CAPITAL ONE FINANCIAL CORP (COF) Risk Factors

Recent key developments

Concrete developments — dated events, named agreements and instruments, legal proceedings — that CAPITAL ONE FINANCIAL CORP surfaced in its latest filing.

• In January 2025, a multi-day system outage occurred due to a technical issue at FIS, a third-party service provider, temporarily impacting certain services for some customers.January 2025
• On July 29, 2019, Capital One announced an outside individual gained unauthorized access on March 22-23, 2019, obtaining personal information of credit card applicants and customers (the 2019 Cybersecurity Incident).July 29, 2019
• In December 2025, the OCC issued a report of preliminary findings of its ongoing supervisory review of the nine largest OCC-regulated banks, including the Bank, to determine whether those banks may have debanked or discriminated against customers based on political or religious beliefs or lawful business activities.December 2025
• The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 provides a legal framework for stablecoins that may allow new and existing competitors to compete for deposits.2025
• In October 2023, the Federal Reserve released a notice of proposed rulemaking to further reduce the cap on interchange fees under Regulation II.October 2023
• In August 2025, a North Dakota district court ruled that the Federal Reserve exceeded its statutory authority when it originally promulgated Regulation II in 2011 and vacated the regulation, but stayed the vacatur order pending appeal, while a Kentucky district court upheld Regulation II.August 2025
• Antitrust lawsuits were filed in 2005 against Mastercard, Visa, and several member banks, including Capital One and its subsidiaries, alleging conspiracy to fix interchange fees.2005
• Silicon Valley Bank, Signature Bank and First Republic Bank were closed in 2023 and placed under FDIC receivership.2023
• The acquisition of Discover (the Transaction) exposes Capital One to additional risks, including integration challenges, assumed liabilities, and potential reclassification as a Category II institution.
• The Company has a $265 billion Community Benefits Plan over five years related to the Discover acquisition.
• The FDIC imposed a special assessment following the closures of Silicon Valley Bank and Signature Bank.