April 17, 2014

A Corporate Response to CREW’s Disclosure Report

By CREW Staff

Capital One logoOn April 16, 2014, Steven DeLuca, the senior director of state and local government relations at Capital One, contacted us to discuss CREW’s “The Myth of Corporate Disclosure Exposed” report.

In the report, CREW identified $450 to the Republican Governors Association (RGA) that Capital One had underdisclosed in its 2012 disclosure report and $25,000 to the Democratic Attorneys General Association (DAGA) that Capital One had omitted from its first half of 2013 disclosure report.

Mr. DeLuca told CREW that the $450 to the RGA was a registration fee for the organization’s annual meeting and that the RGA had not been clear about whether the fee would be considered a contribution by the organization. Mr. DeLuca said Capital One would update their 2012 disclosure report to reflect the additional $450.

Mr. DeLuca said the $25,000 that the DAGA reported receiving in February 2013 was not disclosed in the company’s first half of 2013 report because it had been included in the company’s 2012 report. According to Mr. DeLuca, Capital One invoices for future years’ dues to organizations and discloses contributions in the year that they are approved by the company. Between 2011 and 2013, Capital One disclosed contributing $50,000 to the DAGA, but IRS records filed by the DAGA show $75,000 in contributions from Capital One in that time period. Mr. DeLuca said the extra $25,000 was a payment approved by Capital One in 2010, but the contribution is not included in Capital One’s 2009-2010 disclosure report because the company did not begin disclosing contributions to 527 organizations in its political disclosure reports until 2011.

Though Mr. DeLuca’s explanation for the discrepancies makes sense and suggests Capital One made a good faith effort to disclose its political contributions, the accounting approach used by Capital One is difficult for any public observer to discern and was only clarified through direct conversation. In many ways, this supports CREW’s argument in its rulemaking petition with the Securities and Exchange Commission for “regulations that would provide a clearly delineated, unambiguous, and uniform set of disclosure requirements for all public companies.”

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