Overview
- The Conference of State Bank Supervisors issued the Artificial Intelligence Supervisory Framework on Wednesday, Sept. 16, 2026, and published a Core Examiner Guide, an Examiner Work Program, Nonbank AI Supplements, and an optional AI Use Case Risk Tiering Worksheet.
- CSBS framed the framework as a discretionary supervisory tool that does not create new legal requirements but gives examiners a common, structured way to probe AI uses and risks at state‑chartered banks and state‑licensed nonbank firms.
- The guidance treats generative and agentic AI as distinct challenges because those systems can create content, access data, and trigger actions in ways that traditional model‑risk rules do not cover.
- The framework places special emphasis on third‑party and vendor risk for nonbanks and asks institutions to inventory AI uses, name accountable owners, document vendor relationships, and show controls and evidence that those controls work.
- With federal regulators avoiding prescriptive AI rules, individual states will decide how to adopt the framework and this state‑level playbook could change industry practices and vendor scrutiny even without binding force.