Metro 2 DS Code Verification for Data Furnishers

Verify before you report.

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

File Review — Corrections PackageVerified
Matched account ····4821  Add DS
Status: Currently enrolled · Settlement company named
Evidence grade: Verified · As of: current cycle
Matched account ····7305  Remove DS
Reported DS without current verification support
Evidence grade: Indicated · As of: current cycle
Every line carries its evidence record — status, settlement company, grade, and as-of date.

The industry is not ready — and evidence is the reason

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.

11%

Expect to report DS

Just over one in ten reporting teams surveyed expect to implement the new code.

67%

Are undecided

Two-thirds have not committed either way — the decision is waiting on a defensible verification process.

#1

Barrier: the evidence

“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.

Two ways to put verification in front of the file

Same network, same evidence standard — choose per cycle, or run both.

Metro 2 File Review

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.

How file review works →

Inventory Monitoring

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.

How monitoring works →

What a verified result looks like
Matched account ····4821
Status: Currently enrolled · Settlement company named
Evidence grade: Verified · As of: current cycle
Matched account ····9054
Status: Dropped out · Dropped date returned
Evidence grade: Verified · Action: remove DS

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.

The scale of what furnishers cannot currently see

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.

8.1M

Consumers enrolled

Clients served by debt settlement programs, 2016–2025 (Ernst & Young industry study).

$195.3B

Debt enrolled

Across 54.1 million accounts in the same ten-year window.

~50%

Current at enrollment

TransUnion research found about half of enrollees were current on their accounts when they enrolled — invisible in delinquency data until the damage is done.

Verification built to be defended

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.

CDIA conditions, checked literally — verified engagement with a for-profit debt settlement company, and participation expected to materially alter repayment terms.
Exclusions enforced — the network carries for-profit debt settlement only. Debt management plans and credit counseling records never produce a DS verification.
Evidence grades on every result — verified vs. indicated, with the basis and the as-of date, so your team decides with the strength of the evidence in view.
An audit trail, not a spreadsheet — every check, match, and correction is logged with its purpose. The record a §623 investigation starts from.

Questions furnishers ask first

What exactly is the DS code?

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.

Do you change our Metro 2 file for us?

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.

What counts as “verified”?

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.

What about debt management plans and credit counseling?

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.

Verify before you report

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.

Get Started
Prefer to look first? See how file review works
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