Your SlideShare is downloading. ×

capital one 2007 Policy Affairs Group Annual Report


Published on

Published in: Economy & Finance
  • Be the first to comment

  • Be the first to like this

No Downloads
Total Views
On Slideshare
From Embeds
Number of Embeds
Embeds 0
No embeds

Report content
Flagged as inappropriate Flag as inappropriate
Flag as inappropriate

Select your reason for flagging this presentation as inappropriate.

No notes for slide


  • 1. 2007 Annual Report Policy Affairs Group Capital One Associates Political Fund
  • 2. TAble OF COnTenTs • Legislation Touches All Aspects of Our Company ...................................................... 3 • Capital One Testifies before U.S. Congress ................................................................ 4 • Making Our Communities Safer ................................................................................ 8 • Financial Literacy ....................................................................................................... 9 • State Legislative Lineup ........................................................................................... 11 • Capital One Associates Political Fund ...................................................................... 12 • Capital One Policy on Political Contributions ........................................................... 14 • 2007 PAC Contributions .......................................................................................... 16 2
  • 3. LEGISLATION TOUCHES ALL ASPECTS OF OUR COMPANy Capital One has four federal functional regulators overseeing our lending practices, institutional safety and soundness, and securities governance. Some business lines also have state regulators with oversight responsibility for our products, marketing activities, corporate structure and funding. From designing a new product to sending an offer and managing the account, Capital One is impacted by the legislation enacted by lawmakers in Washington, D.C., and state capitals, as well as regulations issued at the state and federal level. The following sets forth just some of the important laws that impact our business. legislative Controls and Our business Account Management Account evaluation Product Design • Truth in Lending Act • Equal Credit Opportunity Act • Fair Credit Reporting Act • Equal Credit Opportunity Act • Fair Credit Reporting Act • Equal Credit Opportunity Act • Fair Credit Reporting Act • State Laws regarding • Electronic Signatures in Global and • Fair Debt Collection Act credit evaluation National Commerce Act (E-Sign) • Electronic Funds Transfer Act • Bank Secrecy Act/PATRIOT Act • Electronic Funds Transfer Act • Electronic Signatures in Global and • Office of Foreign Assets Control • Regulation Q (limitations National Commerce Act (E-Sign) regulations on interest on deposits) • State Laws regarding customer • Home Mortgage Disclosure Act • Federal Deposit Insurance Regulations agreements; grace periods; • Federal Trade Commission Act • US Postal Service Regulations collection laws; advertisements • Real Estate Settlement Procedures Act Account set-up • State Laws regarding auto finance Offer and mortgages • Electronic Funds Transfer Act • Expedited Funds Availability Act • Truth in Lending Act • Truth in Lending Act • Office of Foreign Assets • Fair Credit Reporting Act • Fair Credit Reporting Act Control regulations • Truth in Savings Act • Equal Credit Opportunity Act • Regulation Q (limitations on • Home Mortgage Disclosure Act • State Laws regarding mail, Internet interest on deposits) • Real Estate Settlement Procedures Act and telephone solicitations; and • US Postal Service Regulations disclosure requirements • Fair Housing Act safety and soundness Regulation • Telephone Consumer Protection Act • Federal Trade Commission Act • Telemarketing Sales Rule • Capital regulations • CAN-SPAM • Truth in Savings Act • Interstate Branching Act • Bankruptcy Act • US Postal Service Regulations • Sarbanes-Oxley Act • Service Members Civil Relief Act • Home Mortgage Disclosure Act • Federal Deposit Insurance Act • Fair Housing Act • Regulation O (loans to insiders) Privacy and Information security • Federal Trade Commission Act • Bank Bribery Act • Gramm-Leach-Bliley Act • CAN-SPAM • Foreign Corrupt Practices Act • Fair Credit Reporting Act • Transactions with Affiliates • Federal information-security regulations and data-breach guidance • Bank Holding Company Act • State credit-freeze and • National Bank Act data-breach laws We track issues as diverse as: • Mortgage Lending • Limitations on Lending to Military Personnel • Spyware • Tax issues such as Business Activity Tax • Community Reinvestment Act • Bankruptcy Reform • Security Breach and Identity Theft • Human Resources Issues • Interchange In 2007, we engaged and tracked more than 2,300 pieces of federal and state legislation. 3
  • 4. CAPITAL ONE TESTIFIES BEFORE U.S. CONGRESS – SENATE Congressional Hearing on Credit Cards During the course of the discussion, Committee before the U.s. senate banking Committee members also described the obvious benefits provided through innovation by credit card issuers, with some indicating a desire to allow the market- On January 25, 2007, John place to function without new governmental or Finneran, Capital One’s regulatory restrictions or prohibitions. General Counsel and Corporate Secretary, The industry witnesses refuted the claims of the appeared on behalf of critics, but acknowledged that existing disclosure Capital One before the requirements are complex and can result in consumer U.S. Senate Committee on confusion. Banking, Housing, and Urban Affairs. The hearing was titled “Examining the Billing, Marketing, In addition to the industry witnesses, the Committee and Disclosure Practices of the Credit Card Industry, called a number of witnesses who were critical of the and Their Impact on Consumers.” industry to testify. Chairman Chris Dodd (D-CT) indicated that this hear- Chairman Dodd indicated that he looked forward to ing was the first in a “series” of hearings on credit working with interested parties, including industry card issues and noted that the industry is criticized representatives, in developing legislative solutions to for certain practices, specifically citing two-cycle the issues that were raised. billing and universal default. The practice of marketing credit cards to college students was also singled out for criticism. Finneran discussed Capital One’s consumer-friendly practices, including our long-standing commitment not to engage in the practice of universal default or two-cycle billing. The Committee members who spoke at the hearing generally seemed to agree that the current credit card disclosure regime is too complex, leaving consumers confused and poorly informed about their credit card terms and accounts. Committee members renewed calls for enhanced customized disclosures on periodic statements informing cardholders of the ill effects of making only minimum payments. 4
  • 5. CAPITAL ONE TESTIFIES BEFORE U.S. CONGRESS – SENATE Congressional Hearing on Credit Card Practices before the U.s. senate’s Permanent subcommittee on Investigations On December 4, 2007, Ryan Schneider, head of Capital One’s Card Businesses, testified before the U.S. Senate Permanent Subcommittee on Investigations (“PSI”). The hearing was titled, “Credit Card Practices: Unfair Interest Rate Increases.” Senator Carl Levin (D-MI), Chair of the PSI, stated that the focus of the hearing was on “circumstances under which credit card issuers may increase the interest rates of cardholders who are in compliance with the terms of their credit cards.” • The specific focus of the hearing was on practices related to “universal default,” which is the practice of increasing cardholder interest rates for creditworthiness reasons even though the cardholder has no defaults on the account being repriced. Ryan Schneider, President, Card, testifies during a • The hearing also focused on the lack of clarity in communications to consumers Permanent Subcommittee from credit card companies when this occurs. on Investigations (Senate • This was the PSI’s second hearing on credit card practices and the first in which Homeland Security and Government Affairs Capital One was asked to testify. Committee) hearing on December 4, 2007. In his statement and responses to questions, Schneider underscored a number of Capital One’s consumer-friendly practices, including its long-standing policy to not engage in universal default in any form. Schneider explained Capital One’s industry-leading notice and opt-out policy proposal, and its existing practices with respect to changes in terms. Where Capital One finds it necessary to increase interest rates due to changing economic conditions, customers are provided with an exceptionally clear “change in terms” (CIT) notice that informs them how to opt out of the interest rate increase, close the account, and pay off the balance at the previous interest rate. Capital One customers receive 45 days’ notice, which is well beyond the 15 days required under current law. Capital One’s CIT notice was attached as an exhibit to Schneider’s testimony and was displayed on large charts in the Committee room. Both Chairman Levin and Ranking Minority Member Norm Coleman (R-MN) Ryan Schneider, President, Card, greets Senator Carl Levin praised the clarity of Capital One’s CIT notice. (D-MI), Chairman of the Senate’s Permanent Subcommittee on Investigations. 5
  • 6. CAPITAL ONE TESTIFIES BEFORE U.S. CONGRESS – SENATE Schneider also highlighted Capital One’s customer- friendly default repricing policy, in which customers can be repriced only if they pay three or more days late twice in a 12-month period, and if they have received a warning notice after the first late payment. He also discussed Capital One’s forward-leaning position on the Federal Reserve Bank’s revisions to Regulation Z and the improvement of customer disclosures. In addition to Capital One, other industry representa- tives and consumers were present at the hearing. • Discover Financial Services and Bank of America were represented and testified. • There was also a panel comprised of three consumers, who were customers of Discover, Bank of America and Chase. Each of these consumers had their interest rate increased although they had no default on their accounts. Credit Card summit In July 2007, Congresswoman Carolyn Maloney, Chair of the Financial Services Committee’s Subcommittee on Financial Institutions and Consumer Credit, held a “summit” to discuss principles she believed should guide the credit card marketplace. At the summit, credit card issuers and consumer groups came together to discuss practices and marketplace impacts. Capital One’s General Counsel, John Finneran, participated in the event with our industry peers including Citibank, J.P. Morgan Chase, Bank of America, Discover and American Express. Congresswoman Maloney used the session as a listening point and plans to expand on the issues in 2008 with the introduction of legislation to regulate the credit card marketplace. 6
  • 7. CAPITAL ONE TESTIFIES BEFORE U.S. CONGRESS – HOUSE 2007 Congressional Hearing on Credit Cards 2008 Credit Card bill Introduced in the U.s. before the U.s. House of Representatives House of Representatives The U.S. House of Representatives Committee on While several bills were introduced in 2007 that Financial Services focused on issues impacting the would limit a variety of credit card practices, none consumer credit arena during 2007. Specifically, the saw substantive legislative action. The three issues Committee focused on the contractual terms that that garnered the most attention were double-cycle are used within the credit card industry, as well as billing and universal default – practices that Capital the Federal Reserve Board’s draft proposal to update One does not engage in – and applying rate increases Regulation Z under the Truth in Lending Act (TILA). to the customer’s outstanding balance, not just future transactions. Other issues that Congress has On June 7, 2007, John Finneran, General Counsel, expressed interest in include overlimit transactions testified on behalf of Capital One before the and fees, payment allocation methods, grace Committee’s Subcommittee on Financial periods, payment deadlines, residual/trailing Institutions and Consumer Credit during a interest, accounts with high fees relative hearing entitled “Improving Credit Card to credit line, and appropriate conditions Consumer Protection: Recent Industry under which to increase interest rates and Regulatory Initiatives.” and how that is disclosed. The two-panel hearing featured testi- In 2008, congressional scrutiny of these mony from regulators, Federal Reserve issues continues, and has resulted in the Board Governor Frederic Mishkin and development of new legislation. House Comptroller of the Currency John Dugan. Financial Services Committee Chairman In addition, representatives from the industry, Barney Frank (D-MA) expressed a strong desire to consumer groups and small business testified about introduce additional legislation, and Subcommittee proposed changes to Regulation Z. The hearing also Chair Carolyn Maloney (D-Ny) has introduced a bill to examined recent industry reforms, including initia- address many of these issues. The first hearing on this tives to change certain practices such as universal bill was heard on March 13, 2008, and an additional default and double-cycle billing, which had come hearing is expected. under heavy criticism. Capital One will continue to provide leadership for In his remarks, Finneran endorsed the Fed’s proposed our industry trade groups to educate Congress about changes to Regulation Z and stated that “the Federal the potential unintended consequences and negative Reserve’s effort marks a landmark advance in how impacts such legislation could have on the industry, disclosures are developed.” Finneran noted that consumers and the economy. If passed, this legisla- Capital One does not engage in universal default tion could raise interest rates and decrease access practices or double-cycle billing, and that the new to credit at a time when the U.S. economy is already Regulation Z disclosures would shed more light on constrained by a credit crunch. repricing practices, which would provide valuable information for consumers to better understand how their credit cards work. He also discussed Capital One’s ongoing efforts to review and change our practices in light of changing customer preferences. 7
  • 8. MAkING OUR COMMUNITIES SAFER Capital One serves on Financial Coalition multibillion-dollar commercial enterprise. The Against Child Pornography Coalition is working diligently to ensure that credit cards and other payment methods cannot be used to purchase child pornography. In 2006, Capital One joined the Financial Coalition Against Child Pornography. The Coalition, which Capital One serves on Virginia Attorney includes leading banks, credit card General’s Youth Internet safety Task Force companies, third-party payment companies and Inter- net service providers, is dedicated to fighting child In 2006, Capital One served on Virginia Attorney pornography over the Internet. In its press release General Bob McDonnell’s youth Internet Safety Task announcing Capital One’s involvement, Ernie Allen, Force. The primary goal of the Task Force was to keep President and CEO of the National Center for Missing children safer online. In addition to Capital One, & Exploited Children (NCMEC) and Chairman of the members of the Task Force included AOL, MySpace, Coalition, stated that the mission of the group is Microsoft and other technology companies, as well “to eliminate the commercial viability of child as educators, parents, law enforcement officials and pornography by stopping the flow of money. As an elected officials. The Task Force issued a final report integral participant in the financial services industry, in December 2006, after six months of meetings. At Capital One will help us accomplish that goal.” his press conference announcing the work of the Task Force, Attorney General McDonnell Senator Richard Shelby (R-AL), Ranking Member of stated, “In addition to increasing the U.S. Senate Banking, Housing, and Urban Affairs Internet safety awareness, we Committee, was the catalyst for bringing the industry are also proposing tough new leaders together to address these problems. Senator sentences for those engaged in Shelby’s staff members, as well as other congressional the production and financing of staffers, regularly attend the Coalition’s meetings. In child pornography, and for those 2006, a number of congressional hearings were held who unlawfully solicit children on this issue in both the House and Senate, where online. Finally, we have identified NCMEC President Allen testified, along with represen- a number of changes in the law tatives from Visa, MasterCard, and American Express. that will aid in the investigation of Internet crimes.” The Coalition has established a global clearinghouse on child pornography to provide a unified system for In 2007, Capital One was asked by the Attorney identifying illegal activities and sharing information General to serve on the Implementation Committee, between Coalition companies. Coalition members to ensure that the report’s recommendations were report child pornography to the clearinghouse; it is put into effect. Also in 2007, Attorney General then reviewed, and feedback is provided to ensure McDonnell submitted a significant legislative action is taken to stop illegal practices. package to the Virginia General Assembly in order to provide the necessary legal authority to the Throughout 2007, with a partnership among its Task Force’s recommendations; the vast majority Policy Affairs, Legal and Fraud Departments, Capital of these provisions were enacted into law during One has remained an active member of the Coalition. that session. Capital One continues to serve on the The Coalition has grown during this time, adding Implementation Committee and to partner closely many new members and supporters to this important with the Attorney General and his staff. cause, and making substantial progress on its goal. NCMEC reports that child pornography has become a 8
  • 9. FINANCIAL LITERACy Capital One is proud to support a range of financial literacy initiatives, including a number of programs designed specifically to reach young adults and college students. Capital One informs members of Congress about our programs, which complement their efforts to promote greater financial literacy. In the spring of 2007, the U.S. House of Representatives and U.S. Senate passed a resolution supporting the goals and ideals of improving financial literacy, and declared April “Financial Literacy Month.” Larry Stein, Senior Vice President of Capital One’s Policy Affairs Group, sent a letter to the authors of the resolution, Senator Daniel Akaka (D-HI) and Representatives Ruben Hinojosa (D-TX) and Judy Biggert (R-IL), congratulating them on passage of the resolution, and describing Capital One’s educational programs and partnerships on financial literacy. As part of Financial Literacy Month, Capital One collaborated with the Representative Hinojosa Congressional Financial Literacy Caucus to promote increased financial submitted a copy of literacy skills at a fair in Washington, D.C., dedicated to the subject. Other Capital One’s letter in private, public and nonprofit organizations participated in the fair, as well. Capital One employees were on hand to showcase our financial literacy the Congressional Record. services and products that can help Americans manage debt and accumulate equity. During the year, Capital One co-sponsored a Jump$tart dinner in support of financial literacy at which Senator Mike Enzi (R-Wy) and Representative Earl Pomeroy (D-ND) were recognized as Jump$tart’s 2007 federal legisla- tors of the year. Richard Woods, Senior Vice President of Capital One’s Corporate Affairs Department, presented the award to Representative Pomeroy, noting his longtime advocacy of financial literacy for people of all ages. Capital One has developed partnerships with leading national nonprofit organiza- tions in order to train them to conduct our financial literacy programs on a local level. Through these efforts, Capital One is ensuring that its literacy programs will continue to run for years to come. In addi- tion, Capital One continues to work with policymakers to promote legislation that improves literacy skills for all consumers. Links to all our financial literacy programs, including “Finance Park” and “MoneyWi$e University,” can be found at Associate Gary Kensey and Drew at Capital One’s Finance Park. 9
  • 10. FINANCIAL LITERACy 2007 April 9, inojosa ubén H ives orable R ntat The Hon se of Represe ce Building Offi Hou House 5 U. S. ayburn 2463 R ton, D.C. 2051 Washing rt ancial dy Bigge ives ls of fin orable Ju and idea ntat g The Hon se of Represe Office Buildin e goals ion of th ou se U. S. H affirmat orth Hou 5 ensure ngw d its sential to . 273, an 1034 Lo ton, D.C. 2051 rs, acy is es s, entrepreneu r H. Res iggert: Washing pport fo cial liter a and B stor strong su nal finan useholds, inve . Hinojos our erso ives express resentat duals: “p , heads of ho tal principles ing to Dear Rep all indivi e workers I am writ en ills for proud of m- fundam ital One sponsibl e bill’s eracy sk cularly lf of Cap ancial lit , and become re supporter of th are parti in our local co On beha onth. try. We eater fin d bt ith nce of gr , credit, and de has been a prou the coun and others w ym literac es across porta tions s the im money ital One mmuniti income popula highlight ared to manage ral years, Cap ills in co slation e- eracy sk - and moderat The legi duals are prep ens.” For seve ancial lit w ring fin education to lo indivi ers, and citiz that tte ent to be lead cial l One/ business mmitm d deliver finan ed below. w: ips follo —Capita oing co obile partnersh program is unique, m e an on-g to develop an ram is describ gnature One has n and its . Th m ar og eate a si ement basics goal is to prep Capital faceted progra untry. This pr educatio e to cr cial in finan orldwid money manag an adult. The r multi- d across the co efforts ent W ents to ou chievem ehensive e-life of an munities 07. ud Junior A ghth-grade st day-in-th l markets in 20 ’s compr with ea ne apital O perienc and ei rtnered ditiona hts of C launch l One pa duce seventh- portunity to ex number of ad ction to ials with . Highlig , Capita sumer A ucation mater a tro In 2006 e Park – to in e students the op will travel to 27 states with Con e Park. ed it nc rtnered gual financial 0 CBOs from to the Financ ievement Fina cities to provid The mobile un ne pa • apital O free, multilin e than 40Os have access sions. or Ach led to select o, C ci Juni mor ancial de years ag to combine ed training to re that CB trave program to make wise fin five ore than first program s have deliver lp ensu ram to he ction. M students the a- ce sumer A rtnership. It is gional conferen a stipend prog r communities . cial educ th ee finan with Con hed bo y pa thei , re illion fr eracy across eyWi$e national literac s. Since 2001 s also establis d outreach in an 1.5 m • Mon i$e, a lit more th esses financial seminar Capital One ha n programs an MoneyWity training and Action, ution of dr educatio e distrib e program ad commun with Consumer nduct financial litate th rn- ate gove in Th le to faci Os nationwide. l and st Together they need to co s been ab with loca very active role CB l One ha ork of 7,300 ces ne works resour ita a ship, Cap rough a netw ided for free. s. apital O ne also played e past two year partner ges th nce, C ov O lt of this th onal Fina nwide. Capital al summit for ion is pr ngua As a resu hures in five la rs. All informat for Pers duced oalition ol systems natioCoalition’s annu One intro ie tion broc d ethnic barr Capital p$tart C ts. the Jum in public scho -sponsored the onsible, -aged studen college e an resp incom with ancially ills to college um educates Together ion curriculum ital One has co come fin lition. ction sk ul at ed to be management niversity curric personal instru tart Coa ap cial educ – and C n they ne • Jump$ include a finan n in Virginia ey U ed formatio and basic mon e MoneyWi$e rsity has provid io ments to form a Coalit ts the in , th ding ve ve studensponsible spen puses in 2002 oneyWi$e Uni g to directly helpin gi . To help minars on cam ent. M h re niversity program to teac st introduced dget managem ation se Wi$e U cial educ ,a fir bu • Money i$e University with Visa and of credit and ent finan untry. pres rams sociates ts ip MoneyW in partnersh ental elemen s around the co One prog pre- which as Capital ed through am campuse Develop about the fund to lead ceted and com program on five n-profits ti-fa students ds of students ongoing . ining no One has a mul cation. s an ch to tra l One ha t organizations re to hund l du ts approa clients, Capita .com/financiale ts. Capita Literacy grassroo en al Effor unity developm n ne tions, a ofit organizatio www.capitalo onomic ng Loc l and Ec organiza • Ongoi of local comm pr at Financia n-profit n to local non- can be found the s l no to client g nationa cial educatio our programs ship with in er ith lead ing lead an to ships w delivery of fin literacy. Links ur ongo h partner 3 and yo ct Throug l level, and dire oving financial Res. 27 n of H. pr on a loca proach to im troductio ur in ap u for yo hensive thank yo ld like to we wou ess. Again, ongr in C Caucus y, Sincerel ffairs licy A ein Larry St ice President, Po Senior V 10
  • 11. STATE LEGISLATIVE LINEUP Across the states Capital One monitors and reports on key legislative actions in all 50 states and the District of Columbia; how- ever, Capital One has a direct lobbying presence in five key states (shown below). n key States In 2007, the Capital One engaged and monitored more than 2,000 pieces of state legislation. 11
  • 12. CAPITAL ONE ASSOCIATES POLITICAL FUND Fund Metrics 2007 Amount raised ...................................................................................$404,308 Year-over-Year Decrease ...................................................................................-22.5% Candidates Supported ............................................................................................96 Capital One Contributors ...................................................................................1,157 Leadership PACs Supported ....................................................................................17 Leadership PACs Total ....................................................................................$62,500 Political Fundraising Entities Supported....................................................................4 Political Entities Total.................................................................................... $60,000 Trade Association PACs Supported ...........................................................................3 Trade Association Total ..................................................................................$15,000 CAPITAL ONE CONTRIBUTIONS FOR 2007 1 Democrat 49% Republican 42% Non-Partisan 9% 1 Based on internal tracking of contributions to candidates for single year. Criteria for Candidate selection The purpose of the Capital One Associates Political Fund is to unify the voices of our associates in the political process. Because Capital One associates have different philosophical beliefs, the Fund does not engage in non-business related issues. The Capital One Associates Political Fund is a nonpartisan organization. In deciding whether to make a Fund contribution, we consider a number of factors including: • Location of Capital One facilities within recipient’s district • Recipient’s understanding of the financial services industry or key issues • Membership in a key committee • Position in party leadership 12
  • 13. CAPITAL ONE ASSOCIATES POLITICAL FUND Capital One and the Competition Thousands 2007 ReCeIPTs 2007 PAC RECEIPTS $2,750 $2,500 $2,250 $2,000 $1,708 $1,750 $1,630 $1,500 $1,250 $1,225 $1,125 $868 $1,00 $750 $722 $500 $404 $384 $376 $250 $0 Wachovia Capital One American Express Wells Fargo Citigroup HSBC Bank of America JPMorgan Chase Receipts based on January 1 through December 31, 2007, Federal Election Commission Filings for the two-year cycle. 13
  • 14. CAPITAL ONE ASSOCIATES POLITICAL FUND Capital One Policy on Political Contributions Corporate Contribution Guidelines: Federal law prohibits corporations, such as Capital One, from making direct corporate contributions to federal candidates and political party committees. All contributions to federal candidates and political party committees are made through the Capital One Associates Political Fund, a federally registered political action committee. Capital One does make corporate political contributions at the state level, when permissible by state campaign finance law. Both state and federal political contribution decisions are made by a contributions committee, with final approval and signoff from the Senior Vice President of Policy Affairs. Political Action Committee (PAC) Contributions: Capital One administers, and pays the administrative expenses, of the Capital One Associates Political Fund (Capital One PAC), a political action committee registered with the Federal Election Commission. All contribu- tions to the Capital One PAC are donated voluntarily by Capital One employees, as federal law prohibits corpo- rate donations to PACs. The Capital One PAC board is comprised of employees who represent a broad range of internal business lines. The PAC board is responsible for overseeing overall solicitation and fundraising drives for the PAC, as well as assisting with communicating the role and importance of the PAC throughout the company. The contributions committee is tasked with recommending which federal candidates the Capital One PAC should support, with final approval and signoff from the Senior Vice President of Policy Affairs. The Policy Affairs Group also provides the Capital One Corporate Board of Directors with a yearly update on the PAC and its activities. All PAC contributions are reported to the Federal Election Commission and are publicly available. Trade Group Memberships: Capital One belongs to several trade associations and pays regular dues as required for membership. Capital One fulfills all legal requirements by reporting these dues as a part of its compliance with federal (Lobbying Disclosure Act of 1995) and state lobbying and ethics filing disclosures. Trade Associations and Organizations to which Capital One belongs: American Bankers Association Financial Services Roundtable American Financial Services Association U.S. Chamber of Commerce Republican Attorneys General Association Democratic Attorneys General Association Virginia Bankers Association Louisiana Bankers Association New york Bankers Association New Jersey Bankers Association National Card Coalition 14
  • 15. CAPITAL ONE ASSOCIATES POLITICAL FUND The Capital One PAC-Match Program The Capital One PAC-Match program enables PAC contributors to support their favorite 501(c)(3) designated organization(s) with a dollar-for-dollar match from Capital One, up to the maximum donation of $5,000 per calendar year. The following guidelines have been established for the PAC-Match program. Suggested Annual Contribution Tier Eligible for 100% PAC-Match President, “C” Roles/Executive VP $5,000 Senior VP $3,000 Managing VP/Vice President $1,500 Senior Director/Director $800 Senior Manager/Manager $600 Suggested Annual Contribution Tier Eligible for 50% PAC-Match President, “C” Roles/Executive VP $2,000 Senior VP $1,000 Managing VP/Vice President $750 Senior Director/Director $500 Senior Manager/Manager $350 Capital One and participating associates are not eligible for a tax deduction through the PAC-Match program. Participation is voluntary. No one will be favored or disadvantaged because of the amount of a contribution or a decision not to contribute. The names of individual contributors are not published internally. However, federal law requires that the Capital One Associates Political Fund file a report with the Federal Election Commission (FEC) listing each person who contributes $200 or more per calendar year. This information is public record. Contributions to the Capital One Associates Political Fund are not tax deductible. Only citizens and permanent residents of the United States may contribute to the PAC. 15
  • 16. CAPITAL ONE ASSOCIATES POLITICAL FUND – 2007 CONTRIBUTIONS CANDIDATE CHAMBER POSITION OR COMMITTEE CONTRIBUTION Bachmann, Michele HOUSE (R-MN6) Financial Services $1, 000 Bachus, Spencer HOUSE (R-AL6) Financial Services $7, 500 Baker, Richard HOUSE (R-LA6) Financial Services, Transportation and Infrastructure, Veterans Affairs $4, 000 Barrett, J. Gresham HOUSE (R-SC3) Budget, Financial Services, Foreign Affairs, Standards of Official Conduct $2, 500 Barton, Joe HOUSE (R-TX6) Energy and Commerce $1, 500 Baucus, Max SENATE (D-MT) Finance Committee $2, 500 Bean, Melissa HOUSE (D-IL8) Financial Services, Small Business $5, 000 Bennett, Robert SENATE (R-UT) Appropriations, Banking, Housing, and Urban Affairs, Joint $2, 000 Economic, Joint Library, Joint Printing, Rules and Administration Berman, Howard HOUSE (D-CA28) Foreign Affairs, Judiciary $1, 500 Biggert, Judy HOUSE (R-IL13) Education and Labor, Financial Services, Science and Technology $1, 000 Blackburn, Marsha HOUSE (R-TN7) Energy and Commerce, Select Energy Independence & Global Warning $1, 500 Blunt, Roy HOUSE (R-MO7) Minority Whip, Energy and Commerce $5, 000 Boehner, John HOUSE (R-OH8) Minority Leader, Select Intelligence $7, 500 Boren, Daniel HOUSE (D-Ok2) Armed Services, Financial Services, Natural Resources $1, 000 Boucher, Rick HOUSE (D-VA9) Energy and Commerce, Judiciary $3, 000 Cantor, Eric HOUSE (R-VA7) Ways and Means $6, 000 Capito, Shelley HOUSE (R-WV2) Financial Services, Transportation and Infrastructure $1, 000 Cardoza, Dennis HOUSE (D-CA18) Agriculture, Rules $1, 000 Carper, Tom SENATE (D-DE) Banking, Housing and Urban Affairs, Homeland Security and $3, 100 Government Affairs, Commerce Science and Transportation, Enviroment and Public Works Castle, Michael HOUSE (R-DE) Education and Labor, Financial Services $6, 000 Clyburn, James HOUSE (D-SC6) Majority Whip, Appropriations $4, 000 Coleman, Norm SENATE (R-MN) Agriculture, Nutrition, and Forestry, Foreign Relations, Homeland $3, 500 Security and Governmental Affairs, Senate Caucus on International Narcotics Control, Small Business and Entrepreneurship, Special Aging Collins, Susan SENATE (R-ME) Armed Services, Homeland Security and Governmental Affairs, $2, 500 Special Aging Cornyn, John SENATE (R-TX) Armed Services, Budget, Judiciary, Select Ethics $1, 000 Davis, Artur HOUSE (D-AL7) House Administration, Judiciary, Ways and Means $1, 000 Davis, Geoffrey HOUSE (R-ky4) Financial Services, Armed Services $1, 000 Davis, Thomas HOUSE (R-VA11) Homeland Security, Oversight & Government Reform $5, 000 Dodd, Christopher* PRESIDENT OF U.S. Banking, Housing and Urban Affairs, Foreign Relations, Rules and $5, 000 (D-CT) Administration Dole, Elizabeth SENATE (R-NC) Armed Services, Banking, Housing, and Urban Affairs, Small Business $2, 000 and Entrepreneurship, Special Aging Donnelly, Joseph HOUSE (D-IN2) Financial Services, Agriculture, Veteran’s Affairs $1, 000 Dorgan, Byron SENATE (D-ND) Appropriations, Commerce, Science, and Transportation, Energy and $1, 000 Natural Resources, Indian Affairs, Rules and Administration Drake, Thelma HOUSE (R-VA2) Armed Services, Transportation and Infrastructure $2, 000 *PAC donation was made to Dodd’s campaign for the Democratic nomination for President of the United States. 16
  • 17. CAPITAL ONE ASSOCIATES POLITICAL FUND – 2007 CONTRIBUTIONS Ellsworth, Brad HOUSE (D-IN8) Small Business, Armed Services, Agriculture $2, 500 Emanuel, Rahm HOUSE (D-IL5) Ways and Means $1, 000 Feeney, Tom HOUSE (R-FL24) Financial Services, Judiciary, Science and Technology $2, 000 Ferguson, Mike HOUSE (R-NJ7) Energy and Commerce $1, 000 Forbes, J. Randy HOUSE (R-VA4) Armed Services, Judiciary $1, 000 Frank, Barney HOUSE (D-MA4) Financial Services $1, 000 Gillmor, Paul HOUSE (R-OH5) Financial Services $2, 500 Gohmert, Louis HOUSE (R-TX1) Judiciary, Resources, Small Business $1, 000 Green, Al HOUSE (D-TX9) Financial Services, Homeland Security $2, 500 Hagel, Chuck SENATE (R-NE2) Banking, Housing, and Urban Affairs, Foreign Relations, Rules and $4, 000 Administration, Select Intelligence Hensarling, Jeb HOUSE (R-TX5) Financial Services, Budget $3, 500 Hill, Baron HOUSE (D-IN9) Energy and Commerce, Joint Economic, Science and Technology [22] $1, 000 Hinojosa, Ruben HOUSE (D-TX15) Education and Labor, Financial Services, Foreign Affairs $1, 000 Hodes, Paul HOUSE (D-NH2) Financial Services, Oversight & Government Reform $1, 000 Hooley, Darlene HOUSE (D-OR5) Budget, Energy and Commerce, Science and Technology $2, 000 Hoyer, Steny HOUSE (D-MD5) Majority Leader, Appropriations $10, 000 kanjorski, Paul HOUSE (D-PA11) Financial Services, Oversight & Government Reform, $1, 000 Science and Technology kind, Ron HOUSE (D-WI3) Natural Resources, Ways and Means $1, 500 klein, Ron HOUSE (D-FL) Financial Services, Foreign Affairs $2, 000 klobuchar, Amy SENATE (D-MN) Agriculture, Nutrition, and Forestry, Commerce, Science, and $1, 000 Transportation, Environment and Public Works, Joint Economic Landrieu, Mary SENATE (D-LA2) Appropriations, Energy and Natural Resources, Homeland Security $3, 500 and Governmental Affairs, Small Business and Entrepreneurship LaTourette, Steven HOUSE (R-OH14) Financial Services, Transportation and Infrastructure $1, 000 Leahy, Patrick SENATE (D-VT) Agriculture, Nutrition, and Forestry, Appropriations, Judiciary $1, 500 Levin, Carl SENATE (D-MI) Armed Services, Homeland Security and Governmental Affairs, Select $5, 000 Intelligence, Small Business and Entrepreneurship Lucas, Frank HOUSE (R-Ok3) Agriculture, Financial Services, Science and Technology $1, 000 Maloney, Carolyn HOUSE (D-Ny14) Financial Services, Joint Economic, Oversight & Government Reform $2, 500 Marshall, Jim HOUSE (D-GA3) Agriculture, Armed Services, Financial Services $1, 000 Martinez, Mel SENATE (R-FL) Banking, Housing and Urban Affairs, Energy and Natural Resources, $1, 000 Armed Services McCrery, Jim HOUSE (R-LA4) Joint Taxation, Ways and Means $1, 500 McHenry, Patrick HOUSE (R-NC10) Financial Services, Budget, Oversight and Government Reform $2, 000 Meeks, Gregory HOUSE (D-Ny6) Financial Services, Foreign Affairs $4, 500 Melancon, Charles HOUSE (D-LA3) Energy and Commerce, Science and Technology $2, 500 Moore, Dennis HOUSE (D-kS3) Budget, Financial Services $6, 000 Perlmutter, Edwin HOUSE (D-CO7) Financial Services, Homeland Security $1, 000 Pryce, Deborah HOUSE (R-OH15) Financial Services $1, 000 Pryor, Mark SENATE (D-AR) Commerce, Science, and Transportation, Rules and Administration, $3, 500 Homeland Security and Government Affairs, Small Business, Ethics Putnam, Adam HOUSE (R-FL12) Financial Services $1, 000 Reed, Jack SENATE (D-RI) Appropriations, Armed Services, Banking, Housing, and Urban $6, 000 Affairs, Health, Education, Labor, and Pensions 17
  • 18. CAPITAL ONE ASSOCIATES POLITICAL FUND – 2007 CONTRIBUTIONS Reid, Harry SENATE (D-NV) Majority Leader, Select Intelligence $5, 000 Renzi, Rick HOUSE (R-AZ1) Financial Services, Natural Resources $1, 000 Rogers, Mike HOUSE (R-MI8) Energy and Commerce, Intelligence $1, 000 Roskam, Peter HOUSE (R-IL6) Financial Services $2, 500 Ross, Michael HOUSE (D-AR4) Energy and Commerce, Science and Technology $2, 500 Royce, Edward HOUSE (R-CA40) Financial Services, Foreign Affairs $1, 000 Schumer, Charles SENATE (D-Ny) Banking, Housing, and Urban Affairs, Finance, Joint Economic, $5, 000 Joint Library, Judiciary, Rules and Administration Scott, Bobby HOUSE (D-VA03) Judiciary, Education and Labor, Budget $1, 000 Scott, David HOUSE (D-GA13) Agriculture, Financial Services, Foreign Affairs $1, 000 Serrano, Jose HOUSE (D-Ny16) Appropriations $1, 000 Shays, Christopher HOUSE (R-CT4) Financial Services, Homeland Security, Oversight & Government Reform $1, 000 Shelby, Richard SENATE (R-AL1) Appropriations, Banking, Housing, and Urban Affairs, Special Aging $1, 000 Smith, Gordon SENATE (R-OR) Commerce, Science, and Transportation, Energy and Natural $1, 500 Resources, Finance, Indian Affairs, Special Aging Specter, Arlen SENATE (R-PA) Appropriations, Judiciary, Special Aging, Veterans Affairs $2, 000 Spratt, John HOUSE (D-SC5) Armed Services, Budget $1, 000 Stabenow, Debbie SENATE (D-MI02) Finance, Agriculture, Budget $2, 000 Sununu, John SENATE (R-NH1) Finance, Commerce, Science and Transportation, $6, 000 Homeland Security and Government Affairs Towns, Edolphus HOUSE (D-Ny10) Energy and Commerce, Oversight and Government Reform $1, 000 Upton, Fred HOUSE (R-MI6) Energy and Commerce $2, 500 Velazquez, Nydia HOUSE (D-Ny12) Financial Services, Small Business $3, 500 Walden, Greg HOUSE (R-OR2) Energy and Commerce, Select Energy Independence & Global Warning $500 Warner, Mark SENATE (D-VA) Candidate $2, 500 Watt, Melvin HOUSE (D-NC12) Financial Services, Judiciary $1, 000 Webb, James SENATE (D-VA) Armed Services, Foreign Relations, Joint Economic, Veterans Affairs $2, 000 Whitfield, Ed HOUSE (R-ky1) Energy and Commerce $2, 500 Wittman, Rob HOUSE (R-VA01) Armed Services $1, 000 $232, 600 18
  • 19. CAPITAL ONE ASSOCIATES POLITICAL FUND – 2007 CONTRIBUTIONS LEADERSHIP PACS SPONSOR AMOUNT All America PAC Sen. Evan Bayh (D-IN) $1,000 AmeriPAC Rep. Steny Hoyer (D-MD) $5,000 Citizens for Action Rep. Paul kanjorski (D-PA) $3,500 Defend America PAC Sen. Richard Shelby (R-AL) $5,000 Dirigo PAC Sen. Susan Collins (R-ME) $2,500 First State PAC Sen. Thomas Carper (D-DE) $5,000 Freedom Fund Sen. Mike Crapo (R-ID) $5,000 Growth & Prosperity PAC Rep. Spencer Bachus (R-AL) $5,000 Impact Sen. Charles Schumer (D-Ny) $5,000 Joe PAC Rep. Joseph Crowley (D-Ny) $2,000 New Millenium PAC Sen. Robert Menendez (D-NJ) $5,000 PETE PAC Rep. Pete Sessions (R-TX) $2,500 Rely on your Beliefs Fund Rep. Roy Blunt (R-MO) $5,000 Searchlight Leadership Fund Sen. Harry Reid (D-NV) $5,000 South Dakota First Sen. Tim Johnson (D-SD) $1,500 The Blue Grass Committee Sen. Mitch McConnell (R-ky) $5,000 The Good Fund Rep. Bob Goodlatte (R-VA) $2,500 Narragansett Bay PAC Sen. Jack Reed (D-RI) $2,000 $67,500 Contributions to Congressional Party Organizations and Leadership PACs As a part of Capital One’s engagement strategy to maximize its voice, the PAC also makes contributions to certain trade association PACs to which Capital One belongs. In addition, periodic contributions are made to leadership PACs of particular members. A leadership PAC is set up by a member of Congress, and funds are distributed as member-to-member contributions. These are especially important for individuals in party leadership positions, because they give the member a vehicle for financially supporting candidates with whom the donor member is philosophically aligned. PARTy RELATED CONTRIBUTIONS TRADE ASSOCIATIONS Direct Voice, The PAC of the DMA $5,000 Democratic Senatorial Campaign Committee $15,000 Financial Services Roundtable PAC $5,000 National Republican Congressional Committee $15,000 TCFC-PAC $2,500 Democratic Congressional Campaign Committee $15,000 ABA BankPAC $5,000 National Republican Senatorial Committee $15,000 $17,500 $60,000 19