CAPITAL ONE FINANCIAL CORP

Capital and Stress Testing Regulation

Stress Capital Buffer Requirements

In September 2026, the Federal Reserve finalized a rule amending the calculation of the stress capital buffer requirement applicable to large banking organizations, including the Company (the “SCB Averaging Rule”). Under the final rule, the Federal Reserve will calculate the stress capital buffer requirement by averaging results over the two most recent stress test cycles. The SCB Averaging Rule also shifts the annual effective date of the stress capital buffer requirement from October 1 to January 1 and adjusts the forward-looking period used to calculate the dividend add-on component of the stress capital buffer requirement to be consistent with this change. The averaging mechanism will first apply to the 2028 stress testing cycle, with the resulting stress capital buffer requirement becoming effective on January 1, 2029.

As a result of this shift in the effective date, and absent further action from the Federal Reserve, the Company’s current stress capital buffer requirement of 4.5% will remain in effect until a new requirement becomes effective on January 1, 2028. Accordingly, the Company’s minimum capital requirements plus the standardized approach capital conservation buffer for CET1 capital, Tier 1 capital and total capital ratios under the stress capital buffer framework will remain at 9.0%, 10.5% and 12.5%, respectively, through January 1, 2028.

Capital Planning and Stress Testing

In September 2026, the Federal Reserve finalized revisions to its supervisory stress testing framework (the “Stress Testing Transparency Rule”). Under the Stress Testing Transparency Rule, the Federal Reserve will annually disclose its supervisory stress test models and provide a formal public comment period on material changes to these models and the design of annual supervisory stress test scenarios. The Stress Testing Transparency Rule also shifts certain timelines on the stress testing calendar and adopts revisions to stress testing reporting requirements.

Concurrently with the finalization of the SCB Averaging Rule and the Stress Testing Transparency Rule, the Federal Reserve also re-proposed certain revisions to the supervisory models to be used to project non-interest income in the 2027 supervisory stress test.

We provide information on our Supervision and Regulation in our 2025 Form 10-K under “Part I—Item 1. Business—Supervision and Regulation” and in our Q1 2026 Form 10-Q under “Part I—Item 2. MD&A—Supervision and Regulation.”