SEC Division of Corporation Finance and Division of Investment Management, Staff Guidance for Conducting Shareholder Meetings in Light of COVID-19 Concerns (Mar. 13, 2020; updated Apr. 7, 2020) (same instrument as Ex. AGY-FED-FINANCIAL-053)

SEC Division of Corporation Finance and Division of Investment Management, Staff Guidance for Conducting Shareholder Meetings in Light of COVID-19 Concerns (Mar. 13, 2020; updated Apr. 7, 2020) (same instrument as Ex. AGY-FED-FINANCIAL-053)

2020: OCC interim final rule, Director, Shareholder, and Member Meetings, 85 Fed. Reg. 31943 (May 28, 2020), effective on publication, to 'permit telephonic and electronic' participation and 'enable national banks and Federal savings associations to conduct necessary meetings remotely during the COVID-19 emergency as well as during any other future emergency when in-person meetings may not be feasible' (Exs. SEC-13-GM-026, -027); OCC Bulletin 2020-51 (May 12, 2020) (Ex. AGY-FED-FINANCIAL-019); SEC staff guidance of Mar. 13, 2020, updated Apr. 7, 2020, on changing 'the Date, Time, or Location of a Shareholder Meeting' and holding 'virtual' or 'hybrid' meetings 'in light of health, transportation, and other logistical issues raised by the spread of coronavirus disease 2019 (COVID-19)' (Ex. SEC-13-GM-029); State emergency orders suspending in-person meeting requirements (e.g., New York EO 202.8, Mar. 20, 2020, Ex. SEC-13-046). 2021: The OCC rule 'permanently amends OCC rules about telephonic or electronic participation' (Ex. SEC-13-GM-027); the SEC guidance remained in effect through 2021 (updated Jan. 19, 2022). Usual dates: Annual, chiefly April-June. Scale: 4,951 FDIC-insured institutions at June 30, 2021. Venue orders 2020: NY-005, CA-002, IL-005, TX-008, FL-010, DC-006, PA-005, MI-011, MA-032. Venue orders 2021: DC-016, IL-079, CA-017, MET-NYC-017, MET-SFO-011.