OCC Issues Examiner Framework For Banks’ Use Of Artificial Intelligence

On November 4, the OCC issued a framework to help examiners evaluate banks’ use AI or what it refers to as “super intelligence”, including agentic AI, in ordinary business activities. The framework supplements the OCC’s announcement, which describes the agency’s technology-neutral approach to bank supervision.

The framework is an examiner resource, not a set of new supervisory expectations or enforceable standards. The OCC says banks are not expected to use it to assess their own AI use or risk management. Examiners may use it to tailor reviews to the materiality and potential consequences of particular use cases. Specifically, the framework:

• Applies existing risk practices to AI.Examiners may consider AI-specific issues alongside banks’ existing model risk management, governance, technology, compliance, and operational-risk practices. The OCC says AI should not be treated as a separate risk category, and banks should not be required to establish a separate AI I risk appetite.