Verification is not a preliminary to reporting the Metro 2 DS code — it is the substance of the report. This page walks the rule, the evidence that satisfies it, and the two ways a furnisher runs the check: against the file before it is transmitted, and against the whole book between cycles.
Read CDIA’s definition once and the shape of the obligation is clear: the code is defined by what the furnisher has done — it indicates the furnisher has verified that the consumer engaged a for-profit debt settlement company to act on the consumer’s behalf. The code does not describe a suspicion, a score, or a pattern of missed payments. It describes a completed verification. A furnisher that reports DS without one has made a representation it cannot support — and a furnisher that cannot verify at all is left guessing about a material fact on millions of accounts. Everything below follows from that single sentence.
Unlike most Metro 2 fields, DS is not data your systems generate. It is a conclusion your process reaches. The process has to exist before the field can be reported.
Reporting DS on a consumer who is not enrolled misstates their file. Missing DS on a consumer who is enrolled leaves the tradeline describing an account as ordinary delinquency when a verified program is in motion. Verification is what keeps both errors down.
Furnisher-side legal guidance on the DS code (Troutman Pepper Locke, July 2026) lands in the same place: settle what documentation and verification steps you will require before the code goes on a file, because inaccurate or inconsistent use is where the FCRA exposure sits.
CDIA’s Industry Bulletin (June 2026) sets two conditions. Both must hold, for the specific consumer, before DS reports.
The full rule is set out on the DS code guide; the settlement-versus-plan distinction is drawn on the DMP page.
Verification is evidence of the engagement itself — not an inference from how the account behaves. An enrollment record that answers four questions is what the standard requires.
The consumer, matched to your account — with identifiers handled so the match is exact, not approximate.
The for-profit settlement company holding the engagement, named — and the lifecycle status: currently enrolled, settlement reached and performing, completed, or dropped out, with the relevant dates.
An as-of date fresh enough to report on. Enrollment is a moving fact; last quarter’s answer is not this cycle’s verification.
A current enrollment record meeting both CDIA conditions — the company named, the status live, the as-of date in cycle. Verified is the grade that supports reporting DS.
A signal consistent with enrollment that does not yet meet the standard — older, partial, or awaiting confirmation. Indicated supports inquiry only. It is returned so your team can see it, and it is never presented as a basis to report.
The complete grading standard, the lifecycle statuses, and what an evidence record holds are set out on the evidence page.
Verification done by someone else, recorded nowhere you control, does not discharge a furnisher’s own duties. Regulation V (12 CFR Part 1022) is written around the furnisher’s records, and the DS workflow has to be too.
Section 1022.41(d) defines the integrity of furnished information as information that is substantiated by the furnisher’s records at the time it is furnished. A DS report therefore needs its verification record sitting in your records, dated on or before the file that carries the code — which is why ScrubHits returns the evidence record with every result instead of keeping it on our side of the wall.
Section 1022.42 requires reasonable written policies and procedures addressing accuracy and integrity, and FCRA §623 carries the underlying duties: accuracy under §623(a), and a reasonable investigation, on the dispute clock, under §623(b). A named verification step, run every cycle with its records retained, is the procedure those provisions describe — and when a DS code is later disputed, the verification record is what the §623(b) investigation starts from. The duties are mapped on the §623 page.
Same network, same evidence standard — the difference is when the verification happens.
Upload the Metro 2 file you are about to transmit. Every account is matched against the enrollment network and the corrections come back: where DS belongs, where a DS code already on the file has no current verification behind it, and what changed since last cycle — each line with its evidence record. You apply the corrections and transmit your own file, staying the furnisher of record.
Load your inventory once and it is watched continuously. When an account enters settlement — or reaches a settlement, completes, or drops out — the event is reported with the company named and the effective date, so most DS decisions are already made before the next file is generated. File review then confirms the file against decisions you have already seen.
A consumer’s say-so is a lead, not a verification. CDIA’s first condition is verified engagement with a for-profit debt settlement company — evidence of the engagement itself: the program, the company holding it, the current status, and how fresh the information is. Report on the evidence, not the assertion.
No. The code applies during active participation, including 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. Waiting for settlements would miss most of the window the code exists to describe.
All applicable accounts at the same financial institution, per CDIA’s direction. Enrollment is a fact about the consumer’s engagement, not about one tradeline — which is why our checks run institution-wide.
No. Debt management plans and credit counseling arrangements are excluded from the code by name. Only for-profit debt settlement engagements qualify, and a verification source that mixes plan records with settlement records cannot answer the DS question.
Current to the cycle you are reporting in. Enrollment starts, settles, completes, and drops out between files; a verification is only as good as its as-of date. Our 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 verification and report sit in the same cycle.
Treat it as a prompt to inquire — nothing more. Indicated results are returned because your team should see the signal, but they do not meet CDIA’s verification condition and must not support a DS report. If the enrollment confirms, the grade rises to Verified with the record behind it.
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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