Bio:
In addition to her work as compliance practitioner & consultant, Barbara is known for her expertise and contributions to the ABA, CBA, and ICBA.
Barbara has more than 20 years of regulatory compliance experience as a compliance practitioner and consultant across the broad range of A-to-Z consumer regulations, including a deep expertise with principle-based regulations such as UDAAP. She has worked with financial institutions and fintechs of all sizes, supporting exams before the CFPB, Federal Reserve, OCC, FDIC, and NCUA.
Boccia is a well-known industry thought-leader, has presented at many industry events including for the ABA, CBA, and ICBA; and has written articles like “Managing UDAAP in the Digital Age” for ABA and “UDAAP Controls For Managing Risk” for the Journal of Financial Compliance. She is a member of the ABA Risk and Compliance Editorial Board.
She can be contacted via LinkedIn.
Questions Answered
04/27/2025
Do banks have a legal obligation to respond to verification of assets for Medicare or public housing? If so, is there a hard and fast rule for a response timeframe. We try to respond timely out of courtesy for our customer base, but the requesters have become increasingly aggressive and pushing for immediate responses. Due to the volume of requests and our limited staff, it is difficult to fulfill all of them the same day that they are received.
04/20/2025
I am looking for the time frames for debit card disputes, not in regard to Reg E, but Mastercard rules.
Customer filled out a dispute form for fraud on 1/25/25. I input it to our processor [omitted] 1/27/25. Today (4/1/25), the merchant has done a rebuttal rejecting the dispute. I opened a case with [vendor name omitted] stating the merchant is outside the 45 days window to respond. They didn't process the chargeback to the Merchant until 2/15/25 (they state they have 120 days to do this-they are within the time frame) which i was under the impression that is as far back as I could go if we were to go back farther than the 60 days past statement receipt, not how long [vendor name omitted] has to process the dispute I opened. Either way if they go by my date of 1/27/25 or their date of 2/15/25, 4/1/25 seems to be outside the 45 days window. I am looking for a table or guide with timeframes to help with disputes please.
04/20/2025
Are applications submitted with fraudulent information HMDA reportable if they reached an application status due to fraud? We have received a fraud trigger but it also reached application status for HMDA reporting.
02/02/2025
We do consumer loans consisting of auto, unsecured, and CD secured loans, and we charge an administration fee of $25.00. This fee is listed in our third-party document generation and processing system as an administrative fee that affects the APR (in other words, a finance charge). I wonder if this is acceptable for a consumer loan.
