The Fed, OCC, and FDIC are now asking banks seven specific questions about AI agent controls in routine exams — while SR 26-2, issued in April, explicitly excludes agentic AI from its scope. The gap is already live.
The Digital Omnibus pushed the EU AI Act's Annex III high-risk deadline from August 2026 to December 2027 — exactly one conformity assessment cycle. Banks that treated the delay as breathing room are already behind.
The OCC's Spring 2026 Risk Perspective and Fed Vice Chair Bowman's governance speech mark a turning point: existing model risk guidance doesn't cover generative or agentic AI, and formal new rules are coming. Here's what that regulatory gap means for bank AI architecture today.
Federal regulators just rewrote SR 11-7 — and explicitly excluded generative AI and agentic AI from the new framework. Banks are now deploying their most powerful AI systems without a regulatory rulebook, and the internal governance vacuum is the real risk story.
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