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ARTICLE · 22 SEPTEMBER 2026

State Regulators Sharpen Focus On AI Risk Management And Supervision

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The Conference of State Bank Supervisors (CSBS) and the NYDFS have each issued new guidance addressing how financial institutions should identify and manage risks associated...

United StatesTechnology
A.J. Dhaliwal
A.J. Dhaliwal
Mehul Madia
Mehul Madia
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The Conference of State Bank Supervisors (CSBS) and the NYDFS have each issued new guidance addressing how financial institutions should identify and manage risks associated with AI and other emerging technologies. On September 16, CSBS released a new AI supervisory framework designed to help state examiners assess AI use and related risks at state-chartered banks and state-licensed nonbank financial institutions. The framework follows September 10 guidance from NYDFS addressing cybersecurity risk assessments, including how regulated entities should account for AI and other emerging technologies.

The CSBS framework is a discretionary tool designed to help state examiners identify and understand AI use, assess associated risks, and determine when additional review may be appropriate. Each state regulator will decide whether and how to incorporate the framework into its supervisory program. NYDFS, meanwhile, clarified how entities subject to its Cybersecurity Regulation should conduct

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