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United States securities and exchange commission logo
December 18, 2020
R. Scott Blackley
Chief Financial Officer
Capital One Financial Corp.
1680 Capital One Drive
McLean, Virginia 22102
Re: Capital One
Financial Corp.
Form 10-Q for the
Quarterly Period Ended September 30, 2020
Filed November 2,
2020
Form 8-K Furnished
October 22, 2020
File No. 1-13300
Dear Mr. Blackley:
We have reviewed your filing and have the following comments. In
some of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-Q for the Quarterly Period Ended September 30, 2020
Notes to Consolidated Financial Statements
Note 3 - Loans, page 93
1. We note that the loan
tables (3.1 through 3.5) include the impacts of the COVID-19
customer assistance
programs where applicable. In order for the reader to obtain a clear
understanding of the
impacts of the COVID-19 programs on the different types of loans
affected, please revise
future filings to address how these loans have been reflected in
each of the tables.
This can be done in separate tables or in footnote disclosure.
2. We note your tabular
presentations would appear to exclude accounts from the TDR
designation due to
regulatory exemptions. Please tell us what consideration has been
given to including a
supplemental table in future filings for those customer loans that
qualified for
regulatory exemption from TDR classification, in order to provide the reader
R. Scott Blackley
Capital One Financial Corp.
December 18, 2020
Page 2
with expanded insight into the underlying credit quality of those
customers. The
following are examples of information that would enhance transparency
and granularity of
your tabular and textual disclosures.
The number of accounts and related dollar amounts excluded by
loan type as well as
the types of loan modifications made.
The number (or percentage) of those customers that have made a
payment in the last
payment cycle.
The number (or percentage) of those customers that have made no
payments since
entering the program.
Provide a distribution by most recent FICO score (e.g., 660 and
above, 621-660, and
less than 620 or no scores).
Form 8-K furnished October 22, 2020
EX-99.2
Reconciliation of Non-GAAP Measures, page 22
3. Please revise your future filings to eliminate the presentation of a
full income statement of
non-GAAP measures. We reference Compliance and Disclosure
Interpretation (C&DI)
Question 102.10 on Non-GAAP Financial Measures.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
You may contact Michael Henderson, Staff Accountant at 202-551-3364 or
Marc
Thomas, Staff Accountant at 202-551-3452 if you have questions regarding
comments on the
financial statements and related matters.
FirstName LastNameR. Scott Blackley Sincerely,
Comapany NameCapital One Financial Corp.
Division of
Corporation Finance
December 18, 2020 Page 2 Office of
Finance
FirstName LastName