Capital One
Capital One Financial Corporation
1680 Capital One Drive
McLean, VA 22102
Via E-mail and Hand Delivery
March 28, 2005
Jennifer J. Johnson
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, N.W.
Washington, D.C. 20551
Regs.Comments@FederalReserve.com
Re:
Advance Notice of Proposed Rulemaking: Truth in Lending
Docket No. R-1217
Dear Ms. Johnson:
Capital One Financial Corporation (“Capital One”) is pleased to submit comments
regarding the Board’s Advance Notice of Proposed Rulemaking on the subject of the open-
end credit provisions of Regulation Z.
Capital One Financial Corporation is a bank holding company whose principal
subsidiaries, Capital One Bank, Capital One, F.S.B., and Capital One Auto Finance, Inc.,
offer a variety of consumer lending products. Capital One’s subsidiaries collectively had 48.6
million accounts and $79.9 billion in managed loans outstanding as of December 31, 2004.
Capital One is a Fortune 500 company and, through its subsidiaries, is one of the largest
providers of MasterCard and Visa credit cards in the world.
Capital One commends the Board for undertaking this major project at this time. As
the Board notes, these provisions of Regulation Z have not been substantially updated in over
20 years, while in the meantime, the nature of the credit card industry has changed. For that
reason, Capital One recommends a number of enhancements to the Regulation Z disclosure
regime.
In a phase of change in the late 1980s and early 1990s, the credit card industry moved
from a regime of uniform, high interest rates, in which credit cards were available only to a
limited segment of the population, to a regime of lower interest rates differentiated according
to customers’ risk. Large savings were achieved for consumers overall by this
Comments on ANPR: Truth in Lending Docket No. R-1217
March 28, 2005
Page 2
transformation, footnote 1 and credit became more widely available to previously underserved
populations.