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