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CRA Evaluation Charter No. 13688

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CRA Evaluation Charter No. 13688 PUBLIC DISCLOSURE August 24, 2020 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Capital One, National Association Charter Number: 13688 1680 Capital One Drive McLean, Virginia 22102 Office of the Comptroller of the Currency Large Bank Supervision Constitution Center 400 7th Street, S.W. Mail Stop 8W-1 Washington, D.C. 20219 NOTE: This document is an evaluation of this institution’s record of meeting the credit needs of its entire community, including low- and moderate-income neighborhoods, consistent with safe and sound operation of the institution. This evaluation is not, and should not be construed as, an assessment of the financial condition of this institution. The rating assigned to this institution does not represent an analysis, conclusion, or opinion of the federal financial supervisory agency concerning the safety and soundness of this financial institution. Charter Number: 13688 Table of Contents Overall CRA Rating ................................................................................................................................. 1 Description of Institution ......................................................................................................................... 3 Scope of the Evaluation ............................................................................................................................ 5 Discriminatory or Other Illegal Credit Practices Review ................................................................... 11 Multistate Metropolitan Statistical Area Rating ................................................................................. 12 New York-Newark, NY-NJ-CT-PA Combined Statistical Area (New York CSA) .............................................................. 12 Philadelphia-Camden-Wilmington, PA-NJ-DE-MD Multistate Metropolitan Statistical Area (Philadelphia MMSA) ........25 Washington-Baltimore-Arlington, DC-MD-VA-WV-PA Combined Statistical Area (Washington, DC CSA) ...................35 State Rating ............................................................................................................................................. 48 State of California................................................................................................................................................................. 48 State of Colorado .................................................................................................................................................................. 63 State of Delaware.................................................................................................................................................................. 72 State of Florida ...................................................................................................................................................................... 80 State of Illinois ...................................................................................................................................................................... 90 State of Louisiana ................................................................................................................................................................. 99 Commonwealth of Massachusetts ....................................................................................................................................... 120 State of Minnesota .............................................................................................................................................................. 137 State of Oregon ................................................................................................................................................................... 146 State of Texas...................................................................................................................................................................... 153 Commonwealth of Virginia ................................................................................................................................................ 179 State of Washington ............................................................................................................................................................ 188 Appendix A: Scope of Examination .................................................................................................... A-1 Appendix B: Summary of MMSA and State Ratings ........................................................................ B-1 Appendix C: Definitions and Common Abbreviations...................................................................... C-1 Appendix D: Tables of Performance Data.......................................................................................... D-1 Charter Number: 13688 Overall CRA Rating Institution’s CRA Rating: This institution is rated Outstanding. The following table indicates the performance level of Capital One, National Association (CONA, or the bank) with respect to the Lending, Investment, and Service Tests: Capital One, National Association Performance Tests Performance Levels Lending Test* Investment Test Service Test Outstanding X X High Satisfactory X Low Satisfactory Needs to Improve Substantial Noncompliance * The Lending Test is weighted more heavily than the Investment and Service Tests when arriving at an overall rating. The major factors that support this rating include: The Lending Test rating is based on an Outstanding rating in all the bank’s rating areas. The Investment Test rating is based on an Outstanding rating in all the bank’s rating areas. The New York CSA AA and the Washington, DC CSA AA, which represent the bank’s most significant markets in terms of deposits and branch distribution, were rated High Satisfactory and Outstanding, respectively, and carried the greatest weight in our overall conclusions. Flexible and Innovative Lending Products CONA offered flexible home mortgage and small business lending programs in order to serve assessment area (AA) credit needs. Flexible lending programs included Community Home Buyers (CHB), Dream, Federal Housing Administration (FHA), Veterans Affairs (VA), and Small Business Administration (SBA) loans. The CHB and Dream loans were portfolio products, which allowed for more flexible underwriting that considered the individual borrower’s unique circumstances. The bank offered its Dream product in Louisiana and Texas, and its CHB product in the Northeast and Mid- Atlantic, to finance the purchase of homes by low- and moderate-income (LMI) borrowers and/or in LMI geographies. They featured low down payment requirements without private mortgage insurance, down payment assistance grants, consideration of nontraditional credit history, and homebuyer education. The loans were complex and labor-intensive. CONA originated or purchased 256 Dream and CHB loans totaling $47.5 million, 568 FHA loans totaling $117 million, 102 VA loans totaling $21 million, and 316 SBA loans totaling $221 million. Flexible and Innovative Investment Programs 1 Charter Number: 13688 CONA created and used several innovative approaches in grant funding to respond to community needs. The following highlights some examples of the bank’s programs: CONA’s Social Purpose Program is a mechanism that enhances the features of affordable housing developments. Under this program, the bank increased its investment in select nonprofit-owned developments by providing grant funding to support social service programs for residents. During the evaluation period, CONA committed to invest $1.57 million to support such programs in eight affordable housing developments. CONA’s Blueprints to Buildings (B2B) was created to provide grants and pre-development funding to support new affordable housing. It is intended to address the primary obstacles to building more affordable housing such as lengthy and often unfunded preparatory steps required to jumpstart affordable housing developments, and a lack of capital to move projects from conception to fruition. B2B provides multi-year grants to support project management expenses and low-cost, and flexible predevelopment loans to pay for project expenses. In addition, participants are eligible to apply for an unsecured line of credit from the bank at a below-market rate to help move the project from conception to closing. During the evaluation period, the bank committed to provide $1.45 million in B2B grants in connection with 19 developments in nine AAs and funded $1.75 million for both current and prior period commitments. CONA partnered with a number of nonprofit organizations to develop and expand Construction Contractors College (CCC). CCC is a free, seven-month small business training and development program that equips qualified business owners in the construction trades business with the knowledge, resources, and guidance they need to successfully bid and win public and private construction contracts. In addition to workshops, each small business owner receives one-on-one coaching and mentoring from CONA associates and professionals from partner organizations. Started in 2014, this program was created in direct response to the City of Houston’s need for a larger pool of certified minority- and women-owned contractors to bid on city projects. The program has since expanded to the Baton Rouge MSA AA and New York CSA AA. The bank provided grants totaling $481,300 to support the program during the evaluation period. In 2018,
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