The questions data furnishers ask about the DS code, the evidence behind it, and how ScrubHits works — in one place. Anything not answered here, ask us directly.
A Metro 2 Special Comment Code adopted through CDIA’s June 2026 Industry Bulletin. It indicates that the furnisher has verified the consumer has engaged a for-profit debt settlement company to act on the consumer’s behalf. The definition, conditions, and exclusions are set out on the DS code guide.
CDIA anticipates reporting can begin in Q2 2027; the effective date is to be announced, with implementation guidance to follow in the Credit Reporting Resource Guide. Reporting is voluntary. A furnisher that reports it must have verified enrollment first, under CDIA’s conditions. See the timeline.
Two things, for that consumer: your institution has verified active participation in a for-profit debt settlement program, and the participation is expected to materially alter repayment terms — including before any settlement completes. When both hold, the code reports on all applicable accounts at the same financial institution.
No. CDIA excludes both by name, along with preliminary inquiries, informal discussions, and speculative negotiations. Only for-profit debt settlement engagements qualify — see settlement vs. DMP.
A current enrollment record: the consumer matched, the for-profit settlement company named, the lifecycle status stated, and an as-of date fresh enough to report on — meeting both CDIA conditions. The full standard is on the evidence page, and the working process is on the verification guide.
Verified meets the standard and supports reporting DS. Indicated is a signal consistent with enrollment that does not yet meet it — returned for inquiry only, never as a basis to report. The grade and its basis appear on every result.
Because Regulation V (12 CFR 1022.41(d)) defines the integrity of furnished information as information substantiated by the furnisher’s records at the time it is furnished. The substantiation for a DS report has to live in your records — so every result returns with its evidence record, and every cycle’s corrections package becomes part of your file.
File review checks the Metro 2 file you are about to transmit, once per cycle, and returns the corrections. Monitoring watches your whole inventory continuously between cycles and reports enrollment events as they happen, so most DS decisions are made before the file is generated. They run on the same network and the same evidence standard, and most furnishers run both.
Keyed to your file: accounts to add DS to, accounts whose DS code lacks current verification support, lifecycle status changes since last cycle, and a no-change confirmation for the rest — every line carrying its enrollment status, the settlement company, the evidence grade and basis, and the as-of date, plus a cycle summary.
Neither — deliberately. You stay the furnisher of record: we return the corrected data and the evidence, your team applies what it accepts, and you transmit your own file. Corrections you reject do not go in; the decision and its record stay with you.
Verification runs before the file is generated and transmitted, with the turnaround fixed in your agreement so corrections return with time to apply them. Out-of-cycle errors are corrected with an AUD in e-OSCAR; monitoring events arrive between cycles as they are confirmed. The implementation checklist sequences the whole cycle.
By volume, on plans: reviewed accounts and monitored inventory count toward one volume, with no platform fees and no minimums to start, and an additional discount on every invoice while a card is on file for autopay. Rates are quoted per institution — see how pricing works.
With a mutual NDA and one file. The NDA is downloadable and returnable on this site; from there we set up your secured access, walk the evidence standard with your team, and review a live file so the first corrections package is argued line by line before anything reports differently. Start at contact.
The dispute arrives through e-OSCAR and starts the FCRA §623(b) investigation clock. Your investigation runs from the verification record — status, company, grade, as-of date — which is retained with its audit trail for exactly that purpose. The full path is on the disputes guide.
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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