Super Intelligence: Supervisory Framework
What is new
The OCC has given US bank examiners a framework for generative and agentic AI. “Super intelligence” is the term a recent executive order requires for what was called AI: a renaming, not a claim about capability. AI risk sits within the existing risk categories, and banks “are not required to define a separate SI risk appetite”. What decides the level of control is the consequence of failure, how much authority passes to the agent, whether its actions can be reversed and how closely people oversee it, not how sophisticated the technology is: “a simple rules-based agent authorized to initiate transactions” can present more risk than “a sophisticated model limited to internal drafting assistance”. A fully autonomous payment agent facing customers sits in the top tier. The section on operational resilience warns that an agent “could remain available while taking inappropriate or harmful actions”. It lists circuit breakers, rate limits and kill switches, staff trained to keep the process running without the agent, and a separate workstream to identify affected customers and put things right, as examples examiners can look for. The OCC says the framework is a resource for examiners and “does not establish supervisory expectations for banks”; it sets no requirement in the UK.
Why a board should care
It turns risk appetite into a description of behaviour: what the agent may do, when it must ask, and who can stop it. The resilience test is a hard one: can we spot and contain an agent that is still running but doing the wrong thing, keep the service going, and put customers right? It also reaches the boardroom. The framework describes reporting to the board on material uses, changes, exceptions and incidents, and in PwC’s survey of US company directors in September, 82% rated the information linking AI to risk and performance as fair, poor or not provided.
Verdict: read section 2.1 (Defined Purpose and Permitted Use), section 2.10 (Operational Resilience) and section 3 (Illustrative Controls Framework and SI/Agent Risk Tiering).