February 22, 2010

in addition to other requirements there is no evidence these claims met, for investments to qualify for tax credits the investments must result in obtaining an ownership in the business, Use pop ups for details. An investment in one entitie to inturn be invested in another business is not allowed. We are to believe BOK obtained the necessary ownerhsip in these entities, this are for profit businesses that will repay taxes?

An examination of four federal reports failed to find where BOK reported holding an ownership interest in any of these businesses as required.

Why were these tax credits then sold to BOK officers and director at 20% of face value, allowing personal gain from what if legit would have been shareholder property. Shareholder property BOK never disclosed to shareholders. Although ,this is an issue for the SEC and other federal agencies to address; this is significant for Oklahoma as evidence of misreporting.

This is the third in a series of articles exposing evidence that recently came to light on Oklahoma's Venture Capital tax credit program operated in secrecy for more than 20 years. More

First, this piece will show virtually every investments BOK claimed qualified for and received tax credits failed to meet the most fundamental requirement necessary to qualify for tax credits; as demostrated by 1) information BOK reported to four federal agencies; SEC, FDIC, Federal Reserve Board and Comptroller of Currency; and 2) many investments did not industry requirements.

What looks, suspiciously like, ordinary business loans, are being passed off as investments. This is further verified by BOK failing to report this same claimed investments as investments as required by federal mandate reporting requirements.

This has allowed the largest bank in Oklahoma to receive an unearned public subsidies amounting to 20% on business loans. The tax credits were then sold to officers and directors at 20% of face value. BOK was receiving an unearned public subsidy equal to 20% of its business loans. This tax credits where then passed on to officers and board members in the form of 80% discounted tax credits.

To add insult to injury the tax commission turned their backs allowing BOK to continue using the program to take tax credits after the program ended. In 2010, more than one year after the program ended, the tax commission accepted with question BOK filing $800 million amendment to a 2008 tax credit claim, that would be used to continue taking tax credits for years to come.

Tax credit program: "Venture Capital" allowing tax credits worth 20% tax credits, for investments that meet certain eligibility requirements, including among others:

• Investments not eligible for tax credits include: real estate, retail sales, lending or investing funds, farming, ranching, oil and gas exploration. More Pop up
• The investments, must result in gaining an an ownership interest in the business invested. The same as any investment, buying stocks on the stock exchange.

Some investments BOK received tax credits for claiming met eligibility requirements.

2006 - 2009 more than 300 investments in more than 150 entities, including:

• non-profits and others that claiming is a business and or obtaining ownership interest, is beyond reason.
  Tribal governments, Roman Catholic Diocese of Tulsa, Oklahoma State Fair, University of Tulsa, YMCAs, Foundations, various other non-profits and private individuals. Buying state officials does not qualify as an eligible investment.
• Ineligible industries, including real estates, investment firms.

An examination of federal reports BOK is required to file with the SEC, FDIC, Federal Reserve or Comptroller of Currency, found no evidence BOK properly disclosed ownership interest in what it claimed to gain. If these were investments as claimed BOK is required disclose to its stockholders the risk associated with these investments. Publically traded companies failing to disclose such extensive interest on SEC reports can bring sudden action by the SEC and exposure to shareholder legal actions.

Publicilly traded company is required to fully disclose all information, including loan and investments alter the risk factor

BOK would violate disclosure by either: failing to disclose investments; or representing loans as investment.

Was information misrepresented to four federal agencies including the SEC and 100,000s of shareholders; exposing BOK to an eternity of shareholder lawsuits; or was information misrepresented to Oklahoma's under the table, off the books secret tax credit program.

Note: BOK or Bank of Oklahoma, Cottonwood Valley Ventures and CVV Partnership are subsidiaries of BOK Financial Corporation

Manager of state tax credit program got 99% of tax credits going to one fund!

Oklahoma Tax Commission allows BOK subsidiary $800 million tax credit claim for a previously closed program!

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