Capital One / ING Direct Acquisition

Background on Capital One / ING AcquisitionTA button
The National Community Reinvestment Coalition (NCRC) announced that it will oppose the Capital One acquisition of ING Direct USA, citing serious concerns about the impact of the deal on consumers, communities and the economy. The deal would make Capital One the fifth largest bank in the United States.
“We already have four too big too fail banks, why make a fifth?” said John Taylor, President & CEO of NCRC. “This is the most important test since the passage of Dodd-Frank of whether or not the bank regulatory culture has changed in this country. Should a systemically important bank be allowed to become bigger without a clear case that it will benefit society? The answer is emphatically no.”
NCRC has called on the Federal Reserve to oppose the proposed Capital One Financial Corporation acquisition of ING Direct USA.


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SUBJECT: Opposition to Capital One’s application to acquire ING Direct

Federal Reserve Bank of Richmond
Attn: Adam M. Drimer, Assistant Vice President
701 East Byrd Street
Richmond, VA 23261-4528
Re: Opposition to Capital One’s application to acquire ING Direct

Dear Mr. Drimer:

[Name of group/personal information] requests that Capital One Financial Corporation’s proposal to acquire ING Direct be denied. We have serious concerns about the impact of the deal on consumers, communities and the economy.

The following concerns justify this request:

Too-Big-to-Fail. Capital One’s proposed acquisition would make Capital One the fifth largest bank in the United States. Carefully examining this aspect of the deal represents the first true test of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) requirement that the Federal Reserve Board analyze systemic risk. Less than three years ago, the Department of Treasury deemed Capital One to be so intertwined in the American financial markets that the pending collapse of other financial institutions required a $3.55 billion injection of taxpayer dollars to buffer the bank’s balance sheet. Federal Reserve Board Governor Daniel Tarullo set this standard for the growth of firms like Capital One: “The regulatory structure for SIFIs [Systemically Important Financial Institutions] should discourage systemically consequential growth or mergers unless the benefits to society are clearly significant.” We have not seen a clear delineation of significant benefits. More products and more ATMs are not “clearly significant” benefits to society. Instead, they amount to little more than the natural consequences of merging any two previously distinct financial institutions. And, often after a merger, we have seen branches close.

Serious Concerns about Capital One’s Business Practices. We are concerned that recent changes to Capital One’s business policies have led to a pattern of discriminatory lending. For example, in 2010, Capital One implemented a policy that cut off Federal Housing Administration (FHA) loans to borrowers with credit scores between 580-620 even though FHA fully guarantees these loans. Capital One’s denial has a disparate impact by race in violation of our nation’s anti-discrimination laws. In fact, there are active lending discrimination complaints against Capital One. A review of CRA exams, Home Mortgage Disclosure Act data, and small business loan data demonstrate significant inconsistencies in the performance of the two banks in making services and branches available to low- and moderate-income communities.

Serious concerns about the potentially predatory nature of Capital One’s credit card lending practices. Attorneys General in Minnesota, West Virginia and California have each investigated Capital One for engaging false and misleading credit card marketing.

Capital One’s pattern of disinvestment from low- and moderate-income areas and communities of color. This lending pattern is demonstrated by their small business lending record. Capital One’s small business lending under the Small Business Administration 7(a) lending programs, a major source of business loans for minorities, women and veterans, has essentially evaporated over the past four years. In 2006, Capital One had roughly $22 billion in assets and did $228 million in 7(a) lending. By 2010, it had grown to over $96 billion in assets, but astonishingly made less than $600,000 in 7(a) loans. Small businesses are the backbone of our economy and they have been the principal catalyst for the economic recovery in the previous two recessions. Capitol One’s abandonment of a major small business lending market for women, minorities and veterans at such a crucial time does not warrant an expansion.

We respectfully urge the Federal Reserve Board to deny Capital One’s proposal to acquire ING Direct. We believe the deal would expand practices that are not beneficial to consumers, communities and the economy. Thank you for this opportunity to comment.         


[First Name]
[Name  of Organization]

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Redlining and Neighborhood Health

Before the pandemic devastated minority communities, banks and government officials starved them of capital.

Lower-income and minority neighborhoods that were intentionally cut off from lending and investment decades ago today suffer not only from reduced wealth and greater poverty, but from lower life expectancy and higher prevalence of chronic diseases that are risk factors for poor outcomes from COVID-19, a new study shows.

The new study, from the National Community Reinvestment Coalition (NCRC) with researchers from the University of Wisconsin–Milwaukee Joseph J. Zilber School of Public Health and the University of Richmond’s Digital Scholarship Lab, compared 1930’s maps of government-sanctioned lending discrimination zones with current census and public health data.

Table of Content

  • Executive Summary
  • Introduction
  • Redlining, the HOLC Maps and Segregation
  • Segregation, Public Health and COVID-19
  • Methods
  • Results
  • Discussion
  • Conclusion and Policy Recommendations
  • Citations
  • Appendix

Complete the form to download the full report: