Urgent! Call to Extend the Comment Period on Capital One / ING Direct Merger

  • by: Consumers Union
  • recipient: Adam M. Drimer, Assistant Vice President, Federal Reserve Bank of Richmond
If the Capital One acquisition is approved without substantial regulatory review, it will signal a continuation of the same culture that brought us the foreclosure crisis, the financial crisis and financial institutions that were Too-Big-to-Fail and are even bigger today. This will undermine confidence in the U.S. financial system by consumers, investors and institutions around the world, and hurt the prospects for a strong economic recovery.

The Federal Reserve Board should not make a decision on whether this transaction is in the public interest without first giving the public a meaningful opportunity to express concerns. Under these circumstances, a 30-day written comment period is not meaningful for such a complex transaction.

Tell the Federal Reserve Board that the public deserves an opportunity to fully and completely raise their concerns in open hearings across the country.
I request a 60-day extension to the comment period and the scheduling of public hearings on Capital One Financial Corporation's proposal to acquire ING Direct. Local and nationwide concerns about Capital One and the banks they have acquired are so pervasive and serious that a 30-day written comment period will not suffice. Indeed, recent media reports indicate that Capitol One's planned acquisitions now include the credit card division of HSBC, a division with its own checkered past. The public deserves an opportunity to fully and completely raise their concerns in open hearings across the country.

In addition, I believe the following concerns also justify this request:

Too-Big-to-Fail. Capital One's proposed acquisition 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. Congress did not intend for systemically important financial institutions to be allowed to grow without clear and significant public benefits. Allowing public hearings on Capital One's proposed acquisition makes good on Dodd-Frank's commitment to hold systemically important financial institutions to a higher standard. It also realizes Dodd-Frank's promise to make the financial regulatory process more transparent. Simply put, the Federal Reserve Board should not make a decision on whether this transaction is in the public interest without first giving the public a meaningful opportunity to express concerns. Under these circumstances, a 30-day written comment period is not meaningful for such a complex transaction.

Transparency and oversight. With the passage of Dodd-Frank, new, overlapping and shifting regulatory responsibilities require rigorous consideration of the acquisition by the Office of the Comptroller of the Currency, the Consumer Financial Protection Bureau, the Federal Reserve and the Financial Stability Oversight Council. Under Dodd-Frank, FSOC has the power to hold hearings and a comment period; it should do so.

Past allegations of abusive financial practices need to be addressed and resolved. There are serious concerns about the potentially predatory nature of Capital One's credit card lending practices. Capital One's current and past customers deserve an opportunity to express their concerns before the Federal Reserve Board allows Capital One to expand. In addition, the Federal Reserve should allow time to gather potential Capitol One credit card complaints from the Consumer Financial Protection Bureau, which recently launched its complaint gathering mechanism. This need is reinforced by the news that Capital One will seek to acquire HSBC's credit card division.

(Your Comments Here)

These issues are far too important to resolve behind closed doors and in 30 days. I respectfully urge the Federal Reserve Board to extend the comment period by 60 days and hold five public hearings across the country to ensure that an adequate opportunity exists for the public to express the serious concerns that accompany Capital One's proposal to acquire ING Direct. Thank you for this opportunity to comment.
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