The Metro 2 “DS” code: enrollment has to be verified first

The CDIA’s Metro 2 format adds a “DS” Special Comment Code for accounts in a debt settlement program. It debuts in Q2 2027 — and a furnisher may only report it when enrollment in a for-profit debt settlement program has been verified.

What the DS code is

The code

  • A Special Comment Code in the Metro 2 credit reporting format, approved in 2026
  • It marks an account whose consumer is enrolled in a debt settlement program
  • Reporting it is voluntary — but if it is reported, it has to be right
  • It covers for-profit debt settlement only — credit counseling / DMP enrollments do not qualify
  • It applies while the consumer is actively participating, where participation is expected to materially alter repayment terms (CDIA bulletin, June 2026)

The verification requirement

  • Before reporting DS, the furnisher must verify the consumer is actually enrolled in a qualifying program
  • A guess, a consumer’s say-so, or a stale list is not verification
  • Verification means dated enrollment evidence: the program, the company holding it, and currency
  • That is exactly what an enrollment scrub returns — status, company, and an “as of” date on every hit
  • Trade coverage of the rollout (insideARM, 2026) names the top adoption hurdle as defining what evidence is sufficient to confirm enrollment — the problem a dated, audit-logged hit exists to solve

Getting ready before Q2 2027

1

Scrub the portfolio

Find which accounts are enrolled today, and with which company — the baseline for any DS reporting decision.

2

Put it on monitoring

Enrollment changes monthly. Monitoring keeps the verification current instead of letting it age.

3

Keep the evidence

Every hit is dated and audit-logged — the record behind the code, if it is ever questioned.

Verify before you report

Contact us to set up secured access, or read what a debt settlement scrub is — and see the Regulation F article for the collection side of the same problem.

DS code — questions

When does the DS code take effect?

It debuts in Q2 2027. Furnishers can prepare now by establishing how they will verify enrollment before reporting it.

Is reporting the DS code mandatory?

No — it is voluntary. The requirement is conditional: if a furnisher reports it, enrollment must have been verified first.

Does a DMP enrollment count for the DS code?

No. The code covers for-profit debt settlement programs. Debt management plans from credit counseling agencies are excluded — and the EnrolledHits network contains no DMP records, so a hit is never a counseling plan in disguise.

What counts as verification?

Dated evidence that the consumer is enrolled in a qualifying program: the enrollment status, the company holding it, and how current the information is. EnrolledHits returns all three on every hit, with an as-of date and an audit trail.

The visibility problem, in the industry’s words

“Credit risk assessors have long faced limited visibility during the window when a consumer is actively in settlement but before the account is officially reported as settled.”

— ACA International’s analysis of the DS code, as reported by White & Jacobs

That window is exactly what an enrollment check closes — the code reports later; the network answers now.

Get started today

Send your first file this week. We set up your secured access, run your full-inventory scrub, and turn monitoring on the same day — plans priced by volume, quoted for your portfolio.

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