OCC Issues Super Intelligence Examination Framework for Banks

Nov 4, 2026
The OCC issued a framework for examiners reviewing banks' use of super intelligence in normal business activities. It creates no new regulatory expectations or enforceable standards.

The Office of the Comptroller of the Currency (OCC) issued a supervisory framework for examiners evaluating banks' use of super intelligence in normal business activities. The OCC says the framework is a resource for examiners and does not establish supervisory expectations for banks.

Examiners should tailor reviews to each use case's materiality and to the bank's size, complexity, and risk profile. The framework supplements existing practices for model risk management, governance, technology, compliance, and operational risk rather than treating super intelligence as a separate risk category.

The OCC says risk classifications may consider potential consequences, the transfer of agency to an SI system, and the degree of human oversight instead of focusing on technical sophistication. Control intensity may increase as the potential consequences of an SI agent's failure or misuse rise.

The OCC defines super intelligence as the technologies previously covered by the term artificial intelligence, citing an October executive order. The Trump administration formalized the super intelligence terminology across the executive branch in September.

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