Capital One Financial Corporation (COF) Earnings Call Transcript & Summary

May 9, 2023

New York Stock Exchange US Financials Consumer Finance conference_presentation 42 min

Earnings Call Speaker Segments

Jason Goldberg

analyst
#1

In this morning's slot of companies, very pleased Capital One -- to have Capital One Financial with us. Capital One's been a very, very long time supporter of this event. So, we appreciate the participation. From the company we have Jeff Norris, who is the Senior Vice President of Global Finance. Jeff, thanks for being with us, again.

Jeff Norris

executive
#2

Thanks, Jason. It's good to be here.

Jason Goldberg

analyst
#3

Obviously, I think most of the audience know Capital One, one of the largest credit card issuers, one of the largest auto issuers, both a branch-based and online depository gatherer really across the country. I guess given that, I suspect you have some unique insights into the consumer. So maybe just start big picture or your kind of normal impressions of the U.S. consumer and just the outlook against the backdrop of very low but potentially rising unemployment. Also they tell me elevated inflation and just still higher than normal payment rates.

Jeff Norris

executive
#4

Sure. So I'm not sure how unique our insights are, but our view of the consumer at the moment is that they continue to be a source of strength in an otherwise highly uncertain economic backdrop. We see labor markets, probably the most important driver of consumer health is still being quite strong. They've softened a little bit, but are still quite strong. I think there's some excess savings that consumers garnered through the pandemic that there's still a source of strength, although high inflation is kind of offsetting that and driving real wages down. So there's some pressure. But I think on the whole, consumers are still very much a source of strength. The debt burdens are low by historical standards and so forth. The one thing that we've got our eye on, though, in addition to continuing inflation, what that's doing to real wages, is the period we've just been through in the pandemic, which had unusually low and unsustainably low charge-offs and delinquencies. And it's our experience that on the other side of really good times like that, there's some catching up that happens on the other side. Just as like through the great recession, there was some elevated levels of charge-offs that sort of pull forward through the great recession and that had the effect of a couple of years in the aftermath of that a very benign credit, because it accelerated some charge-offs. We have an intuition that we can't really quantify that the opposite will happen as we leave the pandemic kind of in the rearview mirror to the event of widespread industry forbearance and stimulus payments and so forth that bridge consumers through that period of time. That could very well have the impact of delaying some charge-offs. And we might have to see some catching up on the other side. So with a couple of headwinds, we still find the consumers to be a relative source of strength.

Jason Goldberg

analyst
#5

I guess maybe we could just stick with that kind of credit quality comment. If we look 30-plus delinquencies are kind of back to pre-pandemic levels, losses still below, which something you alluded to. And you talked about monthly charge-offs returning to that 2019 level around the middle of this year. Can you maybe just talk to how much is that tied to normalization versus kind of deterioration? And just after you get to that point in midyear, does it stop or just continue to go up? And just how should we think about that trajectory?

Jeff Norris

executive
#6

So as we said, delinquencies and particularly the early formation of delinquencies in the domestic card business for us in the U.S. is already back to pre-pandemic or sort of 2019 levels on a monthly basis. And charge-offs aren't there yet, but we expect them to catch up fairly quickly. And we've said probably by the middle of this year. Normalization is kind of a funny term, right? As we've seen delinquencies and charge-offs rise, but remain below pre-pandemic or 2019 levels, that sort of increasing trend we and everybody in the industry is called normalization. But once you reach those 2019 levels, if things continue to worsen, you can't really say that's normalizing anymore, right? So I think we're about to drop that word from our vocabulary. We're assuming some continued pressure on delinquencies and charge-offs, driven by the persistent effects of inflation that we just talked about and just looking at the roll forward of our delinquency trends. So I think they're going to go a little bit higher. We haven't been specific about when or how high. But I expect that the worsening trends will continue for a little bit. We've assumed that in our most recent allowance build. We see the unemployment rate probably moving from its current levels to something above 5%. What we're assuming is that, that trend happens kind of by the end of 2023, early 2024. And all the factors I just talked about that are some emerging headwinds for consumers, I think, are what's in our thinking when we see some continued rising in losses. Now on the other hand, when we look at sort of early vintage performance, we're seeing a couple of encouraging trends. The first one is that if we look at early vintage performance of the accounts and balances we're originating today, it looks very similar to the early vintage performance from back in 2017, 2018, let's say, before the pandemic. So those vintage curves are sort of right on top of each other. And if we look at sort of monthly vintages each successive month, the early performance is right on top of the prior months. So there are some signs that some positive indicators. But against that backdrop, I think our macro view and just rolling forward current delinquency trends, we're assuming we're in store for a little bit more increase to go.

Jason Goldberg

analyst
#7

And I guess that's on the card front. I guess on the auto front, we've seen losses normalize quicker than expected there or not so quick or just quicker not than expected in card. And I guess, more recently, it's actually behaved consistent with seasonal patterns. Perhaps used car prices have been fairly elevated to the first 3 quarters -- first 3 months of this year, will pull back in April. Just kind of maybe -- just kind of delve into what your expectations are there.

Jeff Norris

executive
#8

So again, we don't really make forward-looking statements or give specific guidance about where we see charge-offs and delinquencies going. It's true that auto, in our experience, tends to move up faster and move down faster as cycles change. And so the fact that they -- the credit metrics in the auto business reached pre-pandemic levels sooner than card is kind of consistent with our expectations. I think in addition to all the things that we've been talking about in terms of the consumer, there's the overlay of used vehicle prices, which remain elevated compared to long-term historical levels but have been softening somewhat. We expect them to continue to soften and we actually assume a faster pace of deterioration in our underwriting choices, try and provide some buffer and some resilience even in the face of declining auto prices. But we expect that to continue and to continue to put some pressure on those metrics. But I think at the end of the day, we'll have to see where the used vehicle prices go and how that affects recovery values. We'll have to see about new card inventories and how those trends play out to have a better sense of where they're going. But again, similar to card, we've crossed out of the normalization. And now we're into sort of just seeing how the cycle plays out. But I'd point out that our card and auto businesses, we always assume things are going to get way worse than the actual forecast would suggest to build some resilience into our underwriting. So I think we're pretty well positioned even if the credit metrics continue to deteriorate for a little while.

Jason Goldberg

analyst
#9

Right. So I guess maybe delve into that, right? So you see higher unemployment. You talked about potential for lower used card prices kind of forecasting charges going up. And we saw you add over the last, I think, 3 quarters like almost $3 billion the allowance for loan loss -- allowance for loan losses. So clearly, kind of looking ahead, I think the card allowance is like 7.7%, so a full number. So from here, I guess, how should we think about the need to kind of build reserves? Or how do you think about the need to build reserves from here? I think it was $1.1 billion in the most recent quarter.

Jeff Norris

executive
#10

Right. Predicting the reserve build is a tricky business. Let me just talk a little bit about the elements that kind of go into our allowance for credit losses, calculation each quarter. You start with balanced growth, and that can be a tricky thing because we had pretty significant balance growth in the fourth quarter. But there's a nuance that you have to sort of work through, and that is that a lot of the balance build in the fourth quarter is seasonal. And those credit card balances tend to pay down before they have a chance to charge off, so they don't get a lot of allowance coverage in our methodology. Contrast that with the first quarter where growth appears on the surface to be essentially zero, but there's underlying growth. If you take a look at the year-over-year growth trajectory, it was 21% year-over-year balance growth. Unlike the fourth quarter, most of those balances are going to stick with us. And so they get a high allowance coverage because, as you know, credit card charge-offs are front-loaded, even more front loaded in the allowance methodology under CECL. So that growth in the first quarter gets a higher coverage ratio put against it. Then you look at our current economic forecast, and we've already said we assume unemployment rate is going to be above 5% by the end of the year and with a pretty conservative overlay for inflation and a recoveries effect that is kind of unique to Capital One. I'll come back to that in a minute. Just dropping the lost content from the first quarter of 2023 out of the 12 -- first 12 months of the allowance window, and adding the first quarter of 2024 drives an increase in allowance. And then you have the whole sort of notion that our economic forecast in any given quarter could get worse or better. What we said in the first quarter is that it pretty much stayed the same, but that assumption for losses to be higher in the first quarter, a year from now impacted our reserve build. Now I'll get to the recoveries impact. This is kind of a unique Capital One thing. In that, we work our own recoveries of charged-off debt and tend to do better. Historically, we can average as much as 2x the sort of recovery rate, on charged off debt because we worked our own recoveries as opposed to selling them. And it extends the period of time over which we're collecting against those accounts, but we tend to get more in our efforts. That's a good thing in most seasons. But at the moment, after going through the pandemic and the sort of unusually low charge-offs we saw for the last couple of years, the inventory of charged-off debt is lower. There's less for us to recover against and that has a little bit of an outsized impact on our allowance. And when you put all that into the mix, you see us sort of increasing allowance. Now it's also been true through history that our credit trends tend to move a quarter or 2 earlier than the industry. And so that -- I think that's part of the explanation for why our allowance looked like a larger build than others. And then the final thing I'll say is, I'm not sure how others allowance methodologies work, but ours sometimes can appear to be somewhat unique. One of the things is, I think, a lot of folks draw a fairly tight correlation between the level of unemployment rate and the level of credit card charge-off rate. Our models are actually particularly sensitive to the change in unemployment rate. One intuitive way to think about that is it's kind of the formation of new unemployment that is the bigger driver of card charge-offs. When you think about if somebody loses their job, it will take them 6 months to roll through the delinquency buckets and charge-off at 180 days. So if we work back from our assumption of the unemployment rate going from 3.5% to those something higher than 5% in like 2 quarters, that's a pretty rapid rise in unemployment and since our models are very sensitive to that change, I think that drives some of our build versus some others in the industry.

Jason Goldberg

analyst
#11

Helpful. And then you mentioned pretty strong card growth influencing reserves. So maybe we can kind of shift gears to that, I think we'll get April data next week. But if we look through March, I think you've had now 12 straight years of -- 12 straight months of 19% plus growth. Sales volumes been double digits. Just maybe talk to in terms of kind of what you're seeing, what are the drivers, any kind of shifting in what people are spending money on? And just how you think about growing loans into a rising unemployment rate backdrop?

Jeff Norris

executive
#12

Right. So, that's been a frequent topic of conversation over the last several months. On the one hand, we've got increasing charge-offs and delinquencies and larger than competitors sort of allowance build. On the other hand, we keep saying we're really happy with the growth opportunity and leaning into growth. And that, it's a little bit of cognitive and dissonance how can both of those things feature at the same time. The short answer is, in our experience, the balances that we're laying on now are going to have cash flows and revenue annuities that last a really long time and on a through-the-cycle basis, even in the context of short-term forecast for rising charge-offs and delinquencies. When we look at those things through the cycle, they still create a lot of resilience and a lot of attractive returns over the long term. And in our NPV models come back with very attractive net present value. So let me sort of unpack that a little bit. First, we're seeing pretty strong growth from existing clients as they build balance. These are clients that we know well and have a pretty good handle on credit risk. And the new originations, we're having the most traction in our marketing spend, generating new account relationships. But where we think the customers are at the riskier end of the credit spectrum, we originate them with lower lines. So that mitigates some of the credit risk. We're also seeing spend levels kind of slow down and moderate a little bit, which we think is a good thing. It's evidence of rational consumer behavior against an uncertain backdrop for the economy. If you look at new originations, or about -- or I'm sorry, spend growth, it was about 10%, and that's down from sort of high teens, 20% that we saw sort of a year ago. And if you look at it on a per active account basis, it's actually relatively flat and in some segments, down a little bit. So the entirety of our spend growth on the portfolio is driven by spending on new originations. And spend per account is moderating, which we think is a sign of a healthy consumer and a rationale consumer. So when you put it all together, we're pretty comfortable with the growth. And there's an additional thing that's kind of everything I just talked about is kind of true in our history as well as at the present day. We're also a little bit more comfortable with growth at the moment because we've really transformed our technology. We're operating essentially 100% in the cloud. That enables us to have big data streaming in real time and that enables us to drive in our core credit risk underwriting models, machine learning at scale. And that allows us to -- Rich talks about how we're generally leaning into growth, but trimming around the edges where we find subsegments of business that are performing less well than the rest of the book. With machine learning at scale, we can be a lot more precise and surgical about identifying the pockets of underperformance. So just to draw a very broad sort of hypothetical example, pre-tech transformation, we would have to sort of trim around the edges and I'm just making up the numbers, sort of $25 million, $30 million, $50 million subsegments. With the models and the technology we're employing today, we can sort of -- within a $50 million subsegment that's underperforming, we can generally identify the $10 million of it, that is the primary cause and shut that off and keep going with the other $40 million sort of. So our agility, I think, and precision is in a different place. And when we talk about our growth opportunities being enhanced by technology, that's kind of what we mean.

Jason Goldberg

analyst
#13

Got it. I guess on contrasting to the card growth, auto growth, we've seen it actually slow each or last 12 straight months. March, I think, was the slowest pace we've seen in 12 years. I know you've talked about pulling back, I would suspect there's a demand component. Just maybe just talk about why the pullback and then what would cause you to pivot and then maybe to get a little more aggressive.

Jeff Norris

executive
#14

Sure. There is a demand component, and that has to do with sort of vehicle inventories and the sort of relative confidence level of auto buyers. I think the bigger driver of our pullback by a wide margin, is our own view that industry margins had compressed in a way over the last couple of quarters, in a way that margin coverage for unexpected increases in losses is a key part of how we view resilience. So we need to always feel comfortable that the margin is sufficient to absorb losses that might actually exceed what we model. And we found a couple of quarters ago that credit unions as a whole, and if you sort of look at credit unions as a whole, that's a pretty significant share of prime originations in auto. And then a couple of large competitors that are in through near prime and sub-prime auto as well. We're not, I think, passing along the rising rate-driven funding cost increases into the pricing, and we saw a sort of compression of industry margins, that had us sort of move to the sidelines and pull back pretty sharply on originations. We always thought that, that would be kind of a temporal impact because even if you have a very simple sort of funds transfer pricing methodology, over time, it will work its way into the pricing. And we're seeing that happen. I think over the last few months, we've seen some softening of the -- well, I think softening is not the right word. We've seen some relief of the margin pressures that we've seen across the industry. And that might create some opportunities for us to sort of come back into the originations market. However, well, we've been on the side lines. We've also observed some rising delinquencies and credit losses in the deeper end of sub-prime, which is actually below where we play in the auto business. But in response to seeing those trends below our current origination box, we've actually tightened it to try and keep some distance between where we do originate and where we're seeing the sort of credit pressures. So any re-entry into the originations growth trajectory would be, I think, tempered somewhat by the fact that we'd be re-entering with a tighter credit box. And we'll have to see it if the margin trends sustain in a way that makes us comfortable to come back and something to watch.

Jason Goldberg

analyst
#15

You mentioned marketing earlier. And while down in the first quarter, 20% in mid seasonality, and it was also down a little bit year-over-year, are still a big number like $900 million. So we've seen good account growth, good sales growth, and I suspect, obviously, that's driven by marketing spend. As you think about, again, rising unemployment and the like, do you kind of temper marketing. Can you maybe just talk about just more in detail in terms of what you've been spending the money on, why you need to spend the money on in the future? And kind of just your thoughts around that in general.

Jeff Norris

executive
#16

Sure. So yes, marketing was down in the first quarter by about 20% on a linked quarter basis, which we attributed as sort of fairly typical seasonality. It was kind of flattish year-over-year. It was down like 2%.

Jason Goldberg

analyst
#17

We hang on every dollar.

Jeff Norris

executive
#18

So do we. One of the things I'd point out is that the first quarter of 2022 was a fairly elevated first quarter, because we had sort of continuing marketing spend after the fourth quarter -- prior fourth quarter launch of the Venture X card. And so one of the things that we spend marketing on is early spend bonuses. So people who originated at the launch of Venture X in fourth quarter and the second half of 2021, their spend behaviors drove some early spend bonuses that were paid and ran through the marketing line item in the first quarter of 2022. And that's an indication that the year-over-year decline is off of a fairly high level. So that's an indication that we're still leading in, right, as opposed to thinking it dropped 20% in the quarter. That's a change in our view. It's really not. So what are we spending the marketing on? It's largely driven by domestic card. Auto is less driven by marketing and card is actually more driven by marketing. And we're continuing to see, as I said, new account growth and adding customer relationships that look to us like they're going to create through the cycle value in the way that they generally have in the past. And so where we're playing is we still have a focus at the very top end of the market with rewards, products and customers that are heavy spenders. And we're seeing continued traction and growth there and some share gains, although we're -- our share is very small compared to the share leader in American Express, but we're seeing some good growth there. We're also continuing to get good traction with credit card revolvers from the upper end of subprime up and through prime. The one place where we're not focused on is what we call high balance revolvers or credit card revolvers who tend to carry larger balances and just have higher debt levels. We're still sort of trying not to be in that market. But those lower balance revolvers and the heavy spenders at the top of the market are the places we've been playing and been getting traction for years. And so there's nothing really new. We're still focused where we've always been focused and just enjoying pretty strong new account growth and the spend and balance and revenue growth that drives that. That focus on the top end of the market comes with more marketing expense. Because in addition to sort of the direct stimulus and response marketing, you have those early spend bonuses and we actually run through marketing, the cost we incurred to sort of create compelling top of the market experiences like our travel portal and Capital One lounges in airports and so forth. So we're spending on things besides sort of direct marketing. There's a brand component. We have a really high-performing brand in the U.S., which we are investing to support. And then finally, we haven't talked about deposits yet, but our deposit growth, which has been really strong, is not driven by a large national branch network. In 80% of the country, we don't have branches, but we have a very robust national direct-to-consumer deposit gathering franchise that's driven on the shoulders of our digital capabilities where we have kind of a full-service deposit offering. But it's marketing driven. Some of our brand spend and a fair amount of marketing goes to growing our deposits as well, which is a great franchise. It doesn't have anywhere near the complexity or fixed cost of a national branch infrastructure, but is -- relies more on marketing to drive growth. So for all those reasons, we're -- our posture is still mostly leaning into marketing. And the thing that we changed that, Jason, is our assessment of the opportunities or the risks changes, and we look at that on a fairly real-time basis.

Jason Goldberg

analyst
#19

Got it. I guess you touched on deposits, which is obviously one of the topics is your -- you guys have been an outperformer there in terms of growth and obviously, a very differentiated model, as you alluded to, just given the digital franchise you've put together. Maybe just talk to in terms of what you're seeing there in terms of competitive landscape, in terms of deposit pricing. Are peers maybe getting or other players getting more aggressive just given the collaborator and fair liquidity that we've seen from some of the regional banks and kind of just what are your expectations for, just how that ties into your outlook for net interest margin in general?

Jeff Norris

executive
#20

Sure. So I'll just pull up and talk a little bit about our kind of philosophy and strategy on the deposit side. Way back when we were entirely capital markets funded monoline and we transformed ourselves into a deposit funded sort of balanced bank, as you know, over a period of several years in the early part of the 2000s. Our quest was always to really drive retail deposit growth. In our view, that was always the sort of Holy Grail of deposit funding. We were less focused on building commercial deposits that sort of came along with some of the bank acquisitions. So I'll talk about commercial just for a second. It's a bit of a digression, but commercial deposit balances actually shrank about 6% from the linked quarter. And that's mostly on purpose. We were sort of proactively reducing some of our larger commercial deposits. We also saw some business as usual spending by our deposit clients on the commercial side. And the very thinnest of slice is almost a de minimis impact in the aftermath of SVB and so forth. We saw a couple of large accounts moved their deposits to one of the money centers, and that was offset by some positive came to us from smaller banks. So essentially, all of that sort of shrinkage on the commercial deposit side was more business as usual and not related to SVB aftermath. In contrast, on the retail side, we saw really strong growth. And that is essentially driven by the continuing traction we're getting in our digital national banking strategy. So we have limited physical presence across 80% of the U.S. geography in the form of these Capital One cafes to really sort of showrooms for -- physical showrooms for what you can do digitally. They don't have deposits -- they don't take deposits or disburse cash. There are no tellers, there's no vault. It's really more of a carrier of the brand in places where we don't have physical distribution. We've built a national banking platform where you can do sort of 95% of what you do in a bank branch, you can do digitally with us. We've driven a brand in a really simple and compelling digital customer experience. And the lion's share of our deposit growth is through that sort of national franchise that's kind of a digital bank and the shoulders of our technology transformation. That's mostly a liquid savings product. And we saw a continuing traction there that it's been many, many quarters in a row that we've seen good growth in those deposits. In this quarter, sort of by coincidence because it happened earlier in the quarter, we also had a couple of opportunistic deposit growth offerings that were more sort of onetime, limited time offers on CDs that got some good pickup. And that enabled us to sort of go lighter on capital markets funding, go very light. As a matter of fact, I think we did zero sort of brokered CDs in the capital markets. And then it allowed us to sort of have differential pricing on the sort of existing portfolio of deposits. And so the combination of continuing traction in that digital franchise and some opportunistic plays we made early in the quarter, drove the retail deposit growth and also drove a 2 percentage point increase in our proportion of insured deposits. So about 78% of our total deposits are insured. So we've -- given the heritage I talked about, being born as a capital markets funded monoline, has always given us the sort of belt and suspenders approach to liquidity management. And that put us in a really strong position for the events that happened in the industry and the aftermath of SVB. It wasn't by accident, but was not in response to the recent turmoil. It's just kind of the philosophy we've managed liquidity with all along. And then you asked about NIM. We're carrying sort of excess cash at the moment, which feels like the right call. So we're not going to sort of aggressively manage that down, but I expect that the sort of excess cash levels will diminish a little bit going forward, which could provide some NIM upside. And on the asset side, most of our growth these days is in part, which is another positive for NIM. On the other hand, we're in the sort of rising rate environment that puts pressure on the funding cost side of things. And as our credit metrics continue to rise, if they do, we'll do more revenue suppression. If we think that fees are uncollectible, we suppress that revenue. So there's a couple of headwinds and a couple of tailwinds. And in any given quarter, it's a little bit of a race to see whether the headwinds, the tailwinds went out, and we'll see that will drive the trajectory of NIM.

Jason Goldberg

analyst
#21

I guess when I think back to the financial crisis, since then you've dramatically improved your funding. But coming out of that, you acquired North Fork, Hibernia, Chevy Chase and maybe some others. Kind of this grow around, we see kind of other regional banks struggling, valuations under pressure. Would additional bank acquisitions something you'd kind of reconsider given where valuations will come in? And just, maybe just kind of your overall thoughts maybe on the current landscape for regional banks.

Jeff Norris

executive
#22

So you left out one of the most impactful acquisitions in the aftermath, which was ING Direct, which is the core of our -- of that digital national deposit franchise that I just talked about. But in the current moment, it would surprise me a lot if we were interested in acquiring regional banks. We've been pretty clear for a long time that, that's not really on our radar screen. We don't think the future is adding more branches. We don't think the future is adding bank franchises that come with a bunch of assets that we're probably less interested in. I think our acquisition focus such as it is, is kind of really much more on smaller sort of technology-oriented companies that can enhance our tech journey, maybe asset portfolios and businesses that we know well. But I really don't think we're very interested in acquiring more banks even in the current environment.

Jason Goldberg

analyst
#23

Had to ask. I guess you are a Category 3 bank, and there's certainly been a lot of talk about potentially changing the regulatory backdrop with respect to capital. Just maybe talk to your kind of how you're thinking about potential regulatory changes tied to recent events and the overall thoughts around capital management in general?

Jeff Norris

executive
#24

Sure. The -- on the regulatory front, I think we're kind of expecting the ability to opt out of it, including AOCI and the CET 1, regulatory capital ratio is -- we're, it's likely to go away. We're thinking that Category 3 and maybe Category 4 banks probably will be subject to the total loss absorption or TLAC debt requirements. We're actually in a pretty good spot for both of those potential regulatory changes. If we netted out AOCI as of the end of the first quarter, our 12.5% CET 1 ratio would have been something like 10.5%, and that's against our long-term sort of self-imposed long-term target of about 11%. And in a quarter where we had $1.1 billion allowance build, we still accreted 30 basis points of capital. So being 50 basis points off our long-term target is within spitting distance and it feels like we're in a pretty good position. And then on the TLAC front, just kind of as a matter of coincidence, we converted a couple of years ago to issuing our fixed income debt essentially out of the holding company with terms and conditions that happen to meet TLAC requirements. So I don't think we'd be in a place where we needed to do anything outsized or unusual to be ready for that. So from a AOCI standpoint and the TLAC standpoint, we're in pretty good shape. We're kind of waiting to see what happens to FDIC premiums, but we'll sort of adapt and move on as we see how that comes out. And then turning to how we think about capital, we've said for a couple of quarters now that the uncertainty bands around sort of where the world is going, are just wider and holding capital above our long-term 11% target, felt like the prudent thing to do to be in a position to thrive across a number of potential outcomes. And that certainly hasn't changed. As a matter of fact, it probably feels more comfortable given the recent events of the banking industry. So I would expect that stands to continue for a while.

Jason Goldberg

analyst
#25

Right. So I guess, with the share buyback has slowed a bit, so kind of expectations that's going to be good for...

Jeff Norris

executive
#26

Well, I don't want to -- again, I'm not at liberty to sort of make a prediction or a forward-looking statement, but I think our -- I think running a little bit above our 11% target is probably where we'll live for a little while.

Jason Goldberg

analyst
#27

Makes sense. And then maybe just in February, the CFPB put out a proposal that basically forces banks to reduce credit card late fees. Maybe just discuss the importance of late fees. I know they do sort of a purpose. And just kind of what you think the outcome here is and just how Capital One historically adapted to changes in the environment like that?

Jeff Norris

executive
#28

So a philosophical point to start, right? We have a mission in Capital One to sort of change banking for good. And when we think about our products and how we deal with our customers, the beacon we have is, what if this were a product or a decision we were making for a product that was going to -- that my mother was going to have or my son? What would we want that to be? And it sounds a little bit counterintuitive, but we would want the credit card product to have a meaningful fee for going late on a payment because it's a really strong behavioral incentive not to go late on a payment. And while it might feel good to sort of have a lower fee if that happened, the actual act of going late damages your credit profile, limits your access to credit, raises the cost of that credit. It's a really bad thing for a consumer. So having a really strong incentive not to do that is actually a good thing. But that's a pretty difficult argument to win in the court of public opinion. So we're thinking. We're preparing for the eventuality that late fees will be reduced. I'm not sure if this proposal will go through as is, we'll have to wait and see how that plays out. But I think getting the sort of the nuts and bolts of it, we would -- we had about $2 billion of late fee revenue in the most recent calendar year. And so that would be at risk. There are probably ways that the industry would adapt to that, potentially looking at sort of other upfront pricing mechanisms to -- in the aftermath of the CARD Act, industry revenue margins actually eventually found a place where their long-term equilibrium was at or a little bit above before the CARD Act. But it would -- that's not -- it's not a situation where you shift -- switch something off and switch something else on. The different sort of revenue streams kind of feather in and out over time. And so I think we'd see some pressure on revenues. And I think we see some pressure on serving some of the populations that we serve today without that -- the credit management lever of having a meaningful late fee. We would probably have to pull back from some of the segments that we serve today, which would unfortunately limit access to credit and probably raise the cost of it on average for a larger number of customers. All that said, this is a change that we expect will come to fruition in some way, shape or form, and we'll adapt to it and move on.

Jason Goldberg

analyst
#29

Got it. I guess -- and also maybe just against that and just some uncertainties. You talked about an operating efficiency ratio to be flat, to maybe modestly down in '23 versus 2022. And then previously, you talked about maybe a 42% figure longer term. Is that still kind of a doable number? And just how do you think about managing expenses and maybe some of the CFPB pressures come to fruition. Are there kind of expense offsets to think about?

Jeff Norris

executive
#30

Sure. So I see we're kind of running out of time, so I'll try and make this a fairly brief answer. But I think we've been focused on driving operating efficiency improvements for a long time now. And over the last several years, we have reduced the operating efficiency ratio by a little more than 400 basis points, even while we were investing pretty heavily both in marketing and in our technology transformation. We were very confident at the end of the day that the investments in the technology transformation are really the engine of future long-term efficiency improvements, both because they drive revenue growth and because they allow us to sort of identify analog costs that we can take out and there are a lot of digital productivity gains. So while the expectation and the guidance for the current year is relatively modest, flat to modestly down, I do think that it is our intent that through continuing sort of technology advancements, we will continue to be able to drive that metric lower. I'm not fixated on a specific number. But I think the long-term destination is for improving operating efficiency for a while over the long term. It's an important part of how the economics of investing in Capital One makes sense. So it's something that we really intend to continue to drive.

Jason Goldberg

analyst
#31

Perfect. Let's leave it there. Please join me in thanking Jeff for his time today.

Read the full transcript via the API

You're viewing the first half of this call. Get the complete Capital One Financial Corporation transcript — plus 251,000+ transcripts from 12,000+ companies, speaker segments, AI summaries and full-text search — through the EarningsCalls.dev API.

Get the API View API docs →

This call discussed

For developers and AI pipelines

Programmatic access to Capital One Financial Corporation earnings transcripts and 251,000+ others is available through the EarningsCalls.dev REST API. Plans from $24.99/month — full transcripts, speaker segments, full-text search, and the recently-added /api/v1/transcripts/recent polling endpoint for ETL pipelines.