BOK Financial Corp (BOKF), Parties involved in suspicious financial activities.
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Index
Section Topics
A Cover letter
B Unearned gains, BOK and insiders.
B.1 BOK Financial Corp - Unreported Income and Tax Years
B.2 BOK Financial Corp Insiders
B.3 Robert G Heard - Cimarron Business Capital Company
1 How the fraud works
1.1 BOKs list of investments
1.2 BOK claimed venture capital investments for ineligible for businesses
1.3 Additional evidence
2 Source of evidence 2006  2009
2.1 Oklahoma Tax Commission auditors questioning claim ignored
2.2 Fraudulent financial transactions
2.3 Failure to report income to avoid paying federal taxes
3 Source of evidence (partial) 20012005, 2010. Potentially $369 million more
3.1 Partial evidence for 2001 thru 2005
3.2 Most complete evidence January 2010
4 Tax credit programs operated in secrecy, to prevent discovery
4.1 First, a quasi-state agency
4.2 Second, OCIB was assigned sole authority
4.3 Third, Heard the president outsources OCIB to self
4.4 Heard authorizes himself $3.4 million and BOK $91 million in tax credits
5 Involved parties
5.1 Caution over confusion
6 References

Evidence suggests BOK Financial, BOKF: engaged in illegal tax credit and avoidance activities. (cont)

5. Involved parties

  • BOK Financial Corporation, a bank holding company, with numerous subsidiaries and affiliates. IRS No. 731373454
  • Bank of Oklahoma, a banking subsidiary of BOK Financial,
    • Cottonwood Valley Ventures, a subsidiary of Bank of Oklahoma
    • CVV Partnership, a subsidiary of Bank of Oklahoma
  • BOK as used, here collectively refers to BOK Financial Holding, banking subsidiary BOK
  • Oklahoma Tax Commission
  • Oklahoma Capital Investment Board (OCIB). An Oklahoma trust, Charged with providing oversight for Oklahoma's Venture Capital tax credit program.
  • Institutional Equity Associates, LLC ("IEA" also known as "Edge"). A a private firm contracted to provide management and oversight of OCIB and Oklahoma's Venture Capital tax credit program
  • Robert G. Heard, owner president of IEA
    • owner manager of Cimarron Business Capital
    • invests 99%
  • Origen, Inc an affiliate of Oklahoma Gas and Electric, a publicly traded company.
  • Funds authorizes tax credits through Oklahoma's Venture Capital tax credit program
  • Cimarron Business Capital, a Robert G. Heard managed fund
  • Origen, Inc an affiliate of Oklahoma Gas and Electric,
  • Cottonwood Valley Ventures, a subsidiary of Bank of Oklahoma
  • CVV Partnership, a subsidiary of Bank of Oklahoma
  • CVV Partnership provided 100% of investments funds for Cottonwood Valley Ventures,
  • Cottonwood Valley Ventures, acts as a pass-through entity investing fund received from CVV Partnership, and files tax credits claims. Tax credits flow back to CVV Partnership.
  • Cimarron Business Capital, acts as a pass-through entity investing funds received from Robert G. Heard (99%) and Origen, Inc (1%) Cimarron Business Capital filed tax credits claims. Tax credits flow back to Robert G. Heard (99%) and Origen, Inc (1%)

5.1 Caution over confusion

While this letter addresses suspected tax credit fraud involving the "Venture Capital(G)" tax credit program; other frauds involve the "Capital Formation Incentive Act(H)" tax credit programs; commonly known as Small Business and Rural Venture.

These programs are very similar with small, but significant differences resulting in confusion among even our own state officials and lawmakers, who most admittedly have never read these laws. It is difficult to find anyone in Oklahoma other than those directly involved that are even aware there are different programs, let along the differences. I would caution you to keep that in mind while talking to anyone here, and insure you are both talking apples or oranges.

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.

References

(G) The fact that fraud is occurring under different but similar programs has attributed to considerable confusion. This particular case involves the following, commonly referred to as "Venture Capital" tax credits: Oklahoma Statute 68 2357.7 - Credit Against Tax for Investments in Qualified Venture Capital Companies - Pass-Through Entities;

(H) Other frauds involve the Capital Formation Incentive Act tax credit programs. Commonly known as Small Business and Rural Venture, each having to two subcategories and can be found at: www.oscn.net

Notes: View


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