Starting in Q2 2027, the Metro 2 DS Special Comment Code tells the bureaus a consumer is in a debt settlement program — but a furnisher may only report it after verifying the consumer actually engaged a for-profit debt settlement company. ScrubHits is that verification: your Metro 2 file or your inventory, checked against the enrollment network, with the evidence returned for every line.
Built on the CDIA standard · Evidence your FCRA §623 file can stand on · Network refreshed as often as daily
In Auriemma Roundtables’ 2026 survey of credit bureau reporting teams, most furnishers had not decided whether they will report the DS code at all. The first barrier they named was not systems. It was defining what evidence is sufficient to confirm an enrollment.
Just over one in ten reporting teams surveyed expect to implement the new code.
Two-thirds have not committed either way — the decision is waiting on a defensible verification process.
“Defining what evidence or documentation is sufficient to confirm that a consumer has enrolled in a qualifying for-profit debt settlement program.”
Source: Auriemma Roundtables, Credit Bureau Reporting Roundtable survey, reported by insideARM, September 2026.
Same network, same evidence standard — choose per cycle, or run both.
Upload the file you are about to transmit. We match every account against the network and hand back the corrections: where DS belongs, where reported DS has no verification behind it, and what changed since last cycle — each line with its evidence record. You apply the corrections and send your own file.
Send your inventory once. We watch it continuously and tell you when an account enters settlement — and when it leaves, settles, or completes — so the DS decision for every account is already made before your next file is generated.
Every result carries the enrollment status, the company holding it, an evidence grade, and an as-of date — and sits in an audit log your team can produce. Sample data shown; identifiers are masked and raw SSNs are never stored.
Debt settlement is not a niche program. It is a material share of the unsecured book — and bureau data alone does not show it while it matters.
Clients served by debt settlement programs, 2016–2025 (Ernst & Young industry study).
Across 54.1 million accounts in the same ten-year window.
TransUnion research found about half of enrollees were current on their accounts when they enrolled — invisible in delinquency data until the damage is done.
A DS report is a representation to the bureaus. Ours is built so yours holds up — to an audit, to a regulator, and to a consumer dispute.
A Metro 2 Special Comment Code, adopted through CDIA’s Metro 2 Task Force, indicating that the furnisher has verified the consumer engaged a for-profit debt settlement company to act on their behalf. CDIA anticipates furnishers can begin reporting it in Q2 2027. Full treatment: the DS code guide.
No — deliberately. You stay the furnisher of record: we return the corrected data and the evidence, you apply it and transmit your own file. Our verification report becomes part of your records, which is where Regulation V expects the substantiation to live.
A current enrollment record in the network that names the settlement company, states the status, and carries an as-of date — graded by the strength of the underlying evidence. The standard is set out on the evidence page.
CDIA excludes them from DS, and so do we: the network holds for-profit debt settlement enrollments only, so a DMP can never surface as a DS verification.
Start with a mutual NDA and one file. We review the file you are about to transmit, hand back the corrections with the evidence behind each one, and you decide what reports.
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