BPI submitted a comment letter on July 13th in response to a recently released Office of the Comptroller of the Currency (OCC) interim final rule (IFR) authorizing remote national bank board and shareholder meetings. BPI’s comments, which focused on board of directors meetings, commended the agency for permitting national banks to provide for telephonic or electronic participation at board of directors meetings, noting that remote communications tools provide national banks with more flexibility in planning and holding director meetings; could permit greater director participation at these meetings for those participants not able to attend in person; and may reduce the costs, logistical constraints, and other burdens — as well as, in the current environment, health risks — associated with conducting in-person meetings. In response to a question posed for public comment, BPI, however, cautioned the agency against the issuance of any new OCC risk management standards to govern this telephonic or virtual participation. While BPI and its members recognize the critical importance of the continued integrity of board communications, national banks have extensive experience with risk-reduction tools that predate the current COVID-19 crisis.
BPI Comments on OCC IFR Codifying National Bank Authorization to Hold Board and Shareholder Meetings by Phone or Internet-Based Conferencing
