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2007 Annual Report Policy Affairs Group Capital One Associates Political Fund

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Page 1: capital one 2007 Policy Affairs Group Annual Report

2007 Annual ReportPolicy Affairs Group

Capital One Associates Political Fund

Page 2: capital one 2007 Policy Affairs Group Annual Report

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• 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

TAble OF COnTenTs

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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.

Product Design

• Fair Credit Reporting Act• Equal Credit Opportunity Act• Electronic Signatures in Global and

National Commerce Act (E-Sign)• Electronic Funds Transfer Act• Regulation Q (limitations

on interest on deposits)• Federal Deposit Insurance Regulations• US Postal Service Regulations• Real Estate Settlement Procedures Act

Offer

• Truth in Lending Act• Fair Credit Reporting Act• Equal Credit Opportunity Act• State Laws regarding mail, Internet

and telephone solicitations; and disclosure requirements

• Telephone Consumer Protection Act• Telemarketing Sales Rule• Truth in Savings Act• US Postal Service Regulations• Home Mortgage Disclosure Act• Fair Housing Act• Federal Trade Commission Act• CAN-SPAM

Account evaluation

• Equal Credit Opportunity Act• Fair Credit Reporting Act• State Laws regarding

credit evaluation• Bank Secrecy Act/PATRIOT Act• Office of Foreign Assets Control

regulations• Home Mortgage Disclosure Act• Federal Trade Commission Act

Account set-up

• Electronic Funds Transfer Act• Truth in Lending Act• Fair Credit Reporting Act• Truth in Savings Act• Home Mortgage Disclosure Act• Real Estate Settlement Procedures Act

safety and soundness Regulation

• Capital regulations• Interstate Branching Act• Sarbanes-Oxley Act• Federal Deposit Insurance Act• Regulation O (loans to insiders)• Bank Bribery Act• Foreign Corrupt Practices Act • Transactions with Affiliates

regulations• Bank Holding Company Act• National Bank Act

Account Management

• Truth in Lending Act• Equal Credit Opportunity Act• Fair Credit Reporting Act• Fair Debt Collection Act• Electronic Funds Transfer Act• Electronic Signatures in Global and

National Commerce Act (E-Sign)• State Laws regarding customer

agreements; grace periods; collection laws; advertisements

• State Laws regarding auto finance and mortgages

• Expedited Funds Availability Act• Office of Foreign Assets

Control regulations• Regulation Q (limitations on

interest on deposits)• US Postal Service Regulations• Fair Housing Act• Federal Trade Commission Act • CAN-SPAM• Bankruptcy Act• Service Members Civil Relief Act

Privacy and Information security

• Gramm-Leach-Bliley Act • Fair Credit Reporting Act• Federal information-security

and data-breach guidance• State credit-freeze and

data-breach laws

legislative Controls and Our business

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.

LEGISLATION TOUCHES ALL ASPECTS OF OUR COMPANy

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CAPITAL ONE TESTIFIES BEFORE U.S. CONGRESS – SENATE

Congressional Hearing on Credit Cards before the U.s. senate banking Committee

On January 25, 2007, John Finneran, Capital One’s General Counsel and Corporate Secretary, appeared on behalf of Capital One before the U.S. Senate Committee on Banking, Housing, and Urban Affairs. The hearing was titled “Examining the Billing, Marketing, and Disclosure Practices of the Credit Card Industry, and Their Impact on Consumers.”

Chairman Chris Dodd (D-CT) indicated that this hear-ing was the first in a “series” of hearings on credit card issues and noted that the industry is criticized for certain practices, specifically citing two-cycle 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.

During the course of the discussion, Committee members also described the obvious benefits provided through innovation by credit card issuers, with some indicating a desire to allow the market-place to function without new governmental or regulatory restrictions or prohibitions.

The industry witnesses refuted the claims of the critics, but acknowledged that existing disclosure requirements are complex and can result in consumer confusion.

In addition to the industry witnesses, the Committee called a number of witnesses who were critical of the industry to testify.

Chairman Dodd indicated that he looked forward to working with interested parties, including industry representatives, in developing legislative solutions to the issues that were raised.

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Ryan Schneider, President, Card, testifies during a Permanent Subcommittee on Investigations (Senate Homeland Security and Government Affairs Committee) hearing on December 4, 2007.

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.

• The hearing also focused on the lack of clarity in communications to consumers from credit card companies when this occurs.

• This was the PSI’s second hearing on credit card practices and the first in which Capital One was asked to testify.

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) praised the clarity of Capital One’s CIT notice.

Ryan Schneider, President, Card, greets Senator Carl Levin (D-MI), Chairman of the Senate’s Permanent Subcommittee on Investigations.

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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.

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CAPITAL ONE TESTIFIES BEFORE U.S. CONGRESS – HOUSE

2007 Congressional Hearing on Credit Cards before the U.s. House of Representatives

The U.S. House of Representatives Committee on Financial Services focused on issues impacting the consumer credit arena during 2007. Specifically, the Committee focused on the contractual terms that are used within the credit card industry, as well as the Federal Reserve Board’s draft proposal to update Regulation Z under the Truth in Lending Act (TILA).

On June 7, 2007, John Finneran, General Counsel, testified on behalf of Capital One before the Committee’s Subcommittee on Financial Institutions and Consumer Credit during a hearing entitled “Improving Credit Card Consumer Protection: Recent Industry and Regulatory Initiatives.”

The two-panel hearing featured testi-mony from regulators, Federal Reserve Board Governor Frederic Mishkin and Comptroller of the Currency John Dugan. In addition, representatives from the industry, consumer groups and small business testified about proposed changes to Regulation Z. The hearing also examined recent industry reforms, including initia-tives to change certain practices such as universal default and double-cycle billing, which had come under heavy criticism.

In his remarks, Finneran endorsed the Fed’s proposed changes to Regulation Z and stated that “the Federal Reserve’s effort marks a landmark advance in how disclosures are developed.” Finneran noted that Capital One does not engage in universal default practices or double-cycle billing, and that the new Regulation Z disclosures would shed more light on 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.

2008 Credit Card bill Introduced in the U.s. House of Representatives

While several bills were introduced in 2007 that would limit a variety of credit card practices, none saw substantive legislative action. The three issues that garnered the most attention were double-cycle billing and universal default – practices that Capital One does not engage in – and applying rate increases to the customer’s outstanding balance, not just future transactions. Other issues that Congress has expressed interest in include overlimit transactions

and fees, payment allocation methods, grace periods, payment deadlines, residual/trailing

interest, accounts with high fees relative to credit line, and appropriate conditions under which to increase interest rates and how that is disclosed.

In 2008, congressional scrutiny of these issues continues, and has resulted in the

development of new legislation. House Financial Services Committee Chairman

Barney Frank (D-MA) expressed a strong desire to introduce additional legislation, and Subcommittee Chair Carolyn Maloney (D-Ny) has introduced a bill to address many of these issues. The first hearing on this bill was heard on March 13, 2008, and an additional hearing is expected.

Capital One will continue to provide leadership for our industry trade groups to educate Congress about the potential unintended consequences and negative impacts such legislation could have on the industry, consumers and the economy. If passed, this legisla-tion could raise interest rates and decrease access to credit at a time when the U.S. economy is already constrained by a credit crunch.

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MAkING OUR COMMUNITIES SAFER

Capital One serves on Financial Coalition Against Child Pornography

In 2006, Capital One joined the Financial Coalition Against Child Pornography. The Coalition, which includes leading banks, credit card

companies, third-party payment companies and Inter-net service providers, is dedicated to fighting child pornography over the Internet. In its press release announcing Capital One’s involvement, Ernie Allen, President and CEO of the National Center for Missing & Exploited Children (NCMEC) and Chairman of the Coalition, stated that the mission of the group is “to eliminate the commercial viability of child pornography by stopping the flow of money. As an integral participant in the financial services industry, Capital One will help us accomplish that goal.”

Senator Richard Shelby (R-AL), Ranking Member of the U.S. Senate Banking, Housing, and Urban Affairs Committee, was the catalyst for bringing the industry leaders together to address these problems. Senator Shelby’s staff members, as well as other congressional staffers, regularly attend the Coalition’s meetings. In 2006, a number of congressional hearings were held on this issue in both the House and Senate, where NCMEC President Allen testified, along with represen-tatives from Visa, MasterCard, and American Express.

The Coalition has established a global clearinghouse on child pornography to provide a unified system for identifying illegal activities and sharing information between Coalition companies. Coalition members report child pornography to the clearinghouse; it is then reviewed, and feedback is provided to ensure action is taken to stop illegal practices.

Throughout 2007, with a partnership among its Policy Affairs, Legal and Fraud Departments, Capital One has remained an active member of the Coalition. The Coalition has grown during this time, adding many new members and supporters to this important cause, and making substantial progress on its goal. NCMEC reports that child pornography has become a

multibillion-dollar commercial enterprise. The Coalition is working diligently to ensure that credit cards and other payment methods cannot be used to purchase child pornography.

Capital One serves on Virginia Attorney General’s Youth Internet safety Task Force

In 2006, Capital One served on Virginia Attorney General Bob McDonnell’s youth Internet Safety Task Force. The primary goal of the Task Force was to keep children safer online. In addition to Capital One, members of the Task Force included AOL, MySpace, Microsoft and other technology companies, as well as educators, parents, law enforcement officials and elected officials. The Task Force issued a final report in December 2006, after six months of meetings. At his press conference announcing the work of the Task Force, Attorney General McDonnell stated, “In addition to increasing Internet safety awareness, we are also proposing tough new sentences for those engaged in the production and financing of child pornography, and for those who unlawfully solicit children online. Finally, we have identified a number of changes in the law that will aid in the investigation of Internet crimes.”

In 2007, Capital One was asked by the Attorney General to serve on the Implementation Committee, to ensure that the report’s recommendations were put into effect. Also in 2007, Attorney General McDonnell submitted a significant legislative package to the Virginia General Assembly in order to provide the necessary legal authority to the Task Force’s recommendations; the vast majority of these provisions were enacted into law during that session. Capital One continues to serve on the Implementation Committee and to partner closely with the Attorney General and his staff.

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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 Congressional Financial Literacy Caucus to promote increased financial literacy skills at a fair in Washington, D.C., dedicated to the subject. Other private, public and nonprofit organizations participated in the fair, as well. Capital One employees were on hand to showcase our financial literacy 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 www.capitalone.com/financialeducation.

Representative Hinojosa submitted a copy of Capital One’s letter in the Congressional Record.

Associate Gary Kensey and Drew at Capital One’s Finance Park.

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FINANCIAL LITERACy

April 9, 2007

The Honorable Rubén Hinojosa

U. S. House of Representatives

2463 Rayburn House Office Building

Washington, D.C. 20515

The Honorable Judy Biggert

U. S. House of Representatives

1034 Longworth House Office Building

Washington, D.C. 20515

Dear Representatives Hinojosa and Biggert:

On behalf of Capital One I am writing to express our strong support for H. Res. 273, and its affirmation of the goals and ideals of financial

literacy month.

The legislation highlights the importance of greater financial literacy skills for all individuals: “personal financial literacy is essential to ensure

that individuals are prepared to manage money, credit, and debt, and become responsible workers, heads of households, investors, entrepreneurs,

business leaders, and citizens.” For several years, Capital One has been a proud supporter of the bill’s fundamental principles.

Capital One has an on-going commitment to bettering financial literacy skills in communities across the country. We are particularly proud of

our multi-faceted program to develop and deliver financial education to low- and moderate-income populations and others within our local com-

munities and across the country. This program is described below.

Highlights of Capital One’s comprehensive efforts in financial education and its partnerships follow:

• Finance Park. In 2006, Capital One partnered with Junior Achievement Worldwide to create a signature program—Capital One/

Junior Achievement Finance Park – to introduce seventh- and eighth-grade students to money management basics. This unique, mobile

program traveled to select cities to provide students the opportunity to experience a day-in-the-life of an adult. The goal is to prepare

students to make wise financial decisions. The mobile unit will travel to a number of additional markets in 2007.

• MoneyWi$e with Consumer Action. More than five years ago, Capital One partnered with Consumer Action to launch

MoneyWi$e, a national literacy partnership. It is the first program to combine free, multilingual financial education materials with

community training and seminars. Since 2001, regional conferences have delivered training to more than 400 CBOs from 27 states.

Together with Consumer Action, Capital One has also established a stipend program to help ensure that CBOs have access to the

resources they need to conduct financial education programs and outreach in their communities.

As a result of this partnership, Capital One has been able to facilitate the distribution of more than 1.5 million free financial educa-

tion brochures in five languages through a network of 7,300 CBOs nationwide. The program addresses financial literacy across both

income and ethnic barriers. All information is provided for free.

• Jump$tart Coalition. Together with the Jump$tart Coalition for Personal Finance, Capital One works with local and state govern-

ments to include a financial education curriculum in public school systems nationwide. Capital One also played a very active role in

helping to form a Coalition in Virginia – and Capital One has co-sponsored the Coalition’s annual summit for the past two years.

• MoneyWi$e University. To help give students the information they need to become financially responsible, Capital One introduced

MoneyWi$e University, a program to teach responsible spending and basic money management skills to college-aged students.

Developed in partnership with Visa and first introduced on campuses in 2002, the MoneyWi$e University curriculum educates college

students about the fundamental elements of credit and budget management. MoneyWi$e University has provided personal instruction

to hundreds of students on five campuses around the country.

• Ongoing Local Efforts. Capital One has an ongoing program through which associates present financial education seminars directly

to clients of local community development organizations.

Through partnerships with leading national non-profit organizations, a grassroots approach to training non-profits to lead Capital One programs

on a local level, and direct delivery of financial education to local non-profit organization clients, Capital One has a multi-faceted and compre-

hensive approach to improving financial literacy. Links to our programs can be found at www.capitalone.com/financialeducation.

Again, we would like to thank you for your introduction of H. Res. 273 and your ongoing leadership with the Financial and Economic Literacy

Caucus in Congress.

Sincerely,

Larry Stein

Senior Vice President, Policy Affairs

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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).

In 2007, the Capital One engaged and monitored more than 2,000 pieces of state legislation.

n key States

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CAPITAL ONE ASSOCIATES POLITICAL FUND

Fund Metrics

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

2007 Amount raised ...................................................................................$404,308Year-over-Year Decrease ...................................................................................-22.5%Candidates Supported ............................................................................................96Capital One Contributors ...................................................................................1,157

Leadership PACs Supported ....................................................................................17Leadership PACs Total ....................................................................................$62,500

Political Fundraising Entities Supported....................................................................4Political Entities Total.................................................................................... $60,000

Trade Association PACs Supported ...........................................................................3Trade Association Total ..................................................................................$15,000

1CAPITAL ONE CONTRIBUTIONS FOR 2007Democrat 49%Republican 42%Non-Partisan 9%

1 Based on internal tracking of contributions to candidates for single year.

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CAPITAL ONE ASSOCIATES POLITICAL FUND

Capital One and the Competition

Receipts based on January 1 through December 31, 2007, Federal Election Commission Filings for the two-year cycle.

$2,750

$2,500

$2,250

$2,000

$1,750

$1,500

$1,250

$1,125

$1,00

$750

$500

$250

$0

$376$384 $404

$722

$1,225

$1,630$1,708

Thousands

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2007 PAC RECEIPTS2007 ReCeIPTs

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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 AssociationFinancial Services Roundtable

American Financial Services AssociationU.S. Chamber of Commerce

Republican Attorneys General AssociationDemocratic Attorneys General Association

Virginia Bankers AssociationLouisiana Bankers AssociationNew york Bankers Association

New Jersey Bankers AssociationNational Card Coalition

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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.

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.

TierSuggested Annual Contribution

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

TierSuggested Annual Contribution

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

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CAPITAL ONE ASSOCIATES POLITICAL FUND – 2007 CONTRIBUTIONS

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 Economic, Joint Library, Joint Printing, Rules and Administration

$2, 000

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 Government Affairs, Commerce Science and Transportation, Enviroment and Public Works

$3, 100

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 Security and Governmental Affairs, Senate Caucus on International Narcotics Control, Small Business and Entrepreneurship, Special Aging

$3, 500

Collins, Susan SENATE (R-ME) Armed Services, Homeland Security and Governmental Affairs, Special Aging

$2, 500

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. (D-CT)

Banking, Housing and Urban Affairs, Foreign Relations, Rules and Administration

$5, 000

Dole, Elizabeth SENATE (R-NC) Armed Services, Banking, Housing, and Urban Affairs, Small Business and Entrepreneurship, Special Aging

$2, 000

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 Natural Resources, Indian Affairs, Rules and Administration

$1, 000

Drake, Thelma HOUSE (R-VA2) Armed Services, Transportation and Infrastructure $2, 000

CANDIDATE CHAMBER POSITION OR COMMITTEE CONTRIBUTION

* PAC donation was made to Dodd’s campaign for the Democratic nomination for President of the United States.

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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 Administration, Select Intelligence

$4, 000

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, Science and Technology

$1, 000

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 Transportation, Environment and Public Works, Joint Economic

$1, 000

Landrieu, Mary SENATE (D-LA2) Appropriations, Energy and Natural Resources, Homeland Security and Governmental Affairs, Small Business and Entrepreneurship

$3, 500

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 Intelligence, Small Business and Entrepreneurship

$5, 000

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, Armed Services

$1, 000

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, Homeland Security and Government Affairs, Small Business, Ethics

$3, 500

Putnam, Adam HOUSE (R-FL12) Financial Services $1, 000

Reed, Jack SENATE (D-RI) Appropriations, Armed Services, Banking, Housing, and Urban Affairs, Health, Education, Labor, and Pensions

$6, 000

Page 18: capital one 2007 Policy Affairs Group Annual Report

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, Joint Library, Judiciary, Rules and Administration

$5, 000

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 Resources, Finance, Indian Affairs, Special Aging

$1, 500

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, Homeland Security and Government Affairs

$6, 000

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

Page 19: capital one 2007 Policy Affairs Group Annual Report

19

CAPITAL ONE ASSOCIATES POLITICAL FUND – 2007 CONTRIBUTIONS

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.

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

PARTy RELATED CONTRIBUTIONS

Democratic Senatorial Campaign Committee $15,000

National Republican Congressional Committee $15,000

Democratic Congressional Campaign Committee $15,000

National Republican Senatorial Committee $15,000

$60,000

TRADE ASSOCIATIONS

Direct Voice, The PAC of the DMA $5,000

Financial Services Roundtable PAC $5,000

TCFC-PAC $2,500

ABA BankPAC $5,000

$17,500