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Suspicious wrongs found in BOK Financial Corp (BOKF) SEC Filings.

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1 Cover letter
2 Overview
3 Fraudulent activities
4 How this occurred
5 Critical evidence tax commission emails
6 Evidence - examination and results
7 Ongoing tax credit investigation and achievements
8 Summary


June 7, 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 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 suggests, 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;
  • the 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.


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