OCC Super Intelligence Framework for Bank Examiners

The US Office of the Comptroller of the Currency (OCC), which supervises national banks, has issued a framework to help its examiners review how banks use what it now calls super intelligence (SI). The OCC super intelligence framework was announced in Bulletin 2026-54 on 4 November.

The OCC is clear that this is guidance for its own staff, not new rules for banks. The bulletin says the framework “does not establish supervisory expectations for banks” and adds: “It is intended as a resource to assist examiners in their supervisory activities.”

In brief

The OCC has published a sixteen-part framework to help examiners review banks’ use of super intelligence, its term for AI.
It says the framework sets no new rules or enforceable standards for banks.
Banks are not required to define a separate SI risk appetite, and examiners should scale their work to how material each use is.

What the framework says

The OCC uses “super intelligence” for the technologies it previously called “Artificial Intelligence”, as defined in US law at 15 USC 9401(3). The bulletin’s footnote points to Executive Order 14434, published in the Federal Register on 2 October 2026, as the basis for the change in wording.

According to the framework document, it is built around sixteen components. Nothing in it is intended to “establish new regulatory expectations or set forth enforceable standards or prescriptive requirements”, the bulletin says.

Several points in the text stand out:

Examiners should tailor their review to how material each SI use case is to the bank.
Community banks are covered on a proportionate basis.
Examiners “should not treat SI as a separate and distinct risk category, and banks are not required to define a separate SI risk appetite”.
The intensity of a bank’s controls could rise with the possible consequences if an SI agent fails or is misused.
Risk can be classed by those consequences, by how much decision-making is handed to the system, and by the level of human oversight, rather than by how technically advanced the system is.

The framework itself says it was “prepared with the assistance of SI” and was “reviewed, edited, and approved by a human”. The bulletin was signed by James M. Gallagher, Senior Deputy Comptroller and Chief National Bank Examiner. The OCC says it intends to update the guide over time.

Why the framing matters for banks

The most practical line for banks is the one about risk categories. By telling examiners not to treat SI as a separate risk, the OCC is placing it inside the risk management that banks already run, such as model risk, operational risk and third-party risk. A bank does not need to build a separate SI rulebook to satisfy its examiner.

The focus on consequences rather than technical sophistication is also notable. A simple tool that can move money or deny a customer an account could draw closer scrutiny than an advanced model that only drafts internal notes. The mention of “agents” and the “transfer of agency” shows the OCC is thinking about systems that act, not just systems that advise.

Even without legal force, examiner guidance tends to shape what banks do, because it tells them what questions to expect. Banks may treat the framework as a checklist in practice. Some questions remain open. The bulletin gives no timetable for revising the guide, and how examiners will weigh “human oversight” in practice will only become clear through examinations. Banks that already use SI tools for lending, fraud checks or customer service will want to map each one against the framework’s consequence-based approach before their next examination, rather than waiting for the OCC’s first update. The OCC has already been active in other areas of bank supervision, including its final report on debanking at the largest national banks.

Other financial regulators are also publishing practical tools rather than hard rules, such as the Hong Kong Monetary Authority’s post-quantum cryptography toolkit and Switzerland’s FINMA update to online identification rules. The OCC framework fits that pattern: it tells banks how they will be examined, while leaving the detailed choices to them.