New Debt Settlement Comment Code is Coming, but Adoption Uncertain

A new Metro 2 code could provide greater visibility into debt settlement participation, yet the vast majority of surveyed furnishers are undecided or do not expect to adopt it.

When the Consumer Data Industry Association (CDIA) and Metro 2 Task Force approved a new Special Comment Code for consumers participating in qualifying debt settlement programs, it was billed as addressing a longstanding visibility gap in credit reporting.

Once the DS code debuts in Q2 2027, furnishers will have a standardized way to identify that a consumer is actively participating in a for-profit debt settlement program. That additional context can help inform lenders’ credit risk assessments, account servicing strategies, collections workflows, customer communications, and portfolio management.

But the approval of the new comment code is only the first step: Achieving consistent implementation across the industry is a separate challenge altogether.

Widespread adoption of the DS comment code is far from assured, according to survey data from Auriemma Roundtables’ Credit Bureau Roundtable:

• 22% of survey respondents do not expect to implement the code
• 67% remain undecided
• 11% currently expect to report it

Hurdles for Adoption

Unlike regulatory or Metro 2 changes that require implementation, furnishers will not be obligated to report the new DS comment code. Each organization must determine whether the operational effort justifies the value.

For the DS code, operational effort would include policies, processes, and controls to ensure the code is applied accurately and consistently, such as:

• Defining what evidence or documentation is sufficient to confirm that a consumer has enrolled in a qualifying for-profit debt settlement program
• Identifying how debt settlement is distinguished from other programs like debt management plans, credit counseling, and other forms of financial assistance
• Ensuring the code is supported by well-defined governance and quality controls

When furnishers already face an enormous amount of mandatory work, a voluntary reporting enhancement will naturally compete for limited operational resources that are focused on higher priorities, such as:

• Managing growing volumes of disputes and credit bureau blocks
• Resolving bureau reporting inconsistencies
• Responding to increasingly sophisticated AI-generated disputes

“The challenge is whether organizations can justify prioritizing a voluntary enhancement when they’re working through a long list of other initiatives,” said Howard Fish, Director of Auriemma’s Credit Bureau Roundtable. “Successfully implementing any new code requires an extensive operational framework to support it.”

A Comment Code Is Only Valuable If It’s Used

Metro 2 contains dozens of Special Comment Codes that provide additional context beyond account status, but their utility has always depended on consistent application by furnishers. Questions around implementation and adoption of the DS Comment Code remain—and those questions can’t be solved by any one stakeholder alone.

That’s why Auriemma Roundtables is bringing together creditors and furnishers, debt settlement companies, collection agencies, debt buyers, and other industry participants for its Debt Settlement Companies Session on August 25 in Philadelphia.

The session is designed to encourage candid discussion around the operational realities facing each group of stakeholders, including improving communication and collaboration between creditors and debt settlement providers and identifying practical approaches that can increase transparency while reducing operational friction.

Learn more about the Debt Settlement Companies Session and request to attend here.