United States securities and exchange commission logo
December 21, 2021
Steven E. Nell
Director, Executive Vice President and Chief Financial Officer
BOK Financial Corp
Bank of Oklahoma Tower
Boston Avenue at Second Street
Tulsa, OK 74172
Re: BOK Financial Corp.
Form 10-K for the
Fiscal Year Ended December 31, 2020
Filed February 24,
2021
Form 10-Q for the
Quarterly Period Ended September 30, 2021
Filed November 3,
2021
File No. 001-37811
Dear Mr. Nell:
We have limited our review of your filings to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2020
Cover Page
1. We note that with the
filing of your Form 8-A on June 24, 2016 your Commission File
Number changed to
001-37811. Please represent to us that in all future periodic and
current reports filed
under the Exchange Act you will provide the correct file number.
Steven E. Nell
FirstName LastNameSteven E. Nell
BOK Financial Corp
Comapany21,
December NameBOK
2021 Financial Corp
December
Page 2 21, 2021 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Lines of Business, page 42
2. In the individual segment tables and accompanying narrative
disclosures you present and
discuss "net loans charged off," which appear to be the amounts of the
provision for credit
losses for the periods presented in your segment footnote. For
example, the 2020 "net
loans charged off" for your Commercial Banking business of $69,475,000
from the table
on page 43 agrees with the provision for credit losses amount for this
segment presented
in Note 17 on page 140. Please represent to us that in future filings
you will revise your
lines of business tables and discussions to properly identify your
provision or benefit for
credit losses because charge-offs have a different connotation as you
disclose in Note 4
and elsewhere.
Form 10-Q for the Quarterly Period Ended September 30, 2021
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 1
3. Please revise your disclosure in your future quarterly periodic
filings to include a
discussion of material changes in your results of operations on a
year-to-date basis in
addition to the quarterly basis you currently disclose. Refer to
Regulation S-K, Item
303(c)(2)(i).
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Rolf Sundwall at 202-551-3105 or Mark Brunhofer at
202-551-3638
with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Finance