The Metro 2 DS code

What the new Special Comment Code says, when it may be reported, what it excludes, and when it starts — from CDIA’s own Industry Bulletin (June 2026), the document that created it.

“The DS Special Comment Code indicates that the furnisher has verified that the consumer has engaged a for-profit debt settlement company to act on the consumer’s behalf.”

— CDIA Industry Bulletin, New Metro 2 Special Comment Code for Debt Settlement, June 2026

When the code applies

Per the Bulletin, DS reports during periods when a consumer is actively participating in a for-profit debt settlement program — including periods prior to final settlement, when the consumer is expected to pay a reduced amount but the account has not yet been reported as settled. Two conditions must both hold:

  • A furnisher has verified that a consumer is actively participating in a for-profit debt settlement program, and
  • The participation is expected to materially alter repayment terms, including during periods prior to settlement completion.

And when it reports, it reports completely: the Bulletin directs furnishers to report the code on all applicable accounts at the same financial institution.

What the code is not for

The Bulletin’s exclusion list, verbatim in substance: do not report DS for debt management plans; for credit counseling arrangements; or for preliminary inquiries, informal discussions, or speculative negotiations where the consumer has not engaged a for-profit debt settlement company to negotiate directly with the furnisher. A consumer negotiating on their own, with no company engaged, is outside the definition for the same reason.

Timing and status

  • Adopted: June 2026, through CDIA and the Metro 2 Task Force.
  • Reporting begins: CDIA anticipates furnishers will be able to start reporting the DS code in Q2 2027; the Bulletin lists the effective date as to be announced.
  • Further guidance: CDIA will publish implementation detail to the Credit Reporting Resource Guide (CRRG); in the interim it directs questions to the bureaus.
  • Obligation: reporting is voluntary. Nothing requires a furnisher to report DS — but a furnisher that does must meet the verification condition, and inaccurate reporting carries FCRA exposure either way.
  • Where it sits: a Special Comment Code in the Metro 2 Base Segment, alongside the existing special comment values — one more field your monthly file either justifies or doesn’t.

The readiness gap

The rule is written; the industry’s process is not. Auriemma Roundtables’ 2026 survey of reporting teams found 11% expecting to implement DS, 67% undecided, and 22% not expecting to — with the definition of sufficient enrollment evidence named as the leading obstacle. Law firm guidance to furnishers (Troutman Pepper Locke, July 2026) makes the same point from the risk side: decide what documentation and verification steps you will require before applying the code, because inaccurate or inconsistent use invites FCRA claims.

That is the gap ScrubHits operates in: the evidence standard, applied through file review and monitoring, so that when Q2 2027 opens, the verification step is already a routine part of your cycle.

DS code questions

When does DS reporting start?

CDIA anticipates furnishers will be able to start reporting in Q2 2027. The Bulletin’s effective date is listed as to be announced, with further guidance to follow in the CRRG.

Is reporting the DS code mandatory?

No. It is voluntary — but voluntary cuts both ways: a furnisher that reports it must have verified enrollment first, and a furnisher that does not report it is making a portfolio decision with incomplete information either way.

Does a debt management plan count?

No. DMPs and credit counseling arrangements are excluded by name. Only for-profit debt settlement engagements qualify — which is why a verification source that mixes DMP and settlement records cannot answer the DS question.

What counts as verification?

Evidence that the consumer is enrolled in a qualifying program: the enrollment status, the company holding it, and how current the information is — graded, dated, and auditable. Our full standard: the evidence page.

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.

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