM Financial to withdraw 

the unallocated funds from the escrow account.

36. GM Financial shall provide the United States with samples of all letters, 

and receive the United States’ approval of those letters, before mailing 

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any letter required by this Consent Order to individuals entitled to 

compensation.

37. GM Financial shall promptly skip trace and redeliver or reissue any 

payment or notification that is returned as undeliverable, or that is not 

deposited, cashed, or returned within three (3) months of the date the 

initial payment is sent. 

38. Servicemembers, co-lessees, and co-owners shall have six (6) months 

after issuance to cash or deposit their compensation checks. During the 

term of this Consent Order, GM Financial shall, upon the request of a 

servicemember, co-lessee, or co-owner entitled to compensation, or 

upon the request of the counsel for the United States, reissue any checks 

that are not cashed or deposited prior to their expiration.

39. Every six (6) months for a period of three and a half (3.5) years 

following the mailing of notices to those who are entitled to 

compensation, GM Financial shall provide the DOJ with an accounting 

of all releases received, checks issued, checks cashed or deposited 

(including check copies), and notifications without responses or that 

were returned as undeliverable.

40. Any amounts in the escrow account required by Paragraph 35 that have 

not been distributed to aggrieved persons within four (4) years of the 

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date of this Consent Order shall be paid to the United States Treasury in 

the form of an electronic funds transfer pursuant to written instructions 

to be provided by the United States. 

41. No individual may obtain review by the Parties of the identifications 

made, and payments disbursed (including the amounts thereof), 

pursuant to the Consent Order. 

VI. OTHER RELIEF

42. Within sixty (60) calendar days following the effective date of this 

Consent Order, GM Financial must request that all the credit bureaus to 

which it reports remove negative entries for the servicemember(s) and 

any co-lessee(s) attributable to non-payment of any amounts that would 

not have been owed if GM Financial had permitted early termination 

under the SCRA. 

43. Within sixty (60) calendar days following the effective date of this 

Consent Order, GM Financial shall also request that all the credit 

bureaus to which it reports delete trade lines for accounts belonging to 

servicemember(s) and any co-borrowers (or co-lessees) attributable 

specifically to the wrongful repossessions addressed in this Consent 

Order. Further, GM Financial shall not pursue, must indemnify the 

servicemember and his or her co-borrower(s) (or co-lessee(s)) against 

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any third party’s pursuing, and must refund any amounts the 

servicemember and his or her co-borrower(s) (or co-lessee(s)) have paid 

toward any deficiency that was remaining on the loan or lease after the 

repossession.

44. Within sixty (60) days after completion of its obligations in Paragraph 

42 and 43, GM Financial shall provide the United States with an 

accounting of all credit entries repaired.

VII. CIVIL PENALTY

45. Within thirty (30) calendar days of the effective date of this Consent 

Order, GM Financial shall pay a total of $65,480 to the United States 

Treasury as a civil penalty pursuant to 50 U.S.C. § 4041(b)(3) and 28 

C.F.R. 85.5, to vindicate the public interest. The payment shall be in 

the form of an electronic funds transfer pursuant to written instructions 

to be provided by the United States.

VIII. ADDITIONAL REPORTING AND RECORD-KEEPING 

REQUIREMENTS

46. For the duration of this Consent Order, GM Financial shall retain all 

records relating to its obligations hereunder, including its records with 

respect to all leases for which a servicemember has sought a lease 

termination, all motor vehicle repossessions, and compliance activities 

as set forth herein. The United States shall have the right to review and 

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copy any such records, including electronic data, upon reasonable 

request during the term of this Consent Order.

47. During the term of this Consent Order, GM Financial shall notify 

counsel for the United States in writing every six (6) months of receipt 

of any SCRA or military-related complaint. GM Financial shall 

provide a copy of any written complaints with the notifications. GM 

Financial will incorporate into its SCRA Policies and Procedures a 

requirement that all customer service personnel, upon receiving any 

oral SCRA complaint, shall notify individuals designated and trained to 

receive SCRA complaints. Whether regarding a written or oral SCRA 

complaint, the notification to the United States shall include the full 

details of the complaint, including the complainant’s name, address, 

and telephone number, and the full details of all actions GM Financial 

took to resolve the complaint. GM Financial shall also promptly 

provide the United States all information it may request concerning any 

such complaint. If the United States raises any objections to GM 

Financial’s actions, the parties shall meet and confer to consider 

appropriate steps to address the concerns raised by the United States’ 

review. If the parties are unable to come to an agreement regarding 

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such objections or concerns, either Party may bring the dispute to this 

Court for resolution.

IX. SCOPE OF CONSENT ORDER

48. The provisions of this Consent Order shall apply to GM Financial and 

any of its subsidiaries, predecessors, acquired companies, or successor 

entities. It shall also apply to the officers, employees, agents, 

representatives, assigns, successors-in-interest, and all persons and 

entities in active concert or participation with all of those entities, 

including with respect to any leases and loans they serviced from 

January 1, 2015 to the effective date of this Consent Order.

49. In the event that GM Financial is acquired by or merges with another 

entity, GM Financial shall, as a condition of such acquisition or merger, 

obtain the written agreement of the acquiring or surviving entity to be 

bound by any obligations remaining under this Consent Order for the 

remaining term of this Consent Order.

50. This Consent Order does not release claims for practices not addressed 

in the Complaint’s allegations, and it does not resolve and release 

claims other than claims for violations of Section 3952 of the SCRA 

related to motor vehicle repossessions and Section 3955 of the SCRA 

related to early motor vehicle lease termination requests. This Consent 

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Order does not release any claims that may be held or are currently 

under investigation by any federal agency against GM Financial or any 

of its affiliated entities. 

51. Nothing in this Consent Order will excuse GM Financial’s compliance 

with any currently or subsequently effective provision of law or order 

of a regulator with authority over GM Financial that imposes additional 

obligations on it.

X. LITIGATION HOLD

52. The parties agree that, as of the effective date of this Consent Order, 

litigation is not “reasonably foreseeable” concerning the matters 

described above. To the extent that either party previously 

implemented a litigation hold to preserve documents, electronically 

stored information (ESI), or things related to the matters described 

above, the party is no longer required to maintain such litigation hold. 

Nothing in this Paragraph relieves either party of any other obligations 

imposed by this Consent Order.

XI. MODIFICATIONS, ATTORNEY’S FEES AND COSTS, AND 

REMEDIES FOR NON-COMPLIANCE

53. Any time limits for performance imposed by this Consent Order may be 

extended by the mutual written agreement of the parties.

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54. The parties shall be responsible for their own attorney’s fees and court 

costs, except as provided for in Paragraph 55.

55. The parties shall endeavor in good faith to resolve informally any 

differences regarding the interpretation of and compliance with this 

Consent Order prior to bringing such matters to the Court for 

resolution. However, in the event the United States contends that there 

has been a failure by GM Financial, whether willful or otherwise, to 

perform in a timely manner any act required by this Consent Order or 

otherwise comply with any provision thereof, the United States may 

move the Court to impose any remedy authorized by law or equity, 

including, but not limited to, an order requiring the performance of such 

act or deeming such act to have been performed, and an award of any 

damages, costs, and attorney’s fees which may have been occasioned 

by GM Financial’s violation or failure to perform. 

XI. RETENTION OF JURISDICTION

56. This Consent Order shall be in effect for a period of four (4) years from 

its date of entry. The Court shall retain jurisdiction for the duration of 

this Consent Order to enforce its terms, after which time this case shall 

be dismissed with prejudice. The United States may move the Court to 

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extend the duration of this Consent Order in the interests of justice.

SO ORDERED, this ___ day of __________, ____.

_______________________________

UNITED STATES DISTRICT JUDGE

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The undersigned hereby apply for and consent to the entry of the Order:

For the United States of America:

Dated: September 30, 2022

CHAD E. MEACHAM KRISTEN CLARKE

United States Attorney Assistant Attorney General

Civil Rights Division

_____________________ ________________________

LISA R. HASDAY SAMEENA SHINA MAJEED

Assistant U.S. Attorney Chief

United States Attorney’s Office ELIZABETH A. SINGER 

Northern District of Texas Director, U.S. Attorneys’ Fair 

1100 Commerce Street, Third Floor Housing Program

Dallas, TX 75242-1699 ALAN A. MARTINSON

Telephone: (214) 659-8737 AUDREY M. YAP

Fax: (214) 659-8807 Trial Attorneys

Email: lisa.hasday@usdoj.gov U.S. Department of Justice

Civil Rights Division

Housing and Civil Enforcement 

Section

4 Constitution Square

150 M Street, NE

Washington, D.C. 20530

Telephone: (202) 616-2191

Fax: (202) 514-1116

Email: alan.martinson@usdoj.gov

Attorneys for THE UNITED STATES OF AMERICA

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For AmeriCredit Financial Services, Inc.

dba GM Financial:

_________________________________

Andrew W. Schilling

Brian J. Wegrzyn

Buckley LLP

1133 Avenue of the Americas

Suite 3100

New York, NY

Tel. 212-600-2400

Email: aschilling@buckleyfirm.com

Attorneys for AMERICREDIT FINANCIAL SERVICES, INC. dba GM 

FINANCIAL

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EXHIBIT A

IMPORTANT NOTICE AFFECTING MILITARY SERVICEMEMBERS

RIGHTS AND PROTECTIONS AFFORDED UNDER THE 

SERVICEMEMBERS CIVIL RELIEF ACT

Attached to this notice you will find a waiver of rights and protections that may be 

applicable to you and your dependents pursuant to the Servicemembers Civil 

Relief Act, 50 U.S.C. § 3901, et seq. (the “SCRA”). The SCRA provides military 

personnel and their dependents with a wide range of legal and financial 

protections. Among other benefits and protections, the SCRA: 

• Prohibits the repossession of a servicemember’s motor vehicle without a 

court order during a period of military service, as long as a deposit or at least 

one installment payment was made before the borrower entered into that 

period of military service.

• Upon notice by the servicemember, imposes a 6% maximum rate of interest 

that may be charged during military service on loans incurred before the 

servicemember began his or her current period of military service. 

• Postpones court actions against servicemembers under certain 

circumstances.

• Permits servicemembers to terminate motor vehicle and residential leases 

upon receipt of certain military orders.

If you choose to sign the attached waiver, AmeriCredit Financial Services Inc. dba 

GM Financial (“GM Financial”) will have the option to proceed with a 

repossession of your motor vehicle without the protections of the SCRA. If you do 

not sign this waiver, GM Financial will be required to provide you the protections 

of the SCRA if you took out your loan and made a down payment on the motor 

vehicle, or at least one payment on the loan, when you were not in military service. 

Additionally, if GM Financial goes to court to repossess your motor vehicle, the 

court may take steps to ensure that a judgment is not entered against you if you are 

unable to appear in the case.

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This waiver applies only to your SCRA rights related to motor vehicle 

repossessions; you are not waiving any other SCRA protections that you may have. 

Before waiving these important statutory rights, you should consult an attorney 

regarding how best to exercise your rights or whether it is in your interest to waive 

these rights under the conditions offered by GM Financial.

For More Information: 

• CONSULT AN ATTORNEY: To fully understand your rights under the 

law, and before waiving your rights, you should consult an attorney. 

• JAG / LEGAL ASSISTANCE: Servicemembers and their dependents with 

questions about the SCRA should contact their unit’s Judge Advocate, or 

their installation’s Legal Assistance Officer. A military legal assistance 

office locator for all branches of the Armed Forces is available at 

http://legalassistance.law.af.mil. 

• MILITARY ONESOURCE: “Military OneSource” is the U.S. Department 

of Defense’s information resource. Go to 

http://www.militaryonesource.com.

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AGREEMENT AND WAIVER OF RIGHTS UNDER

SERVICEMEMBERS CIVIL RELIEF ACT

I __________________________ am a Servicemember OR the duly authorized 

agent or attorney-in-fact of ______________________ , a Servicemember, 

pursuant to a power of attorney dated ___________________and I am aware that I 

have protections available to me under the Servicemembers Civil Relief Act 

(SCRA). This includes, but is not limited to, the right not to have a lender 

repossess my motor vehicle or personal property without a court order. 

By signing this waiver, I acknowledge and agree that:

• I have read and understood the attached IMPORTANT NOTICE TO 

MILITARY SERVICEMEMBERS.

• I am waiving my right to have a court rule on whether AmeriCredit 

Financial Services, Inc. dba GM Financial (“GM Financial”) can repossess 

my motor vehicle, a [YEAR] [MAKE] [MODEL] [VIN] (the “Vehicle”), in 

accordance with 50 U.S.C. § 3952(a)(1).

• I understand that if the vehicle sells for less than I still owe on the loan, I 

may be responsible for the difference (“deficiency balance”), plus accrued 

interest. 

• In exchange for waiving my SCRA rights with respect to the Vehicle, GM 

Financial agrees to waive the recovery of any storage costs, attorneys’ fees, 

and any other fees and costs incurred in connection with the repossession or 

sale of the vehicle. GM Financial will also instruct any third party in 

possession of the vehicle to return any personal property I left in my vehicle.

• This Waiver shall have no effect on my right to receive any excess proceeds 

from the sale of the Vehicle as provided by state law.

• This waiver is made voluntarily, without coercion, duress or compulsion. I 

understand the terms of this waiver of rights, and acknowledge that I was 

advised to consult with an attorney regarding this waiver and the protections 

afforded by the SCRA.

Subject to the above provisions, I hereby waive and give up any right I may have 

to have a court rule on the repossession of the Vehicle.

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Dated: _________________ By: 

_____________________________

 Signature

 

______________________________

 Print Name

For: AmeriCredit Financial Services. 

Inc. dba GM Financial

Dated: _________________ By: 

______________________________ 

 Signature

 

______________________________

 Print Name

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EXHIBIT B

EMPLOYEE ACKNOWLEDGMENT

I acknowledge that on [INSERT DATE], I was provided training regarding 

Servicemembers Civil Relief Act (SCRA) compliance, a copy of the Consent 

Order resolving the United States’ allegations in United States v. AmeriCredit 

Financial Services, Inc. dba GM Financial, Case No. [INSERT CASE NUMBER] 

(N.D. Tex.), and copies of GM Financial’s policies and procedures applicable to 

my duties. I have read and understand these documents and have had my questions 

about these documents and the SCRA answered. I understand my legal 

responsibilities and shall comply with those responsibilities. 

____________________________________ 

[PRINT NAME]

 

____________________________________ 

[SIGNATURE]

 

____________________________________ 

[JOB TITLE]

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EXHIBIT C

RELEASE – Lease Terminations (for Oregon residents)

Pursuant to the Consent Order resolving the United States’ allegations in 

United States v. AmeriCredit Financial Services, Inc. dba GM Financial, Case No. 

[INSERT CASE NUMBER] (N.D. Tex.), that AmeriCredit Financial Services, Inc. 

(“GM Financial”) violated the Servicemembers Civil Relief Act, and in 

consideration of GM Financial’s payment to me of $ [AMOUNT], I, [LESSEE’S 

NAME], hereby release and forever discharge all claims, arising prior to the date 

of this Release, related to the facts at issue in the litigation referenced above and 

related to the alleged violation of Section 3955 of the Servicemembers Civil Relief 

Act, that I may have against GM Financial and all related entities, parents, 

predecessors, successors, subsidiaries, and affiliates and all of its past and present 

directors, officers, agents, managers, supervisors, shareholders, and employees and 

its heirs, executors, administrators, successors or assigns.

Executed this ______ day of ______________________, 202__.

SIGNATURE: __________________________

PRINT NAME: __________________________

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EXHIBIT D

DECLARATION – Vehicle Repossessions

I, [INSERT NAME], do hereby declare and state as follows:

1. I owned a vehicle obtained through a loan with AmeriCredit Financial 

Services, Inc. dba GM Financial,, Loan Number [LOAN NUMBER] that 

was repossessed.

2. I obtained the loan on or about [LOAN FUNDING DATE].

3. On or about [REPOSSESSION DATE], I WAS either:

i. on a covered period of military service; OR

ii. a member of a reserve component (Reserves or National Guard) and

had received orders to report for a covered period of military service. 

Please consider the following additional information in support of this 

Declaration:

I confirm that the foregoing is true and correct.

Executed this ______ day of ______________________, 20__.

SIGNATURE: __________________________ 

PRINT NAME:__________________________

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APPENDIX REGARDING MILITARY SERVICE

As used in this Declaration, a “covered period of military service” is any of 

the following:

a) Full-time active duty with the armed forces of the United States (Army, 

Navy, Air Force, Marine Corps, Coast Guard, or Space Force), including 

National Guard members serving under orders issued under Title 10 of the 

United States Code;

b) A period of active service with the National Guard:

i)) authorized by the President or the Secretary of Defense;

ii) longer than thirty (30) consecutive days;

iii) under orders issued under Section 502(f) of Title 32 of the United States 

Code; and

iv) for the purpose of responding to a national emergency declared by the 

President and supported by federal funds.

c) Active service as a commissioned officer of the Public Health Service or the 

National Oceanic and Atmospheric Administration; or

d) A period of time during which I was a servicemember absent from duty on 

account of sickness, wounds, leave, or other lawful cause.

If you have any additional questions about whether your service constitutes a 

“covered period of military service” for purposes of this declaration, please contact 

the Department of Justice at 202-514-4713 and reference the GM Financial SCRA 

case.

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EXHIBIT E

RELEASE – Vehicle Repossessions

Pursuant to the Consent Order resolving the United States’ allegations in 

United States v. AmeriCredit Financial Services, Inc. dba GM Financial, Case No. 

[INSERT CASE NUMBER] (N.D. Tex.), that AmeriCredit Financial Services, Inc. 

dba GM Financial (“GM Financial”) violated the Servicemembers Civil Relief Act, 

and in consideration of GM Financial’s payment to me of $ [AMOUNT], I, 

[BORROWER OR LESSEE’S NAME], hereby release and forever discharge all 

claims, arising prior to the date of this Release, related to the facts at issue in the 

litigation referenced above and related to the alleged violation of Section 3952 of 

the Servicemembers Civil Relief Act, that I may have against GM Financial and all 

related entities, parents, predecessors, successors, subsidiaries, and affiliates and 

all of its past and present directors, officers, agents, managers, supervisors, 

shareholders, and employees and its heirs, executors, administrators, successors or 

assigns.

SO ORDERED on this 3rd day of October 2022. 

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