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BOK Financial

Governance: Customers

Corporate ethics and governance reflect the company’s focus on accountability and drive our three-part vision of valuing our employees, customers, and communities we serve.

Small Business and Community Development Loans

SASB: FN-CB-240a.1

Loans designed to promote small business and small farms

Year Number of Loans Amount
2018 1,460 $415,569,000
2019 1,894 $582,848,000
2020* 9,191 $1,572,208,000

Loans designed to promote community development

Year Number of Loans Amount
2018 87 $370,695,000
2019 72 $400,996,000
2020 150 $407,003,000

Community Reinvestment Act Program

BOK Financial earned an outstanding rating in its most recent Community Reinvestment Act (CRA) exam, making it one of only 29% of banks rated by the OCC in 2020 to do so. The company maintains a strong CRA program by:
  • Tracking lending opportunities in our communities and working with government, business and non-profit partners.
  • Reviewing lending distribution quarterly.
  • Annually (or as needed) reviewing assessment area boundaries.
  • Establishing and communicating goals for CRA performance.
  • Measuring the bank against our peers.
  • Considering CRA implications for opening and closing retail bank offices.
  • Investing in our communities.
  • Partnering and volunteering with non-profits and organizations that impact LMI individuals and communities.

BOK Financial actively monitors compliance with the Home Mortgage Disclosure Act (HMDA) and CRA requirements. Teams monitor activities; identify, track and report issues discovered in the lines of business; and incorporate findings into formal reporting back to the lines of business. Monitoring also aids in identifying opportunities to inform the scoping of testing performed by HMDA and CRA management.

The CRA Officer is responsible for coordinating, developing, implementing and administering the CRA compliance program and reports to the Chief Compliance Officer.

Fair and Responsible Banking

BOK Financial does not discriminate against any applicant or discourage anyone on the basis of race, color, religion, national origin, gender, marital status, age or any other prohibited basis. We are fully committed to the principle that all consumers will be treated consistently and fairly in all phases of our credit operations, including product design, marketing and advertising, loan application, underwriting, pricing, collection, servicing, and loss mitigation activities.

The Fair and Responsible Banking Department performs regular analysis on lending data to identify potential fair lending concerns and opportunities to expand access to credit in our communities, including among underserved populations and areas. The department is also engaged in preventing unfair, deceptive, or abusive acts or practices (UDAAP) by:

  • Reviewing products and services, as well as the marketing and advertising of those products and services, to ensure terms are fair, clear, accurate, and easily understood by customers and potential customers;
  • Investigating potential sales practice misconduct to ensure that agents of BOK Financial are treating customers and potential customers fairly, transparently, and in accordance with the company’s ethics and values in all stages of the sales and service process; and
  • Analyzing and investigating complaints which may act as an early warning system to identify potential systemic concerns or issues that may result in consumer harm.

The Fair and Responsible Banking Director is responsible for the administration of the fair banking program reports to the Chief Compliance Officer.

Our Commitment to ESG

For more than 100 years, we’ve focused on making sure that families and businesses have a trusted, secure source of financial expertise. We’ve been committed to making our communities a better place to live and work. And, we’ve been an employer that values diversity, promotes inclusion and fosters career growth for all of our team members.

Governance: Board Oversight
Governance: Business Ethics
Governance: Responsible Investing
Governance: Systemic Risk Management

Our ESG Commitment