The Office of the Comptroller of the Currency has issued supervisory guidance on how its examiners should review the use of super intelligence by the banks it supervises. OCC Bulletin 2026-54, titled "Super Intelligence: Supervisory Framework", was issued on 4 November 2026 alongside news release NR 2026-97. It is issued guidance rather than a proposal open for comment, and the OCC states that it intends to update the document over time.
The bulletin is addressed to the chief executive officers of all national banks, federal savings associations, and federal branches and agencies, to department and division heads, to all examining personnel, and to other interested parties. Footnote 1 defines banks as national banks, federal savings associations, and federal branches and agencies of foreign banking organizations. The bulletin directs examiners to tailor review to the materiality of the super intelligence use case, and states that examiners should not treat super intelligence as a separate and distinct risk category and that banks are not required to define a separate super intelligence risk appetite. It ties risk classification to potential consequences, transfer of agency, and the degree of human oversight rather than to technical sophistication, and states that control intensity could increase with the potential consequences of a super intelligence agent's failure or misuse. The document states that it does not establish supervisory expectations for banks and is intended as a resource to assist examiners.
National banks, federal savings associations, and federal branches and agencies of foreign banking organizations will meet these questions in examinations. Banks running agentic systems in payments, credit decisioning or financial crime monitoring face review keyed to what follows from an agent's failure or misuse and to how much agency has been transferred away from a person, not to how advanced the model is. Community banks are within reach of the document, because the OCC states that examiners may use it when supervising community banks' super intelligence use. Technology vendors supplying such systems to national banks will see consequence-based questions passed through to them in diligence and in contract negotiation.
The bulletin states no effective date and rescinds no earlier issuance. Its own text records that nothing in the guide is intended to establish new regulatory expectations, so a bank measuring itself against the document is reading examiner instructions rather than a rule carrying its own penalties. The existing risk categories remain the operative supervisory structure, since the bulletin places super intelligence inside them rather than beside them.
Licentium advises banks, payment firms and technology vendors on the supervisory treatment of automated and agentic systems. Work we undertake includes mapping deployed use cases against the materiality and consequence criteria the bulletin applies, documenting human oversight and escalation controls, allocating responsibility for agent failure in vendor contracts, and assembling materials for examination requests.
Source: OCC Bulletin 2026-54, Super Intelligence: Supervisory Framework, 4 November 2026