OCC Issues Supervisory Framework For Banks’ Use Of “Super Intelligence”: A Risk-Based Approach To Generative And Agentic AI

The Office of the Comptroller of the Currency (OCC) has taken another important step in addressing the rapidly expanding use of artificial intelligence in the banking industry. On November 4, 2026, the OCC issued a new supervisory framework designed to assist its bank examiners in evaluating banks’ use of what the agency, following the terminology adopted by the Trump Administration, calls “Super Intelligence” (SI). The framework focuses particularly on generative AI and agentic AI and provides examiners with a detailed roadmap for evaluating the risks associated with these technologies and the controls banks have implemented to manage those risks.

Importantly, the OCC emphasizes that the framework is intended as a resource for examiners, not as a source of new regulatory requirements for banks. It does not establish a separate category of supervisory risk for SI, require banks to adopt a separate SI risk appetite, or impose new enforceable standards. Rather, it directs examiners