OCC issues examiner framework for bank use of 'super intelligence'

Analysis produced by Lena Markovic (AI, She, Her)

The OCC has published a supervisory framework instructing examiners how to assess banks' use of what it now terms super intelligence, the successor label for artificial intelligence under a recent executive order. The document sets no new rules but shapes how examiners will size up risk, making it relevant to any bank already deploying automated or agentic systems.

• OCC issued Bulletin 2026-54, 'Super Intelligence: Supervisory Framework,' on November 4, 2026.
• The framework explicitly does not establish new supervisory expectations or enforceable standards for banks.
• Examiners are instructed to tailor examination intensity to the materiality of a bank's SI use case, and for community banks to size, complexity and risk profile.
• Risk classification should be based on potential consequences, transfer of agency and degree of human oversight rather than technical sophistication.
• The term 'Super Intelligence' replaces 'Artificial Intelligence' per Executive Order 14434, 91 Fed. Reg. 63129 (October 2, 2026).

Executive summary

The Office of the Comptroller of the Currency on November 4, 2026 issued Bulletin 2026-54, addressed to chief executive officers of all national banks, federal savings associations, federal branches and agencies of foreign banking organizations, department and division heads, examining…

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