On April 29, 2025 Acting Comptroller Rodney E. Hood told the National Fair Housing Alliance's Responsible AI Symposium that the OCC is committed to AI being used 'ethically and responsibly' in banking. He said the OCC expects 'robust risk management practices for AI applications, consistent with conventional model risk management practices,' covering bias, security vulnerabilities, and explainability, and that banks should apply existing OCC and interagency guidance as part of their AI governance. The speech is the clearest pre-2026 statement of the OCC's innovation-friendly but risk-managed AI stance.
| Document | Acting Comptroller Hood, 'AI in Financial Services' (Apr 2025) — Remarks by Acting Comptroller Rodney E. Hood at the National Fair Housing Alliance's Responsible AI Symposium: 'AI in Financial Services' |
| Issued by | Office of the Comptroller of the Currency |
| Type | Speech |
| Status | Final |
| Published | Apr 29, 2025 |
| Applies to | National banks and federal savings associations (statement of supervisory posture, not requirements) |
| Official source | occ.treas.gov ↗ |
| Use cases | AI governance (general) · Fair lending & discrimination · Model risk management · Credit scoring & underwriting |
What are the key points of Acting Comptroller Hood, 'AI in Financial Services' (Apr 2025)?
- Frames the United States as a global leader in AI innovation and the OCC as supporting responsible bank adoption.
- Notes OCC observations of banks using AI across risk management, fraud detection, and customer service, with benefits for efficiency and inclusion.
- States that AI is 'generally more complex' than conventional analytics and that some uses produce outputs that are 'more difficult to understand or explain.'
- Expects banks to assess and mitigate AI risks including bias, security vulnerabilities, and explainability, consistent with conventional model risk management.
- Points banks to existing OCC and interagency guidance for AI governance, and to the OCC's Office of Financial Technology, which evaluates fintech developments including AI.
- Highlights Project REACh as the OCC's financial-inclusion initiative alongside responsible AI.
What did Acting Comptroller Hood, 'AI in Financial Services' (Apr 2025) change for banks?
It signalled that the 2025 OCC would not write an AI rule but would hold banks to model-risk and fair-lending expectations while encouraging adoption — the posture then formalised by Bulletin 2026-13's carve-out of generative AI and the Spring 2026 risk report's review of supervisory expectations. Jonathan V. Gould succeeded Hood as Comptroller on July 15, 2025 and has continued the innovation-first framing.
What is the OCC's official stance on AI in banking?
Innovation-friendly but risk-managed: the OCC has said it supports responsible AI adoption, expects risk management consistent with model risk management practices (bias, security, explainability), and relies on existing guidance rather than an AI-specific rule.
Does the OCC require explainability for AI models?
There is no explicit explainability rule, but Acting Comptroller Hood's April 2025 remarks and the 2011/2026 model risk frameworks expect banks to understand how their models work and to manage the risk that AI outputs are difficult to explain, especially in credit decisions subject to ECOA adverse-action notice requirements.
| Date | Document | Status |
|---|---|---|
| May 7, 2026 | OCC Semiannual Risk Perspective, Spring 2026 — Semiannual Risk Perspective from the National Risk Committee, Spring 2026 | Final |
| Apr 17, 2026 | OCC Bulletin 2026-13 — Model Risk Management: Revised Guidance | In force |
| Jun 6, 2023 | OCC Bulletin 2023-17 — Third-Party Relationships: Interagency Guidance on Risk Management | In force |
| Apr 9, 2021 | OCC Bulletin 2021-19 — Bank Secrecy Act/Anti-Money Laundering: Interagency Statement on Model Risk Management for Bank Systems Supporting BSA/AML Compliance and Request for Information | Superseded |
| Mar 31, 2021 | 2021 Interagency AI RFI (OCC Bulletin 2021-17) — Request for Information and Comment on Financial Institutions' Use of Artificial Intelligence, Including Machine Learning | Final |
| Apr 4, 2011 | OCC Bulletin 2011-12 — Sound Practices for Model Risk Management: Supervisory Guidance on Model Risk Management | Superseded |
Follow every document these regulators publish
6 curated AI stories for banking executives · Every morning · Free
Subscribe to BankingNewsAI →