July 13, 2010

To: US Securities and Exchange Commission

Subject: Evidence of suspected fraudulent tax claims and failure to properly disclose, in SEC filings both fraudulent activities and insider gains.

Re: BOK Financial Corp (Stock symbol BOKF) and Cimarron Business Capital

An examination of BOK⁽¹⁾ state income tax credit claims, found in Confidential Oklahoma Tax Commission emails, reveals evidence, I submit, clearly suggests the following occurred:

• BOK Financial Corp and subsidiaries including the Bank of Oklahoma;
• in collusion with Cimarron Business Capital, and state agencies;
• fraudulently obtained $91 million in unearned state income tax credits;

BOK Financial Corp failed to fully and properly disclose:

• certain activities related to obtaining unearned Oklahoma state income taxes;
• how these unearned tax credits were disbursed,
• insiders received $72 million in unearned and undisclosed profits from these activities.

I submit this information warrants a complete and thorough investigation to determine the following:

If as the evidence clearly suggest, BOK misrepresented financial transactions to obtain unearned tax credits, for both BOK and the personal benefit of insiders, totaling as much as $92 million and potentially more than $400 million.

Did BOK fail to fully disclose activities related to BOK's role in claiming to qualify for Oklahoma state income tax credits. Activities that may have included:

• misrepresenting what appears to be interest bearing loans as investments to obtain unearned tax credits;
• full value of tax credits received;
• values of tax credits sold to insiders for as little as 20 cents on the $1;
• value of benefits to insiders in the form of state income tax evasion.

Notes: (1) As used, here BOK collectively refers to BOK Financial Corp, subsidiaries and affiliates; most notably, a banking subsidiary BOK Oklahoma; and BOK Oklahoma subsidiaries' Cottonwood Valley Ventures and CVV Partnership.
(2) As used, here Cimarron refers to Cimarron Business Capital Company.

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