What counts as verified enrollment for the DS code?

A current enrollment record meeting both CDIA conditions: verified active participation in a for-profit debt settlement program, and participation expected to materially alter repayment terms. Results are graded Verified (supports reporting) or Indicated (supports inquiry only).

What is in a ScrubHits evidence record?

The masked matched account, enrollment status, the settlement company named, effective and as-of dates, the evidence grade and its basis, and an audit trail of every check.

The Evidence Standard — What Verified Means

The CDIA test — both halves, every time

CDIA’s Industry Bulletin sets two conditions for reporting DS. A ScrubHits verification is built to answer both, in order.

Verified engagement

The furnisher has verified that the consumer is actively participating in a for-profit debt settlement program — a real engagement with a for-profit debt settlement company acting on the consumer’s behalf, not an inquiry, a consultation, or a negotiation the consumer is running alone.

Material alteration expected

The participation is expected to materially alter repayment terms — including during the period before any settlement completes, while the consumer is expected to pay a reduced amount and the account has not yet been reported as settled.

Every account at the institution

When both conditions hold, the code reports on all applicable accounts at the same financial institution — which is why our checks run institution-wide, not one account at a time.

What never verifies

Debt management plans — excluded by CDIA by name. The network carries no DMP records.
Credit counseling arrangements — excluded the same way, and absent from the network for the same reason.
Preliminary inquiries, informal discussions, speculative negotiations — CDIA’s words. An inquiry is not an enrollment, and our records begin at enrollment.
The consumer negotiating alone — with no for-profit company engaged, there is nothing for the code to describe.

The two grades

Verified — a current enrollment record: the program, the company holding it, the status, and an as-of date fresh enough to report on. This is the grade that supports reporting DS.
Indicated — a signal consistent with enrollment that does not yet meet the standard: older, partial, or awaiting confirmation. Indicated results are returned for inquiry — they are never presented as a basis to report.

Grades are shown on every result, with the basis. A furnisher that wants to see why a line graded as it did can see it.

The lifecycle, and what each status means for the file

Statuses the network tracks

Currently enrolledreport DS (both conditions met)

Settlement reached — performingDS stays; lifecycle recorded

Completedprogram finished; history retained

Dropped outremove DS at the next file

Removedrecord withdrawn by the program

What the evidence record holds

Matched accountmasked — ····4821

Enrollment statuscurrent lifecycle state

Settlement companynamed on every verified hit

Effective & as-of dateswhen it began; how fresh the check is

Evidence grade & basisverified or indicated, and why

Audit trailevery check logged with its purpose

Why this record is the one your duties ask for

Two provisions do the asking.

Regulation V, §1022.41 defines the integrity of furnished information as information substantiated by the furnisher’s records at the time it is furnished. The evidence record is designed to be that substantiation — in your records, dated, before the file goes out.

FCRA §623(b) requires a furnisher, on notice of a consumer dispute from a bureau, to investigate and report within the dispute window. When a DS code is disputed, the investigation starts from the verification record: who was enrolled, with whom, as of when, on what evidence.

Regulation V, §1022.42 requires reasonable written policies and procedures for accuracy and integrity. A named verification step, run every cycle, is the kind of procedure that requirement describes.

Retention with a tail — FCRA suits can reach back years (the limitations period runs to five years from the violation). Evidence records and audit logs are retained to match.

Evidence questions

Who sets this standard — you or CDIA?

CDIA sets the conditions for the code. The standard on this page is our operating implementation of those conditions: what our network must hold before a result is graded Verified. Where CDIA publishes further guidance in the Credit Reporting Resource Guide, the standard is updated to it.

Can we rely on an Indicated result to report DS?

No — and we will tell you that in the data itself. Indicated is a prompt to inquire, not a verification. Reporting on an indication would fail CDIA’s first condition.

How fresh is “current”?

The network is refreshed as often as daily, every result carries its as-of date, and file review runs against the file you are about to send — so the verification and the report sit in the same cycle.

The evidence standard