OCC Bulletin 2026-54 of 4 November 2026: How the OCC's Examiner Framework Tiers National Banks' Super Intelligence and AI Agents, From Payment Agents in Tier 1 to Productivity Tools in Tier 4

What the OCC issued to its examiners on 4 November 2026

OCC Bulletin 2026-54, "Super Intelligence: Supervisory Framework," goes to the chief executives of all national banks, federal savings associations and federal branches and agencies of foreign banks, and to all OCC examining personnel. The framework, a 22-page PDF, groups 16 components under six pillars: purpose, risk, control, oversight, resilience and assurance. "Super Intelligence" is the federal term for AI under Executive Order 14434, defined by reference to the statutory definition of artificial intelligence in 15 U.S.C. 9401(3). The OCC says the document was prepared with the assistance of SI and reviewed, edited and approved by a human.

How the four illustrative tiers rank AI agents in banks

The framework scores each use case on decision consequence, reversibility, customer and financial impact, autonomy, data sensitivity, explainability and provenance. In the framework's illustration, a fully autonomous, customer-facing payment agent sits in Tier 1 "regardless of how well it performs in testing," and an internal productivity tool with no customer or financial data exposure, no direct action and fully human-controlled use sits in Tier 4. The core principle is consequence-based risk tiering: a simple rules-based agent that can initiate transactions may present more risk than a sophisticated model that only drafts internal text.

What the bulletin says about its own force

The bulletin states that it does not establish supervisory expectations for banks, that banks are not expected to use it to assess their own SI, and that banks need no separate SI risk appetite. Its text still describes, in detail, the agentic AI controls examiners may consider where they apply it, from kill switches to agent credentials.