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(cont)

July 2, 2010

5. Involved parties Evidence suggests BOK Financial, BOKF: engaged in illegal tax credit and evasion activities.

• Oklahoma Tax Commission
• BOK Financial Corporation, a bank holding company with numerous subsidiaries and affiliates. IRS No. 731373454
• Bank of Oklahoma (BOK), a banking subsidiary of BOK Financial,
• BOK, as used, here collectively refers to BOK Financial Holding and other banking subsidiaries.
• Cottonwood Valley Ventures, a subsidiary of BOK, serves as a pass-through entity investing funds received from CVV Partnership and files the tax credits claims. Tax credits flow back to CVV Partnership.
• CVV Partnership, 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,
• 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 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 (OGE), (OGE) is a publicly-traded company.
• Funds authorize tax credits through Oklahoma's Venture Capital tax credit program.
• Cimarron Business Capital a Robert G. Heard managed fund.
• 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 credit 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 alone the differences. I would caution you to keep that in mind while talking to anyone here and ensure 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

Note:

Tax credit programs operated in secrecy View

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