OCC

The Office of the Comptroller of the Currency is a U.S. federal agency that regulates national banks and federal savings associations, with growing authority over their use of artificial intelligence and emerging technologies. The OCC has issued guidance on AI risk management, model governance, and third-party vendor oversight that directly impacts how financial institutions deploy and monitor AI systems in lending, fraud detection, and customer service. For enterprises in the banking sector, OCC compliance requirements establish baseline standards for AI transparency, auditability, and bias testing that influence broader industry practices.

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ResearchUS2026-09-01

SR 26-2 Implementation Guide Exposes Legacy Model Inventory Gaps

Lumenova AI has published a practitioner implementation guide for SR 26-2, the Federal Reserve and OCC's updated model risk management supervisory guidance. The guide identifies concrete steps including model inventory rationalization, revised materiality-based tiering, strengthened validation independence, and a separate governance lane for agentic and generative AI. Compliance teams at regulated financial institutions can use the operating model recommendations as a readiness benchmark ahead of examinations.

SR 26-2 model risk management agentic AI generative AI banking OCC Federal Reserve model inventory

ResearchUS2026-09-01

SR 26-2 Forces Banks to Rethink Model Governance From Inventory to Board Oversight

The OCC's revised model risk management guidance, SR 26-2, resets supervisory expectations for U.S. banks by shifting to a materiality-based approach that covers both traditional statistical models and AI systems. CRA's practitioner analysis identifies four practical redesign areas: inventory scope, model tiering, validation, and governance alignment. Banks that operate AI governance and model risk management as separate programs face immediate pressure to harmonize them.

model risk management SR 26-2 banks OCC model validation inventory financial services AI governance