Quarterlytics / Financial Services / Banks - Regional / BOK Financial

BOK Financial

bokf · NASDAQ Financial Services
Claim this profile
Ticker bokf
Exchange NASDAQ
Sector Financial Services
Industry Banks - Regional
Employees 1001-5000
← All annual reports
FY2018 Annual Report · BOK Financial
Sign in to download
Loading PDF…
ANNUAL REPORT

Dear Shareholders,
2018 was a record 
year for BOK Financial 
in many ways. 

KEY STATISTICS

DIVERSIFIED REVENUE

Assets: $38 billion

Loans: $22 billion

Deposits: $25 billion

Fiduciary Assets: $45 billion

Assets Under Management and/or 
Administration: $76 billion

At December 31, 2018

CREDIT RATINGS

BOK Financial Corporation
Long-term Issuer

BOKF, NA
Long-term Issuer

11% FIDUCIARY AND ASSET 

MANAGEMENT

7%

BROKERAGE
AND TRADING

61%

NET INTEREST
REVENUE

7%

DEPOSIT SERVICE 
CHARGES

6%

MORTGAGE 
BANKING

5% TRANSACTION CARD

3% OTHER REVENUE

S&P

Moody’s

Fitch Ratings

BBB+ (ON)

A3 (OS)

A (OS)

A- (ON)

A3 (OS)

A (OS)

2018 HIGHLIGHTS
FOR A RECORD REVENUE YEAR

28th consecutive year
of profitability 

33% year-over-year increase
in net income to $446 million

Largest acquisition in 
company history with the addition 
of CoBiz Financial 

Robust loan production bringing 
total loan portfolio to over $21 billion 
for the first time in company history

14th consecutive year of dividend 
increases for stockholders

Named ‘Best Places To Work’ 
by both Glassdoor and Forbes 

Record  earnings,  near  record  loan  production,  and  the  
largest  acquisition  in  company  history  were  the  defining 
characteristics of the year, and these landmarks could not 
have been reached without the hard work and dedication of 
every single one of our employees. They work tirelessly to 
ensure that BOK Financial stands apart in an increasingly 
competitive  environment  with  our  customers,  prospects, 
and communities. 

For the year, pre-tax earnings was a record $565.5 million; 
net income attributable to BOK Financial shareholders was 
$445.6 million, up 33.2 percent compared to 2017; and we 
reported  diluted  earnings  per  share  of  $6.63,  the  highest 
level in our company’s history. I think this is a testament to 
the philosophy upon which we’ve built our bank: managing 
for long-term value rather than short-term results. 

COBIZ: EXPANDING OUR
WESTERN PRESENCE

We  decided  to  invest  our  excess  capital  and  the  benefit 
from corporate tax reduction to make a long-term invest-
ment in our company with an almost $1 billion purchase of 
CoBiz Financial. This acquisition vaulted BOK Financial to a 
top-ten  deposit  share  bank  in  Colorado,  and  more  than 
doubled  our  market  share  in  Denver  and  Phoenix—both  
important growth markets for BOK Financial. 

We have taken a very detailed and thoughtful approach to 
integrating the two companies and expect 2019 results to 
positively reflect the acquisition and the efforts of so many 
across the company. By adding CoBiz, an organization that 
like us has proven the ability to grow organically over time, 
we feel that BOK Financial is now the premier commercial 
banking franchise in Colorado and Arizona. We are very ex-
cited about the future of the combined organization, and we 
are pleased to welcome our new teammates from CoBiz.

LOAN GROWTH:
A RECORD YEAR

Our  revenue  diversity  remains  a  large  component  of  our 
strategy,  and  this  showed  its  value  again  in  2018  as  we  
saw substantial loan growth across most businesses and 
markets  as  rising  interest  rates  impacted  our  fee-based 
businesses. More on the fee businesses later in my letter. 

Economic  and  employment  growth  helped  drive  us  to  
near record loan growth in 2018, ultimately resulting in an 
increase  in  loan  balances  of  more  than  nine  percent  for  
the year. 

With such broad growth across our loan portfolio, there is 
plenty to be optimistic about. Our energy lending business 
has grown substantially this year, and we would expect this 
to continue into 2019. One of our core philosophies is that 
we are not casual in our business segments, and we stay 
fully committed to our customers even when cycles impact 

certain business segments. That has never been more clear 
than in our approach to the energy sector, and our contin-
ued growth is a byproduct of that long-term commitment. 
Commercial  real  estate  has  also  been  an  area  of  growth, 
although  we  remain  cautious  given  the  length  of  the  
economic  recovery.  Our  commercial  and  industrial  busi-
ness  continues  to  drive  regionally-diverse  growth,  which 
portends  well  for  continued  stability.  Our  healthcare  
portfolio  continues  to  expand,  and  demographic  trends  
indicate that this business has plenty of potential for strong 
ongoing growth. 

We remain optimistic about core loan growth as we head 
into  2019  as  long  as  the  broader  economy  continues  to 
show  strength.  We  believe  our  geographic  footprint  and 
quality  of  our  banking  teams  will  allow  us  to  outperform  
the  national  economy,  especially  as  we  integrate  CoBiz 
portfolios into our lines of business. 

RISING INTEREST RATES: 
A DOUBLE-EDGED SWORD

Rising  interest  rates  helped  create  margin  expansion,  
greatly  benefiting  our  traditional  banking  units  in  2018.  
While increasing deposit betas will impact BOK Financial, 
we continue to track favorable to the industry, primarily due 
to our enviable mix of high commercial demand deposits. 
Even so, holding deposit costs at competitive levels while 
still growing balances will be a challenging objective for all 
of us in the banking industry. 

Rising  rates,  while  excellent  for  margin,  also  provided  a 
headwind for our mortgage and mortgage-backed security 
trading business. As a result, run rate expense save mea-
sures have been undertaken in these businesses to right-
size  for  the  current  environment.  Many  of  you  will  recall 
2012 when  these businesses carried  our earnings  growth 
as  loan  balances  and  spreads  declined.  Bottom  line,  
our  business  diversification  makes  us  a  more  stable  and 
predictable  company—for  shareholders,  employees,  and 
customers.

WEALTH MANAGEMENT

Our  wealth  management  capabilities  are  still  the  envy  of  
the  industry,  and  we  continue  to  innovate  to  address  the 
changing market landscape. 

The team undertook initiatives to expand and enhance their 
delivery channels to include virtual advisors and call center 
support  for  our  consumer  branch  delivery  channel.  This  
initiative, financed through a reallocation of current resourc-
es, will undoubtedly pay dividends in the future as clients 
expect  to  have  instant  access  to  advice  and  results  no  
matter  which  area  of  wealth  management  is  providing  
their services. We expect to remain competitive and con-
tinue  to  grow  by  taking  share  from  larger,  less  client  
focused national competitors. 

The team also successfully added two new mutual funds 
in  response  to  regulatory  changes.  By  being  able  to 
quickly  address  the  changes  in  the  regulatory  environ-
ment  to  serve  our  clients  better,  we  demonstrate  our  
agility in meeting constantly changing client needs.

While  the  expansion  of  trading  activities  in  the  MBS  
market proved difficult in 2018 due to the aforementioned 
interest rate environment, our MBS trading activities were 
down only 6 percent year over year. When compared to 
the overall mortgage origination activity in the U.S. being 
off by nearly 11 percent, we consider this a win and fully 
intend to stay committed to this business going forward.

EXPENSE MANAGEMENT

Another primary driver of our strong 2018 financial perfor-
mance was expense discipline. One of our core goals is to 
drive earnings leverage by holding expense growth to no 
more  than  half  of  revenue  growth,  with  the  goal  of  a  
60 percent efficiency ratio. We made great strides in this 
regard,  as  expenses  were  down  from  the  prior  year  
despite  the  significant  increase  in  revenue,  and  moved 
our  efficiency  ratio  from  66  percent  at  the  beginning  of 
2018 to 63 percent at the end of the year, even before full 
run rate efficiencies were realized from the CoBiz acquisi-
tion. We are clearly moving the needle and quicker than 
was previously anticipated with our three-year timeframe. 

RISK MANAGEMENT, 
COMPLIANCE, AND 
TECHNOLOGY

We had a banner year within our operations and technol-
ogy  group.  The  collaboration  with  our  business  lines  is 
producing faster and more competitive customer product 
and delivery enhancements. In fact, we saw a significant 
upgrade  to  our  deposit  system  go  off  without  a  hitch— 
a monumental accomplishment. 

We are excited to see what 2019 and beyond hold for our 
organization,  as  we  seek  ways  to  generate  accuracy  
and efficiency by introducing robotics and machine learn-
ing  within  our  operational  environment.  We  are  on  the 
cusp of technology being a competitive advantage for our 
company—a  significant  component  in  today’s  ever-
changing economy.

Our  risk  management  group,  in  collaboration  with  
operations  and  technology,  made  significant  strides  in 
addressing risks identified with the natural disasters that  
occurred in August of 2017. We feel that we stand even 
more  ready  to  address  risk  than  ever  before,  but  we  
continue  to  push  ourselves  to  improve.  Initiatives  like  
cyber awareness and security have been a strong empha-
sis and will continue as top priorities into next year.

COMMUNITY, DIVERSITY, 
AND INCLUSION

While  a  record  fiscal  year  is  something  to  be  proud  of,  
I think I am most proud of the organization’s success this 
year  in  our  communities.  BOK  Financial  has  always  
put our commitment to our communities, our customers, 
and  each  other  above  all.  The  philanthropic  priorities  
of  our  chairman,  George  Kaiser,  have  imprinted  them-
selves  onto  the  organization.  Our  employees  learn  early  
in  their  careers  that  community  involvement  is  who  we  
are and that the leaders in our company have embraced 
this commitment. 

And  each  year  is  better  than  the  last.  In  2018,  BOK  
Financial employees volunteered nearly 19,000 hours to 
local non-profit entities, and more than 350 of them serve 
in 650 leadership roles with nearly 500 non-profits and set 
the tone, direction, and strategy for these organizations. 
Employees  donated  $2.23  million  to  our  various  United 
Way campaigns in 2018. Their charitable spirit is matched 
by the company, which granted more than $5.3 million to 
philanthropic causes through the BOKF Foundation. 

In 2018, we celebrated the opening of Gathering Place in 
Tulsa, a spectacular new public park built as a communal 
site for the entire city. Gathering Place was a vision of the 
George  Kaiser  Family  Foundation,  which  raised  nearly 
$500 million to make it a reality. It’s a tremendous exam-
ple of the philanthropic nature of our Chairman and our 
company—and we should all be proud to play a continu-
ing role in its funding.

This philanthropic approach in our communities is echoed 
by our employees in our workplace culture. In fact, BOK 
Financial was recently named one of the best places to 
work by both Glassdoor and Forbes. This is a testament 
to the efforts we’ve put forth in talent attraction and reten-
tion, and these designations will only serve to make the 
organization even more competitive in recruiting new and 
mid-career professionals. 

We also challenged several top talent workgroups to help 
us develop a more intentional approach to creating great-
er  diversity  and  inclusion  across  the  company.  We  are 
working to form a council within the bank that I will chair— 
to advise my team and me on strategies we can employ 
to  make  sure  our  company  reflects  the  values  and  
perspective of our markets and customers. To that end, 
we were pleased to add two new and diverse members to 
our  Executive  Leadership  Team  this  year  in  Kelley  Weil 
(EVP-Chief  Human  Resource  Officer)  and  Derek  Martin 
(EVP-Consumer  Banking  Services),  both  of  whom  will 
broaden our perspective as we set ongoing strategy for 
the company. 

LOOKING FORWARD 

We are incredibly proud of our results in 2018 and are equally 
enthusiastic about what 2019 has in store. As we noted in our 
investor  communications  throughout  2018,  we  expect  to  see 
great  things  from  the  CoBiz  acquisition  and  look  forward  to 
completing the integration process soon. 

Although there are some market headwinds that many will point  
to as potential roadblocks for the financial industry, I have full  
faith  in  our  diversified  approach  to  driving  shareholder  value.  
And  it’s  that  approach  that  will  leave  us  well-positioned  for 
strong earnings growth in the coming years.

Best regards,

Steven G. Bradshaw
President and Chief Executive Officer

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

(Mark One) 

FORM 10-K

ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the quarterly period ended December 31, 2018 

OR

TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from _____________ to ______________                 

Commission File No. 0-19341

BOK FINANCIAL CORPORATION
(Exact name of registrant as specified in its charter)

Oklahoma

(State or other jurisdiction
of Incorporation or Organization)

Bank of Oklahoma Tower

Boston Avenue at Second Street

Tulsa, Oklahoma

(Address of Principal Executive Offices)

73-1373454

(IRS Employer
Identification No.)

74172

(Zip Code)

 (918) 588-6000
(Registrant’s telephone number, including area code)

Securities registered pursuant to Section 12 (b) of the Act:  None
Securities registered pursuant to Section 12 (g) of the Act:
Common stock, $0.00006 par value

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.  Yes  
Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15 (d) of the Act.  Yes  

  No  

  No  

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange 
Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been 
  No  
subject to such filing requirements for the past 90 days.       Yes  

Indicate by check mark whether the registrant has submitted electronically and posted on its corporate Website, if any, every Interactive Data 
File required to be submitted and posted pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter)during the preceding 12 months 
(or for such shorter period that the registrant was required to submit and post such files)Yes  

  No  

Indicate by check mark if disclosure of delinquent filers pursuant to Item 405 of Regulation S-K is not contained herein, and will not be 
contained, to the best of registrant’s knowledge, in definitive proxy or information statements incorporated by reference in Part III of this 
Form 10-K or any amendment to this Form 10-K.   

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer or a smaller reporting 
company.  See definitions of “larger accelerated filer,” “accelerated filer” and “smaller reporting company” in Rule 12b-2 of the Exchange 
Act.  (Check one):
Large accelerated filer  
If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying 
with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act.  
Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act).    Yes  

     Accelerated filer   Non-accelerated filer  

Smaller reporting company  

Emerging growth company  

  No  

The aggregate market value of the registrant's common stock ("Common Stock") held by non-affiliates is approximately $2.4 billion (based 
on the June 30, 2018 closing price of Common Stock of $94.01 per share). As of January 31, 2019, there were 72,251,266 shares of Common 
Stock outstanding.

Part III incorporates certain information by reference from the Registrant’s Proxy Statement for the 2019 Annual Meeting of Shareholders.

DOCUMENTS INCORPORATED BY REFERENCE

 
 
 
 
 
 
 
 
BOK Financial Corporation
Form 10-K
Year Ended December 31, 2018 

Index

Part I

Business

Risk Factors
Unresolved Staff Comments 
Properties

Legal Proceedings

Mine Safety Disclosures

Part II
Market for Registrant's Common Equity, Related Stockholder Matters and Issuer 
Purchases of Equity Securities
Selected Financial Data
Management's Discussion and Analysis of Financial Condition and Results of Operations 
Quantitative and Qualitative Disclosures about Market Risk
Financial Statements and Supplementary Data
Changes In and Disagreements with Accountants on Accounting and Financial Disclosure 
Controls and Procedures
Other Information

Part III
Directors, Executive Officers and Corporate Governance
Executive Compensation
Security Ownership of Certain Beneficial Owners and Management and Related 
Stockholder Matters
Certain Relationships and Related Transactions, and Director Independence 
Principal Accounting Fees and Services

Item 1

Item 1A

Item 1B

Item 2

Item 3

Item 4

Item 5

Item 6

Item 7

Item 7A

Item 8

Item 9

Item 9A

Item 9B

Item 10

Item 11

Item 12

Item 13

Item 14

Part IV

Item 15

Exhibits, Financial Statement Schedules

Signatures

Exhibit 10.4.11 Employment Agreement between BOK Financial and Scott B. Grauer dated December 18,

Exhibit 21

Exhibit 23

Exhibit 31.1
Exhibit 31.2

2013

Subsidiaries of the Registrant

Consent of Independent Registered Public Accounting Firm

Chief Executive Officer Section 302 Certification
Chief Financial Officer Section 302 Certification

Exhibit 32

Section 906 Certifications

1
9

14

14

14

14

15

18

18

70

77

164

164

164

164

164

165

165

165

165

168

ITEM 1.   BUSINESS

PART I

General

Developments relating to individual aspects of the business of BOK Financial Corporation ("BOK Financial" or "the 
Company") are described below. Additional discussion of the Company’s activities during the current year appears within Item 
7 "Management’s Discussion and Analysis of Financial Condition and Results of Operations."

Description of Business

BOK Financial is a financial holding company incorporated in the state of Oklahoma in 1990 whose activities are governed by 
the Bank Holding Company Act of 1956 ("BHCA"), as amended by the Financial Services Modernization Act or Gramm-
Leach-Bliley Act and the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). BOK 
Financial offers full service banking in Oklahoma, Texas, New Mexico, Northwest Arkansas, Colorado, Arizona, and Kansas/
Missouri. At December 31, 2018, the Company reported total consolidated assets of $38 billion.

BOKF, NA is a wholly owned subsidiary bank of BOK Financial. BOKF, NA operates TransFund, Cavanal Hill Investment 
Management, BOK Financial Asset Management, Inc. and seven banking divisions: Bank of Albuquerque, Bank of Arizona, 
Bank of Arkansas, Mobank, Bank of Oklahoma, Bank of Texas and Colorado State Bank and Trust. On October 1, 2018, BOK 
Financial acquired CoBiz Bank as a wholly owned subsidiary, greatly enhancing our market presence in the Colorado and 
Arizona markets. CoBiz Bank will be merged into BOKF, NA in first quarter of 2019. BOKF, NA and CoBiz Bank are 
collectively referred to as "the subsidiary banks" in the discussion following. Other wholly owned subsidiaries of BOK 
Financial include BOK Financial Securities, Inc., a broker/dealer that primarily engages in retail and institutional securities 
sales and municipal bond underwriting and The Milestone Group, Inc., an investment adviser to high net worth clients. Other 
non-bank subsidiary operations do not have a significant effect on the Company’s financial statements. 

Our overall strategic objective is to emphasize growth in long-term value by building on our leadership position in Oklahoma 
through expansion into other high-growth markets in contiguous states. We operate primarily in the metropolitan areas of Tulsa 
and Oklahoma City, Oklahoma; Dallas, Fort Worth and Houston, Texas; Albuquerque, New Mexico; Denver, Colorado; 
Phoenix, Arizona, and Kansas City, Kansas/Missouri. Our acquisition strategy targets fairly priced quality organizations with 
demonstrated solid growth that would supplement our principal lines of business. We provide additional growth opportunities 
by hiring talent to enhance competitiveness, adding locations and broadening product offerings. Our operating philosophy 
embraces local decision-making in each of our geographic markets while adhering to common Company standards.

Our primary focus is to provide a comprehensive range of nationally competitive financial products and services in a 
personalized and responsive manner. Products and services include loans and deposits, cash management services, fiduciary 
services, mortgage banking and brokerage and trading services to middle-market businesses, financial institutions and 
consumers. Commercial banking represents a significant part of our business. Our credit culture emphasizes building 
relationships by making high quality loans and providing a full range of financial products and services to our customers. We 
offer derivative products that enable mortgage banking customers to manage their production risks and our energy financing 
expertise enables us to offer commodity derivatives for customers to use in their risk management. Our diversified base of 
revenue sources is designed to generate returns in a range of economic situations. Historically, fees and commissions provide 
40% to 48% of our total revenue. Approximately 40% of our revenue came from fees and commissions in 2018.

BOK Financial’s corporate headquarters is located at Bank of Oklahoma Tower, Boston Avenue at Second Street, Tulsa, 
Oklahoma 74172.

The Company’s Annual Reports on Form 10-K, Quarterly Reports on Form 10-Q, Current Reports on Form 8-K and 
amendments to those reports are available on the Company’s website at www.bokf.com as soon as reasonably practicable after 
the Company electronically files such material with or furnishes it to the Securities and Exchange Commission.

1

Operating Segments

BOK Financial operates three principal lines of business: Commercial Banking, Consumer Banking and Wealth 
Management. Commercial Banking includes lending, treasury and cash management services and customer risk management 
products for small businesses, middle market and larger commercial customers. Commercial Banking also includes the 
TransFund electronic funds network. Consumer Banking includes retail lending and deposit services, lending and deposit 
services to small business customers served through the retail branch network and all mortgage banking activities. Wealth 
Management provides fiduciary services, private bank services and investment advisory services in all markets. Wealth 
Management also underwrites state and municipal securities and engages in brokerage and trading activities. Discussion of 
these principal lines of business appears within the Lines of Business section of "Management's Discussion and Analysis of 
Financial Condition and Results of Operations". 

Competition

BOK Financial and its operating segments face competition from other banks, thrifts, credit unions and other non-bank 
financial institutions, such as investment banking firms, investment advisory firms, brokerage firms, investment companies, 
financial technology firms, government agencies, mortgage brokers and insurance companies. The Company competes largely 
on the basis of customer services, interest rates on loans and deposits, lending limits and customer convenience. Some 
operating segments face competition from institutions that are not as closely regulated as banks, and therefore are not limited 
by the same capital requirements and other restrictions. All market share information presented below is based upon share of 
deposits in specified areas according to the Federal Deposit Insurance Corporation ("FDIC") as of June 30, 2018.

We are the largest financial institution in the state of Oklahoma with 13% of the state’s total deposits. We have 32% and 10% of 
the market share in the Tulsa and Oklahoma City areas, respectively. We compete with two banks that have operations 
nationwide and have greater access to funds at lower costs, higher lending limits, and greater access to technology resources. 
We also compete with regional and locally-owned banks in both the Tulsa and Oklahoma City areas, as well as in every other 
community in which we do business throughout the state.

We compete against numerous financial institutions in the state of Texas, including some of the largest in the United States, and 
have a market share of approximately 2% in the Dallas, Fort Worth area and less than 1% in the Houston area. We have an 11% 
market share in the Albuquerque area and compete with four large national banks, some regional banks and several locally-
owned smaller community banks. Our market share is approximately 4% in the Denver area. We serve Benton and Washington 
counties in Arkansas with a market share of approximately 2%. Our market share is approximately 2% in the Kansas City, 
Missouri/Kansas area. We operate as a community bank with locations in Phoenix, Mesa and Scottsdale with approximately 1% 
market share. The Company’s ability to expand into additional states remains subject to various federal and state laws.

Employees

As of December 31, 2018, BOK Financial and its subsidiaries employed 5,313 full-time equivalent employees. None of the 
Company’s employees are represented by collective bargaining agreements. Management considers its employee relations to be 
good.

Supervision and Regulation

BOK Financial and its subsidiaries are subject to extensive regulations under federal and state laws. Both the scope of the laws 
and regulations and the intensity of the supervision to which our business is subject have increased in recent years. Regulatory 
enforcement and fines have also increased across the banking and financial services sector. Many of these changes have 
occurred as a result of the Dodd-Frank Act and its implementing regulations, most of which are now in place. These regulations 
and others are designed to promote safety and soundness, protect consumers and ensure the stability of the banking system as a 
whole. The purpose of these regulations is not necessarily to protect shareholders and creditors. As detailed below, these 
regulations require the Company and its subsidiaries to maintain certain capital balances and require the Company to provide 
financial support to its subsidiaries. These regulations may restrict the Company’s ability to diversify, to acquire other 
institutions and to pay dividends on its capital stock. These regulations also include requirements on certain programs and 
services offered to our customers, including restrictions on fees charged for certain services. President Trump has issued an 
executive order that sets forth principles for reform of the federal financial regulatory framework; however, the recent change 
to a Democrat controlled House may limit the opportunity for further regulatory reform. The Company expects that its business 
will remain subject to extensive regulation and supervision. 

2

The following information summarizes certain existing laws and regulations that affect the Company’s operations. It does not 
summarize all provisions of these laws and regulations and does not include all laws and regulations that affect the Company 
presently or in the future.

General

As a financial holding company, BOK Financial is regulated under the BHCA and is subject to regular inspection, examination 
and supervision by the Board of Governors of the Federal Reserve System (the "Federal Reserve Board"). Under the BHCA, 
BOK Financial files quarterly reports and other information with the Federal Reserve Board.

BOKF, NA is organized as a national banking association under the National Banking Act, and is subject to regulation, 
supervision and examination by the Office of the Comptroller of the Currency (the "OCC"), the FDIC, the Federal Reserve 
Board, the Consumer Financial Protection Bureau ("CFPB") and other federal and state regulatory agencies. The OCC has 
primary supervisory responsibility for national banks and must approve certain corporate or structural changes, including 
changes in capitalization, payment of dividends, change of place of business, and establishment of a branch or operating 
subsidiary. The OCC performs examinations concerning safety and soundness, the quality of management and directors, 
information technology and compliance with applicable regulations. The National Banking Act authorizes the OCC to examine 
every national bank as often as necessary.

A financial holding company, and the companies under its control, are permitted to engage in activities considered "financial in 
nature" as defined by the BHCA, Gramm-Leach-Bliley Act and Federal Reserve Board interpretations. Activities that are 
"financial in nature" include securities underwriting and dealing, insurance underwriting, merchant banking, operating a 
mortgage company, performing certain data processing operations, servicing loans and other extensions of credit, providing 
investment and financial advice, owning and operating savings and loan associations, and leasing personal property on a full 
pay-out, non-operating basis. A financial holding company is required to notify the Federal Reserve Board within thirty days of 
engaging in new activities determined to be "financial in nature." BOK Financial is engaged in some of these activities and has 
notified the Federal Reserve Board.

In order for a financial holding company to commence any new activity permitted by the BHCA, each insured depository 
institution subsidiary of the financial holding company must be "well capitalized" and "well managed" and have received a 
rating of at least "satisfactory" in its most recent examination under the Community Reinvestment Act. A financial holding 
company and its depository institution subsidiaries are considered to be "well capitalized" if they meet the requirements 
discussed in the section captioned "Capital Adequacy and Prompt Corrective Action" which follows. A financial holding 
company and its depository institution subsidiaries are considered to be "well managed" if they receive a composite rating and 
management rating of at least "satisfactory" in their most recent examinations. If a financial holding company fails to meet 
these requirements, the Federal Reserve Board may impose limitations or conditions on the conduct of its activities and the 
company may not commence any new financial activities without prior approval.   

The BHCA requires the Federal Reserve Board’s prior approval for the direct or indirect acquisition of more than five percent 
of any class of voting stock of any non-affiliated bank. Under the Federal Bank Merger Act, the prior approval of the OCC is 
required for a national bank to merge with another bank or purchase the assets or assume the deposits of another bank. In 
reviewing applications seeking approval of merger and acquisition transactions, the bank regulatory authorities consider, 
among other things, the competitive effect and public benefits of the transactions, the capital position of the combined 
organization, the applicant’s performance record under the Community Reinvestment Act and fair housing laws and the 
effectiveness of the subject organizations in combating money laundering activities.

A financial holding company and its subsidiaries are prohibited under the BHCA from engaging in certain tie-in arrangements 
in connection with the provision of any credit, property or services. Thus, a subsidiary of a financial holding company may not 
extend credit, lease or sell property, furnish any services or fix or vary the consideration for these activities on the condition 
that (1) the customer obtain or provide additional credit, property or services from or to the financial holding company or any 
subsidiary thereof, or (2) the customer may not obtain some other credit, property or services from a competitor, except to the 
extent reasonable conditions are imposed to insure the soundness of credit extended.

The Company and other non-bank subsidiaries are also subject to other federal and state laws and regulations. For example, 
BOK Financial Securities, Inc. is regulated by the Securities and Exchange Commission ("SEC"), the Financial Industry 
Regulatory Authority ("FINRA"), the Federal Reserve Board, and state securities regulators. Such regulations generally include 
licensing of certain personnel, customer interactions, and trading operations. 

3

Volcker and Swap Rules

Title VI of the Dodd-Frank Act, commonly known as the Volcker Rule, prohibits the Company from (1) engaging in short-term 
proprietary trading for our own account, and (2) having certain ownership interests in or relationships with private equity or 
hedge funds. The fundamental prohibitions of the Volcker Rule apply to banking entities of any size, including the Company 
and its bank subsidiary. The Company has implemented a compliance program required by the Volcker Rule. Trading activity 
remains largely unaffected by the Volcker Rule as most of our trading activity is exempted or excluded from the proprietary 
trading prohibitions.

Title VII of the Dodd-Frank Act, commonly known as the Swap Rule, subjects nearly all derivative transactions to the 
regulations of the Commodity Futures Trading Commission ("CFTC") or SEC. This includes registration, recordkeeping, 
reporting, capital, margin and business conduct requirements on swap dealers and major swap participants. Under CFTC and 
SEC rules, entities transacting in less than $8 billion in notional value of swaps over any 12 month period are exempt from the 
definition of and registration as a "swap dealer." The Company currently estimates that the nature and volume of its swaps 
activity will not require it to register as a swap dealer.

Enhanced Prudential Standards

The Dodd-Frank Act directed the Federal Reserve Board to monitor emerging risks to financial institutions and enacted 
enhanced supervision and prudential standards applicable to bank holding companies with consolidated assets of $50 billion 
or more and non-bank covered companies designated as systematically important to the Financial Stability Oversight 
Council (often referred to as systemically important financial institutions). The Dodd-Frank Act mandated that certain 
regulatory requirements applicable to systemically important financial institutions be more stringent than those applicable to 
other financial institutions.  

In February 2014, the Federal Reserve Board adopted rules to implement certain of these enhanced prudential standards. 
Beginning in 2015, the rules required publicly traded bank holding companies with $10 billion or more in total consolidated 
assets to establish risk committees and required bank holding companies with $50 billion or more in total consolidated assets 
to comply with enhanced capital, liquidity and overall risk management standards. In May 2018, the Economic Growth, 
Regulatory Relief and Consumer Protection Act ("Regulatory Relief Act") raised the threshold for systemically important 
financial institutions from $50 billion to $250 billion while providing the Federal Reserve with authority to establish 
incremental prudential standards for banks between $100 billion and $250 billion. The regulations to implement this change 
have not been finalized.

Consumer Financial Protection

We  are  subject  to  a  number  of  federal  and  state  consumer  protection  laws  that  extensively  govern  our  relationship  with  our 
customers. These laws include the Equal Credit Opportunity Act, the Fair Credit Reporting Act, the Truth in Lending Act, the 
Truth in Savings Act, the Electronic Fund Transfer Act, the Expedited Funds Availability Act, the Home Mortgage Disclosure Act, 
the Fair Housing Act, the Real Estate Settlement Procedures Act, the Fair Debt Collection Practices Act, the Service Members 
Civil  Relief Act  and  these  laws’  respective  state-law  counterparts,  as  well  as  state  usury  laws  and  laws  regarding  unfair  and 
deceptive acts and practices. These and other federal laws, among other things, require disclosures of the cost of credit and terms 
of deposit accounts, provide substantive consumer rights, prohibit discrimination in credit transactions, regulate the use of credit 
report information, provide financial privacy protections, prohibit unfair, deceptive and abusive practices, restrict our ability to 
raise interest rates and subject us to substantial regulatory oversight. Violations of applicable consumer protection laws can result 
in significant potential liability from litigation brought by customers, including actual damages, restitution and attorneys’ fees. 
Federal bank regulators, state attorneys general and state and local consumer protection agencies may also seek to enforce consumer 
protection requirements and obtain these and other remedies, including regulatory sanctions, customer rescission rights, action by 
the state and local attorneys general in each jurisdiction in which we operate and civil money penalties. Failure to comply with 
consumer protection requirements may also damage our reputation and result in our failure to obtain any required bank regulatory 
approval for merger or acquisition transactions we may wish to pursue or our prohibition from engaging in such transactions even 
if approval is not required.

The CFPB has broad rulemaking authority for a wide range of consumer financial laws that apply to all banks, including, among 
other things, the authority to prohibit “unfair, deceptive or abusive” acts and practices. Abusive acts or practices are defined as 
those that materially interfere with a consumer’s ability to understand a term or condition of a consumer financial product or 
service or take unreasonable advantage of a consumer’s (i) lack of financial savvy, (ii) inability to protect himself in the selection 
or use of consumer financial products or services, or (iii) reasonable reliance on a covered entity to act in the consumer’s interests. 
4

The CFPB can issue cease-and-desist orders against banks and other entities that violate consumer financial laws. The CFPB may 
also institute a civil action against an entity in violation of federal consumer financial law in order to impose a civil penalty or 
injunction. 

Community Reinvestment Act

The Community Reinvestment Act of 1977 ("CRA") requires depository institutions to assist in meeting the credit needs of their 
market areas consistent with safe and sound banking practice. Under the CRA, each depository institution is required to help meet 
the  credit  needs  of  its  market  areas  by,  among  other  things,  providing  credit  to  low-  and  moderate-income  individuals  and 
communities. Depository institutions are periodically examined for compliance with the CRA and are assigned ratings. In order 
for a financial holding company to commence any new activity permitted by the BHCA, or to acquire any company engaged in 
any new activity permitted by the BHCA, each insured depository institution subsidiary of the financial holding company must 
have received a rating of at least “satisfactory” in its most recent examination under the CRA. Furthermore, banking regulators 
take into account CRA ratings when considering a request for an approval of a proposed transaction. BOKF, NA received a rating 
of "outstanding" in its most recent CRA examination, which is above "satisfactory."

Financial Privacy

The federal banking regulators adopted rules that limit the ability of banks and other financial institutions to disclose non-
public information about consumers to non-affiliated third parties. These limitations require disclosure of privacy policies to 
consumers and, in some circumstances, allow consumers to prevent disclosure of certain personal information to a non-
affiliated third party. These regulations affect how consumer information is transmitted through diversified financial companies 
and is conveyed to outside parties.

Capital Adequacy and Prompt Corrective Action

The Federal Reserve Board, the OCC and the FDIC have issued substantially similar risk-based and leverage capital guidelines 
applicable to United States banking organizations to ensure capital adequacy based upon the risk levels of assets and off-
balance sheet financial instruments. In addition, these regulatory agencies may from time to time require that a banking 
organization maintain capital above the minimum levels, whether because of its financial condition or actual or anticipated 
growth. Capital adequacy guidelines and prompt corrective action regulations involve quantitative measures of assets, 
liabilities, and certain off-balance sheet items calculated under regulatory accounting practices. Capital amounts and 
classifications are also subject to qualitative judgments by regulators regarding components, risk weighting and other factors.  

Federal Reserve Board risk-based guidelines define a four-tier capital framework based on three categories of regulatory 
capital. Common equity Tier 1 capital ("CET1") includes common shareholders' equity, less goodwill, most intangible assets 
and other adjustments. Tier 1 capital consists of CET1 capital plus certain additional capital instruments and related surplus. 
Supplementary capital ("Tier 2") consists of preferred stock not qualifying as Tier 1 capital, qualifying mandatory convertible 
debt securities, limited amounts of subordinated debt, other qualifying term debt and allowances for credit losses, subject to 
limitations. Assets and off-balance sheet exposures are assigned to categories of risk-weights, based primarily upon relative 
credit risk. Risk-based capital ratios are calculated by dividing CET1, Tier 1 and total capital by risk-weighted assets.

Additional capital rules were effective for banks and bank holding companies, including BOK Financial, on January 1, 2015 as 
part of a package of regulatory reforms developed by the Basel Committee on Banking Supervision ("BCBS") to strengthen the 
regulation, supervision and risk management of the banking sector, commonly referred to as the Basel III framework. 
Implementation of certain components of these rules continues to be deferred. 

The leverage ratio is determined by dividing Tier 1 capital by adjusted average total assets. A bank which falls below acceptable 
levels, including the capital conservation buffer, would be subject to regulatory restrictions on capital distributions (including 
but not limited to dividends and share repurchases) and executive bonus payments. 

The Federal Deposit Insurance Corporation Improvement Act of 1991 (the "FDICIA"), among other things, identifies five 
capital categories for insured depository institutions from well capitalized to critically under-capitalized and requires the 
respective federal regulatory agencies to implement systems for prompt corrective action for institutions failing to meet 
minimum capital requirements within such categories. FDICIA imposes progressively more restrictive covenants on operations, 
management and capital distributions, depending upon the category in which an institution is classified. The various regulatory 
agencies have adopted substantially similar regulations that define the five capital categories identified by FDICIA, using the 
total risk-based capital, Tier 1 risk-based capital and leverage capital ratios as the relevant capital measures. Such regulations 
establish various degrees of corrective action to be taken when an institution is considered under-capitalized.

5

Stress Testing 

The Regulatory Relief Act eliminated the requirement for periodic company run capital stress tests known as the Dodd-Frank 
Act Stress Test for banks with assets less than $250 billion. Although the mandate has been lifted, the Company still continues 
to perform capital stress testing on a regular basis. 

Executive and Incentive Compensation

Guidelines adopted by federal banking agencies prohibit excessive compensation as an unsafe and unsound practice and 
describe compensation as excessive when the amounts paid are unreasonable or disproportionate to the services performed by 
an executive officer, employee, director or principal shareholder. The Federal Reserve Board has issued comprehensive 
guidance on incentive compensation intended to ensure that the incentive compensation policies do not undermine safety and 
soundness by encouraging excessive risk taking. This guidance covers all employees that have the ability to materially affect 
the risk profile of an organization, either individually or as part of a group, based on key principles that (i) incentives do not 
encourage risk-taking beyond the organization's ability to identify and manage risk, (ii) compensation arrangements are 
compatible with effective internal controls and risk management, and (iii) compensation arrangements are supported by strong 
corporate governance, including active and effective board oversight. Deficiencies in compensation practices may affect 
supervisory ratings and enforcement actions may be taken if incentive compensation arrangements pose a risk to safety and 
soundness.  

Deposit Insurance

Substantially all of the deposits held by the subsidiary banks are insured up to applicable limits by the Deposit Insurance Fund 
("DIF") of the FDIC and are subject to deposit insurance assessments to maintain the DIF. In 2011, the FDIC released a final 
rule to implement provisions of the Dodd-Frank Act that affect deposit insurance assessments. Among other things, the Dodd-
Frank Act raised the minimum designated reserve ratio from 1.15% to 1.35% of estimated insured deposits, removed the upper 
limit of the designated reserve ratio, required that the designated reserve ratio reach 1.35% by September 30, 2020, and 
required that the FDIC offset the effect of increasing the minimum designated reserve ratio on depository institutions with total 
assets of less than $10 billion. The Dodd-Frank Act provided the FDIC flexibility in implementation of the increase in the 
designated reserve ratio, but it will ultimately result in increased deposit insurance costs to the Company. The Dodd-Frank Act 
also required that the FDIC redefine the assessment base to average consolidated assets minus average tangible equity. 

On June 30, 2016, the DIF rose above the 1.15%, resulting in a reduction of the initial assessment rate for all banks and 
implementing a 4.5% surcharge on insured depository institutions with total consolidated assets of $10 billion or more. The 
assessment base for the surcharge was the regular assessment base reduced by $10 billion. On September 30, 2018 the DIF rose 
above 1.35%. Accordingly, the surcharge for depository institutions with assets of greater than $10 million will cease. Base 
assessment rates will remain unchanged, but are scheduled to decrease when the reserve ratio exceeds 2%.

Dividends

A key source of liquidity for BOK Financial is dividends from BOKF, NA, which is limited by various banking regulations to 
net profits, as defined, for the year plus retained profits for the preceding two years. Dividends are further restricted by 
minimum capital requirements and the Company's internal capital policy. BOKF, NA's dividend limitations are discussed under 
the heading "Liquidity and Capital" within "Management's Discussion and Analysis of Financial Condition and Results of 
Operations."

Source of Strength Doctrine

According to Federal Reserve Board policy, a bank holding company is expected to act as a source of financial strength to each 
subsidiary bank and to commit resources to support each such subsidiary. This support may be required at times when a bank 
holding company may not be able to provide such support. 

6

 
Transactions with Affiliates

The Federal Reserve Board regulates transactions between the Company and its subsidiaries. Generally, the Federal Reserve 
Act and Regulation W, as amended by the Dodd-Frank Act, limit the Company’s banking subsidiary and its subsidiaries, to 
lending and other "covered transactions" with affiliates. The aggregate amount of covered transactions a banking subsidiary or 
its subsidiaries may enter into with an affiliate may not exceed 10% of the capital stock and surplus of the banking subsidiary. 
The aggregate amount of covered transactions with all affiliates may not exceed 20% of the capital stock and surplus of the 
banking subsidiary.

Covered transactions with affiliates are also subject to collateral requirements and must be conducted on arm’s length 
terms. Covered transactions include (a) a loan or extension of credit by the banking subsidiary, including derivative contracts, 
(b) a purchase of securities issued to a banking subsidiary, (c) a purchase of assets by the banking subsidiary unless otherwise 
exempted by the Federal Reserve, (d) acceptance of securities issued by an affiliate to the banking subsidiary as collateral for a 
loan, and (e) the issuance of a guarantee, acceptance or letter of credit by the banking subsidiary on behalf of an affiliate. 

Bank Secrecy Act and USA PATRIOT Act

The Bank Secrecy Act ("BSA") and The USA PATRIOT Act of 2001 ("PATRIOT Act") impose many requirements on financial 
institutions in the interest of national security and law enforcement. BSA requires banks to maintain records and file suspicious 
activity reports that are of use to law enforcement and regulators in combating money laundering and other financial crimes. 
The PATRIOT Act is intended to deny terrorists and criminals the ability to access the U.S. financial services system and places 
significantly greater requirements on financial institutions. Financial institutions, such as the Company and its subsidiaries, 
must have a designated BSA Officer, internal controls, independent testing and training programs commensurate with their size 
and risk profile. As part of its internal control program, a financial institution is expected to have effective customer due 
diligence and enhanced due diligence requirements for high-risk customers, as well as processes to prohibit transactions with 
entities subject to Office of Foreign Asset Control sanctions. Documentation and recordkeeping requirements, as well as system 
requirements, aimed at identifying and reporting suspicious activity reporting, must increase with the institution's size and 
complexity. Failure to implement or maintain adequate programs and controls to combat terrorist financing and money 
laundering may have serious legal, financial, and reputational consequences.

Governmental Policies and Economic Factors

The operations of BOK Financial and its subsidiaries are affected by legislative changes and by the policies of various 
regulatory authorities and, in particular, the policies of the Federal Reserve Board. The Federal Reserve Board has statutory 
objectives to maximize employment and maintain price stability. Among the instruments of monetary policy used by the 
Federal Reserve Board to implement these objectives are: open-market operations in U.S. Government securities, changes in 
the discount rate and federal funds rate on bank borrowings, and changes in reserve requirements on bank deposits. The effect 
of future changes in such policies on the business and earnings of BOK Financial and its subsidiaries is uncertain.

In response to the significant recession in business activity which began in 2007, the Federal Reserve took aggressive actions to 
reduce interest rates and provide liquidity. While many of the crisis-related programs have expired or been closed, government 
legislation and policies continue to be accommodative, including increases in government spending, reduction of certain taxes 
and promotion of affordable home programs. 

The Federal Reserve completed its bond purchase program designed to reduce longer–term rates in October of 2014. Beginning 
in October of 2017, the Federal Reserve initiated a balance sheet normalization program that will gradually reduce the 
reinvestment of principal payments from its securities holdings though the pace and extent of the reduction remains uncertain.

As a result of signs of an improving economy, the Federal Reserve increased its target rate by 25 basis points four times during 
2018. We expect the Federal Reserve will slow the frequency of rate increases in 2019 when compared to 2018. Real gross 
domestic product is forecasted to slow to about 2 percent in 2019 after being around 3 percent in 2018. The inflation rate 
increased 2 percent in 2018 and is expected to remain close to that pace in 2019. The short–term effectiveness and long–term 
impact of these programs on the economy in general and on BOK Financial in particular are uncertain.

The Tax Cuts and Jobs Act ("the Tax Reform Act"), signed into law on December 22, 2017, has had a broad impact on the 
Company and our customers. We believe that the overall impact of lower income tax rates and other provisions of the Tax 
Reform Act will be beneficial to future economic growth.

7

BOK Financial does not engage in operations in foreign countries, nor does it lend to foreign governments.

Foreign Operations

8

ITEM 1A.   RISK FACTORS

BOK Financial Corporation and its subsidiaries could be adversely affected by risks and uncertainties that could have a 
material impact on its financial condition and results of operations, as well as on its common stock and other financial 
instruments. Risk factors which are significant to the Company include, but are not limited to:

General and Regulatory Risk Factors

Adverse factors could impact BOK Financial's ability to implement its operating strategy.

Although BOK Financial has developed an operating strategy, which it expects to result in continuing improved financial 
performance, BOK Financial cannot ensure that it will be successful in fulfilling this strategy or that this operating strategy will 
be successful. Achieving success is dependent upon a number of factors, many of which are beyond BOK Financial's direct 
control. Factors that may adversely affect BOK Financial's ability to implement its operating strategy include:

•
•
•
•
•
•
•
•

deterioration of BOK Financial's asset quality;
deterioration in general economic conditions, especially in BOK Financial's core markets;
inability to control BOK Financial's non-interest expenses;
inability to increase non-interest income;
inability to access capital;
decreases in net interest margins;
increases in competition; and
adverse regulatory developments.

Substantial competition could adversely affect BOK Financial.

Banking is a competitive business. BOK Financial competes actively for loan, deposit and other financial services business in 
the southwest region of the United States. BOK Financial's competitors include a large number of small and large local and 
national banks, savings and loan associations, credit unions, trust companies, broker-dealers and underwriters, as well as many 
financial and non-financial firms that offer services similar to those of BOK Financial. Large national financial institutions 
have substantial capital, technology and marketing resources. Such large financial institutions may have greater access to 
capital at a lower cost than BOK Financial does, which may adversely affect BOK Financial's ability to compete effectively.

BOK Financial has expanded into markets outside of Oklahoma, where it competes with a large number of financial institutions 
that have an established customer base and greater market share than BOK Financial. With respect to some of its services, BOK 
Financial competes with non-bank companies that are not subject to regulation. The absence of regulatory requirements may 
give non-banks a competitive advantage.

The increasingly competitive environment is in part a result of changes in regulation, changes in technology and product 
delivery systems and the accelerating pace of consolidation among financial service providers. Our success depends on our 
ability to respond to the threats and opportunities of financial technology innovations. Developments in "fintech" and crypto-
currencies have the potential to disrupt the financial industry and change the way banks do business. Investment in new 
technology to stay competitive could result in significant costs and increased cybersecurity risk. Our success depends on our 
ability to adapt to the pace of the rapidly changing technological environment which is important to retention and acquisitions 
of customers.  

Government regulations could adversely affect BOK Financial.

BOK Financial and BOKF, NA are subject to banking laws and regulations that limit the type of acquisitions and investments 
that we may make. In addition, certain permitted acquisitions and investments are subject to prior review and approval by 
banking regulators, including the Federal Reserve, OCC and FDIC. Banking regulators have broad discretion on whether to 
approve proposed acquisitions and investments. In deciding whether to approve a proposed acquisition, federal banking 
regulators will consider, among other things, the effect of the acquisition on competition; the convenience and needs of the 
communities to be served, including our record of compliance under the Community Reinvestment Act; and our effectiveness 
in combating money laundering. They will also consider our financial condition and our future prospects, including projected 
capital ratios and levels; the competence, experience, and integrity of our management; and our record of compliance with laws 
and regulations. 

9

The last several years have seen an increase in regulatory costs borne by the banking industry. Laws, regulations or policies 
currently affecting BOK Financial and its subsidiaries may change. The implementation of the Dodd-Frank Act has and will 
continue to affect BOK Financial’s businesses, including interchange revenue, mortgage banking, derivative and trading 
activities on behalf of customers, consumer products and funds management. 

Regulatory authorities may change their interpretation of these statutes and regulations, including the OCC, our primary 
regulator, and the CFPB, our regulator for certain designated consumer laws and regulations. Violations of laws and 
regulations could limit the growth potential of BOK Financial's businesses. We have made extensive investments in human 
and technological resources to address enhanced regulatory expectations, including investments in the areas of risk 
management, compliance, and capital planning. Political developments, including the change in administration in the United 
States and more recent change in leadership in the House of Representatives, have added additional uncertainty to the 
implementation, scope and timing of changes in the regulatory environment for the banking industry and for the broader 
economy. 

Political environment could negatively impact BOK Financial’s business.

As a result of the financial crisis and related government intervention to stabilize the banking system, there have been a series 
of laws and related regulations proposed or enacted in an attempt to ensure the crisis is not repeated. Many of the new 
regulations have been far-reaching. The intervention by the government also impacted populist sentiment with a negative view 
of financial institutions. High profile mistakes by the very largest banks in the country have continued to fuel negative 
sentiment towards the banking industry. This sentiment may increase litigation risk to the Company or have an adverse impact 
on BOK Financial’s future operations. The passage of recent legislative proposals have eased some of the regulatory burden for 
BOK Financial; however, legislative outcomes and their durability are inherently uncertain. 

Credit Risk Factors

Adverse regional economic developments could negatively affect BOK Financial's business.

At December 31, 2018, loans to businesses and individuals with collateral primarily located in Texas represented approximately 
30% of the total loan portfolio, loans to businesses and individuals with collateral primarily located in Oklahoma represented 
approximately 16% of our total loan portfolio and loans to businesses and individuals with collateral primarily located in 
Colorado represented approximately 15% of our total loan portfolio. These geographic concentrations subject the loan portfolio 
to the general economic conditions within these areas. Poor economic conditions in Texas, Oklahoma, Colorado or other 
markets in the southwest region may cause BOK Financial to incur losses associated with higher default rates and decreased 
collateral values in BOK Financial's loan portfolio. A regional economic downturn could also adversely affect revenue from 
brokerage and trading activities, mortgage loan originations and other sources of fee-based revenue.

Extended oil and gas commodity price downturns could negatively affect BOK Financial customers.

At December 31, 2018, 17% of BOK Financial's total loan portfolio is comprised of loans to borrowers in the energy industry. 
The energy industry is historically cyclical and prolonged periods of low oil and gas commodity prices could negatively impact 
borrowers' ability to pay. In addition, the Company does business in several major oil and natural gas producing states 
including Oklahoma, Texas and Colorado. The economies of these states could be negatively impacted by prolonged periods of 
low oil and gas commodity prices resulting in increased credit migration to classified and nonaccruing categories, higher loan 
loss provisions and risk of credit losses from both energy borrowers and businesses and individuals in those regional 
economies.

Other adverse economic factors affecting particular industries could have a negative effect on BOK Financial customers 
and their ability to make payments to BOK Financial.

Certain industry-specific economic factors also affect BOK Financial. For example, BOK Financial's loan portfolio includes 
commercial real estate loans. A downturn in the real estate industry in general or in certain segments of the commercial real 
estate industry in the southwest region could also have an adverse effect on BOK Financial's operations. Regulatory changes in 
healthcare may negatively affect our customers. Legislation affecting reimbursement rates along with the continued transition 
to managed care in place of fee for service payments could affect their ability to pay.

10

Adverse global economic factors could have a negative effect on BOK Financial customers and counterparties.

Economic conditions globally could impact BOK Financial’s customers and counterparties with which we do business. The 
United Kingdom has not yet found an agreement regarding BREXIT, trade related issues remain between the United States and 
China, and the turmoil in Venezuela, who holds the world's largest oil reserve, continues without an obvious agreement. We 
have no direct exposure to European sovereign debt and limited exposure to European and Chinese financial institutions. We 
have not identified any significant customer exposures to European sovereign debt, European financial institutions or Chinese 
financial institutions.

Liquidity and Interest Rate Risk Factors

Fluctuations in interest rates could adversely affect BOK Financial's business.

BOK Financial's business is highly sensitive to:

•

•
•

the monetary policies implemented by the Federal Reserve Board, including the discount rate on bank borrowings and
changes in reserve requirements, which affect BOK Financial's ability to make loans and the interest rates we may
charge;
changes in prevailing interest rates, due to the dependency of the subsidiary banks on interest income;
open market operations in U.S. Government securities.

A significant increase in market interest rates, or the perception that an increase may occur, could adversely affect both BOK 
Financial's ability to originate new loans and BOK Financial's ability to grow. Conversely, a decrease in interest rates could 
result in acceleration in the payment of loans, including loans underlying BOK Financial's holdings of residential mortgage-
backed securities and termination of BOK Financial's mortgage servicing rights. In addition, changes in market interest rates, 
changes in the relationships between short-term and long-term market interest rates or changes in the relationships between 
different interest rate indices, could affect the interest rates charged on interest-earning assets differently than the interest rates 
paid on interest-bearing liabilities. This difference could result in an increase in interest expense relative to interest income, 
which would reduce the Company’s net interest revenue. In a rising interest rate environment, the composition of the deposit 
portfolio could shift resulting in a mix that is more sensitive to changes in interest rates than is the current mix. An increase in 
market interest rates also could adversely affect the ability of BOK Financial's floating-rate borrowers to meet their higher 
payment obligations. If this occurred, it could cause an increase in nonperforming assets and net charge-offs, which could 
adversely affect BOK Financial's business.

We have a significant number of loans, derivative contracts, borrowings and other financial instruments with attributes that are 
either directly or indirectly dependent on LIBOR. In 2017, the U.K. Financial Conduct Authority announced that it would no 
longer persuade or compel banks to submit to LIBOR after 2021. U.S. regulatory authorities have voiced similar support for 
phasing out LIBOR. The Federal Reserve Bank of New York's Alternative Reference Rate Committee has recommended the 
Secured Overnight Financing Rate ("SOFR") as an alternative to LIBOR.  However, for two key reasons, SOFR is a secured 
rate while LIBOR is an unsecured rate and SOFR is an overnight rate while LIBOR is published for different maturities, SOFR 
is not the economic equivalent of LIBOR. The impact of SOFR or other alternatives to LIBOR on the valuations, pricing and 
operation of our financial instruments is not yet known. 

Changes in mortgage interest rates could adversely affect mortgage banking operations along with mortgage serving rights 
as well as BOK Financial's substantial holdings of residential mortgage-backed securities, and brokerage and trading 
revenue. 

BOK Financial derives a substantial amount of revenue from mortgage banking activities, the production and sale of mortgage 
loans and the servicing of mortgage loans. In addition, as part of BOK Financial's mortgage banking business, BOK Financial 
has substantial holdings of mortgage servicing rights. Revenue generated from the production and sale of mortgage loans is 
affected by mortgage interest rates and government policies related to economic stimulus and home ownership. Falling interest 
rates tend to increase mortgage lending activities and related revenue while rising interest rates have an opposite effect. 

11

Mortgage servicing revenue is a fee earned over the life of the related loan. However, mortgage servicing rights are assets that 
are carried at fair value which are very sensitive to numerous factors with the primary factor being changes in market interest 
rates. Falling interest rates tend to increase loan prepayments, which may lead to a decrease in the value of related servicing 
rights. We attempt to manage this risk by maintaining an active hedging program. The primary objective of the Company's 
hedging program is to provide an offset to changes in the fair value of these rights due to hedgeable risks, primarily changes in 
market interest rates. Due to numerous unhedgeable factors, hedging strategies may not offset all changes in the fair value of 
the asset. Such unhedgeable factors include, but are not limited to, changes in customer prepayment or delinquency behavior 
that is inconsistent with historical actual performance in a similar market environment; changes in the long-term or short-term 
primary/secondary mortgage spreads; and changes in survey-driven assumptions such as the cost of servicing and discount 
rates. 

We also hold a substantial portfolio of residential mortgage-backed securities issued by U.S. government agencies. The fair 
value of residential mortgage-backed securities is highly sensitive to changes in interest rates.  A significant decrease in interest 
rates may lead mortgage holders to refinance the mortgages constituting the pool backing the securities, subjecting BOK 
Financial to a risk of prepayment and decreased return on investment due to subsequent reinvestment at lower interest rates. A 
significant decrease in interest rates may also accelerate premium amortization. Conversely, a significant increase in interest 
rates may cause mortgage holders to extend the term over which they repay their loans, which delays the Company’s 
opportunity to reinvest funds at higher rates. We mitigate this risk somewhat by investing principally in shorter duration 
mortgage products, which are less sensitive to changes in interest rates.

In addition, the Company actively engages in trading activities that provide U.S. government agency residential mortgage-
backed securities and related derivative instruments to our customers. Trading activities generate net interest revenue, trading 
revenue and customer hedging revenue. Trading revenue and customer hedging revenue varies in response to customer 
demand. The value of trading securities will increase in response to decreases in interest rates or decrease in response to 
increases in interest rates. We mitigate the market risk of holding trading securities through appropriate economic hedging 
techniques. 

Market disruptions could impact BOK Financial’s funding sources.

BOK Financial’s subsidiary bank may rely on other financial institutions and the Federal Home Loan Bank of Topeka as a 
significant source of funds. Our ability to fund loans, manage our interest rate risk and meet other obligations depends on funds 
borrowed from these sources. The inability to borrow funds at market interest rates could have a material adverse effect on our 
operations.

Operating Risk Factors

Dependence on technology increases cybersecurity risk.

As a financial institution, we process a significant number of customer transactions and possess a significant amount of 
sensitive customer information. As technology advances, the ability to initiate transactions and access data has become more 
widely distributed among mobile phones, personal computers, automated teller machines, remote deposit capture sites and 
similar access points. These technological advances increase cybersecurity risk. While the Company maintains programs 
intended to prevent or limit the effects of cybersecurity risk, there is no assurance that unauthorized transactions or 
unauthorized access to customer information will not occur. The financial, reputational and regulatory impact of unauthorized 
transactions or unauthorized access to customer information could be significant.

We depend on third parties for critical components of our infrastructure.

We outsource a significant portion of our information systems, communications, data management and transaction processing 
to third parties. These third parties are sources of risk associated with operational errors, system interruptions or breaches, 
unauthorized disclosure of confidential information and misuse of intellectual property. If the service providers encounter any 
of these issues, we could be exposed to disruption of service, reputation damages, and litigation risk that could be material to 
our business. 

Integration of  BOK Financial and CoBiz may be more difficult, costly or time consuming than expected and the anticipated 
benefits and cost savings of the merger may not be realized.

The success of the merger will depend on a number of factors including:

•

Successful integration of the acquired business into current operations;

12

•
•
•
•

Retention of acquired deposits and earning assets;
Control over incremental non-interest expense;
Retention of certain key employees; and
Continued performance of the CoBiz credit portfolio.

The acquisition of CoBiz which represents BOK Financials’s largest transaction to date, includes anticipated benefits and cost 
savings, that depend, in part, on our ability to successfully combine and integrate the businesses in a manner that permits 
growth opportunities and does not materially disrupt existing customer relations nor result in decreased revenues due to loss of 
customers. Business disruptions may cause customers to remove their accounts to competing financial institutions. Disruption 
of ongoing businesses or inconsistencies in standards, controls, procedures and policies may adversely affect our ability to 
maintain relationships with clients, customers, depositors and employees or to achieve the anticipated benefits and cost savings 
of the merger. In addition, the loss of key employees could adversely affect our ability to successfully conduct its business. We 
may also encounter unexpected difficulties or costs during the integration. Integration efforts may also divert management 
attention and resources. 

Risks Related to an Investment in Our Stock

Although publicly traded, BOK Financial's common stock has substantially less liquidity than the average trading market 
for a stock quoted on the NASDAQ National Market System.

A relatively small fraction of BOK Financial's outstanding common stock is actively traded. The risks of low liquidity include 
increased volatility of the price of BOK Financial's common stock. Low liquidity may also limit holders of BOK Financial's 
common stock in their ability to sell or transfer BOK Financial's shares at the price, time and quantity desired.

BOK Financial's principal shareholder controls a majority of BOK Financial's common stock.

Mr. George B. Kaiser owns approximately 53% of the outstanding shares of BOK Financial's common stock at December 31, 
2018. Mr. Kaiser is able to elect all of BOK Financial's directors and effectively control the vote on all matters submitted to a 
vote of BOK Financial's common shareholders. Mr. Kaiser's ability to prevent an unsolicited bid for BOK Financial or any 
other change in control could have an adverse effect on the market price for BOK Financial's common stock. A substantial 
majority of BOK Financial's directors are not officers or employees of BOK Financial or any of its affiliates. However, because 
of Mr. Kaiser's control over the election of BOK Financial's directors, he could change the composition of BOK Financial's 
Board of Directors so that it would not have a majority of outside directors.

Possible future sales of shares by BOK Financial's principal shareholder could adversely affect the market price of BOK 
Financial's common stock.

Mr. Kaiser has the right to sell shares of BOK Financial's common stock in compliance with the federal securities laws at any 
time, or from time to time. The federal securities laws will be the only restrictions on Mr. Kaiser's ability to sell. Because of his 
current control of BOK Financial, Mr. Kaiser could sell large amounts of his shares of BOK Financial's common stock by 
causing BOK Financial to file a registration statement that would allow him to sell shares more easily. In addition, Mr. Kaiser 
could sell his shares of BOK Financial's common stock without registration under Rule 144 of the Securities Act. Although 
BOK Financial can make no predictions as to the effect, if any, that such sales would have on the market price of BOK 
Financial's common stock, sales of substantial amounts of BOK Financial's common stock, or the perception that such sales 
could occur, could adversely affect market prices. If Mr. Kaiser sells or transfers his shares of BOK Financial's common stock 
as a block, another person or entity could become BOK Financial's controlling shareholder.

Statutory restrictions on subsidiary dividends and other distributions and debts of BOK Financial's subsidiaries could limit 
amounts BOK Financial's subsidiaries may pay to BOK Financial.

A substantial portion of BOK Financial's cash flow typically comes from dividends paid by BOKF, NA. Statutory provisions 
and regulations restrict the amount of dividends BOKF, NA may pay to BOK Financial without regulatory approval. 
Management also developed, and the BOK Financial board of directors approved, an internal capital policy that is more 
restrictive than the regulatory capital standards. In the event of liquidation, creditors of the subsidiary banks and other non-bank 
subsidiaries of BOK Financial are entitled to receive distributions from the assets of that subsidiary before BOK Financial, as 
holder of an equity interest in the subsidiaries, is entitled to receive any distributions. 

13

ITEM 1B.   UNRESOLVED STAFF COMMENTS

None.

ITEM 2.   PROPERTIES

BOK Financial and its subsidiaries own and lease improved real estate that is carried at $196 million, net of depreciation and 
amortization. The Company’s principal offices are located in leased premises in the Bank of Oklahoma Tower in Tulsa, 
Oklahoma. Banking offices are primarily located in Tulsa and Oklahoma City, Oklahoma; Dallas, Fort Worth and Houston, 
Texas; Albuquerque, New Mexico; Denver, Colorado; Phoenix, Arizona; and Kansas City, Kansas/Missouri. Primary 
operations facilities are located in Tulsa and Oklahoma City, Oklahoma; Dallas, Texas and Albuquerque, New Mexico. The 
Company’s facilities are suitable for their respective uses and present needs.

The information set forth in Notes 5 and 14 of the Company’s Notes to Consolidated Financial Statements, which appear 
elsewhere herein, provides further discussion related to properties.

ITEM 3.   LEGAL PROCEEDINGS

The information set forth in Note 14 of the Company’s Notes to Consolidated Financial Statements, which appear elsewhere 
herein, provides discussion related to legal proceedings.

ITEM 4.   MINE SAFETY DISCLOSURES

Not applicable.

14

PART II

ITEM 5.   MARKET FOR REGISTRANT’S COMMON EQUITY, RELATED STOCKHOLDER MATTERS AND 
ISSUER PURCHASES OF EQUITY SECURITIES

BOK Financial’s $0.00006 par value common stock is traded on the NASDAQ Stock Market under the symbol BOKF. As of 
January 31, 2019, common shareholders of record numbered 755 with 72,251,266 shares outstanding.

The highest and lowest quarterly closing bid price for shares and cash dividends declared per share of BOK Financial common 
stock follows:

2018:

Low

High

Cash dividends declared

2017:

Low

High

Cash dividends declared

First

Second

Third

Fourth

$

90.62

$

93.00

$

93.33

$

100.98

0.45

105.24

0.45

104.74

0.50

$

75.15

$

74.34

$

77.30

$

84.81

0.44

85.83

0.44

89.08

0.44

70.61

96.91

0.50

82.30

93.50

0.45

15

Shareholder Return Performance Graph

Set forth below is a line graph comparing the change in cumulative shareholder return of the NASDAQ Composite Index, the 
KBW NASDAQ Bank Index and the SNL U.S. Bank NASDAQ Index for the period commencing December 31, 2013 and 
ending December 31, 2018.*

Index
BOK Financial Corporation
NASDAQ Composite
SNL U.S. Bank NASDAQ
KBW NASDAQ Bank Index

Period Ending December 31,

2013

2014

2015

2016

2017

2018

100.00
100.00
100.00
100.00

92.79
114.75
103.57
109.37

94.85
122.74
111.80
109.91

135.55
133.62
155.02
141.24

154.01
173.22
163.20
167.50

124.75
168.30
137.56
137.83

* Graph assumes value of an investment in the Company's Common Stock for each index was $100 on December 31, 2013. Cash dividends

on Common Stock are assumed to have been reinvested in BOK Financial Common Stock.

16

The following table provides information with respect to purchases made by or on behalf of the Company or any “affiliated 
purchaser” (as defined in Rule 10b-18(a)(3) under the Securities Exchange Act of 1934), of the Company’s common stock 
during the three months ended December 31, 2018.

Period

October 1, 2018 to October 31, 2018

November 1, 2018 to November 30, 2018

December 1, 2018 to December 31, 2018

Total 
Number of 
Shares 
Purchased 
as Part of 
Publicly 
Announced 
Plans or 
Programs 1
200,000

235,000

90,000

Maximum
Number of
Shares that
May Yet Be
Purchased
Under the
Plans

1,749,917

1,514,917

1,424,917

Total 
Number of 
Shares 
Purchased 2
200,000

235,000

90,000

Average 
Price Paid 
per Share

$

$

$

85.08

88.68

80.02

Total
1  On October 1, 2015, the Company's board of directors authorized the Company to repurchase up to five million shares of the Company's 
common stock. As of December 31, 2018, the Company had repurchased 3,575,083 shares under this plan. Future repurchases of the 
Company's common stock will vary based on market conditions, regulatory limitations and other factors. 

525,000

525,000

2  The Company may repurchase shares from employees to cover the exercise price and taxes in connection with employee shared-based 

compensation.

17

ITEM 6.  SELECTED FINANCIAL DATA

The selected financial data is set forth within Table 1 of Item 7, “Management’s Discussion and Analysis of Financial 
Condition and Results of Operations.”

ITEM 7.  Management’s Discussion and Analysis of Financial Condition and Results of Operations

Table 1 – Consolidated Selected Financial Data

(Dollars in thousands, except per share data)

Selected Financial Data

For the year:

Interest revenue

Interest expense

Net interest revenue

Provision for credit losses
Fees and commissions revenue5
Net income attributable to BOK Financial

Corporation shareholders

Period-end:

Loans

Assets

Deposits

Shareholders’ equity
Nonperforming assets1

2018

2017

2016

2015

2014

December 31,

$

1,228,426

$

972,751

$

829,117

$

766,828

$

732,239

243,559

984,867

8,000

643,642

131,050

841,701

(7,000)

642,390

81,889

747,228

65,000

647,726

63,474

703,354

34,000

614,960

67,045

665,194

—

588,012

445,646

334,644

232,668

288,565

292,435

21,656,730

17,153,424

16,989,660

15,941,154

38,020,504

32,272,160

32,772,281

31,476,128

25,263,763

22,061,305

22,748,095

21,088,158

4,432,109

3,495,367

3,274,854

3,230,556

267,162

290,305

356,641

251,908

14,208,037

29,089,698

21,140,859

3,302,179

256,617

Profitability Statistics

Earnings per share (based on average equivalent

shares):

Basic

Diluted

Percentages (based on daily averages):

Return on average assets

Return on average shareholders' equity

Average total equity to average assets

Common Stock Performance

Per Share:

Book value per common share

Market price: December 31 close

Market range – High close bid price

Market range – Low close bid price

Cash dividends declared

Dividend payout ratio

$

$

$

6.63

6.63

$

5.11

5.11

$

3.53

3.53

$

4.22

4.21

4.23

4.22

1.28%

11.98%

10.70%

1.02%

9.82%

10.43%

0.72%

7.02%

10.38%

0.94%

8.65%

11.03%

1.04%

9.21%

11.47%

$

61.45

73.33

105.24

70.61

1.90

$

53.45

92.32

93.50

74.34

1.77

$

50.12

83.04

84.13

44.72

1.73

$

49.03

59.79

72.44

53.37

1.69

47.78

60.04

70.18

57.87

1.62

28.55%

34.45%

48.81%

40.03%

38.35%

18

Table 1 – Consolidated Selected Financial Data

(Dollars in thousands, except per share data)

Selected Financial Data

Selected Balance Sheet Statistics

Period-end:

Common equity Tier 1 ratio2
Tier 1 capital ratio2
Total capital ratio2
Leverage ratio2
Allowance for loan losses to nonaccruing loans4
Allowance for loan losses to loans
Combined allowances for credit losses to loans 3

Miscellaneous (at December 31)

Number of employees (full-time equivalent)

Number of TransFund locations

Fiduciary assets

2018

2017

2016

2015

2014

December 31,

10.92%

10.92%

12.50%

8.96%

12.05%

12.05%

13.54%

9.31%

11.21%

11.21%

12.81%

8.72%

12.13%

12.13%

13.30%

9.25%

N/A

13.33%

14.66%

9.96%

132.89%

129.09%

112.33%

180.09%

245.34%

0.96%

0.97%

5,313

2,426

1.34%

1.37%

4,930

2,223

1.45%

1.52%

4,884

2,021

1.41%

1.43%

4,789

1,972

1.33%

1.34%

4,743

2,080

$ 44,841,339

$48,761,477

$42,378,053

$38,333,638

$ 35,997,877

Mortgage loans serviced for others

21,658,335

22,046,632

21,997,568

19,678,226

16,162,887

1  Includes nonaccruing loans, renegotiated loans and assets acquired in satisfaction of loans. Excludes loans past due 90 days or more and still accruing.
2  Risk-based capital ratios for 2018, 2017, 2016 and 2015 calculated under revised regulatory capital rules issued July 2013 and effective for the Company on 

January 1, 2015. Previous risk-based ratios presented are calculated in accordance with then current regulatory capital rules. 

3  Includes allowance for loan losses and accrual for off-balance sheet credit risk.
4  Excludes residential mortgage loans guaranteed by agencies of the U.S. government.
5   Non-GAAP measure to net interchange charges from prior years between transaction card revenue and data processing and communications expense as a 

result of the recent revenue recognition standard. This measure has no effect on net income or earnings per share.

Management’s Assessment of Operations and Financial Condition

Overview

The following discussion is management’s analysis to assist in the understanding and evaluation of the financial condition and 
results of operations of BOK Financial Corporation ("BOK Financial" or "the Company"). This discussion should be read in 
conjunction with the Consolidated Financial Statements and footnotes and selected financial data presented elsewhere in this 
report.

For 2018, the U.S. economy continued to grow, supported by declining unemployment, continued payroll growth and modest 
inflation. GDP increased 3.5% through the third quarter of 2018 and is expected to remain in the range of 2 to 3 percent in 
2019. The national unemployment rate fell to 3.1% at December of 2018 from 4.1% in December of 2017. Inflation also 
remained low around 2% for 2018. The minutes of the Federal Open Market Committee ("FOMC") of the Federal Reserve for 
December indicated continued strengthening of labor market conditions and unchanged longer-run inflation expectations. 

The Federal Reserve increased the target range for the federal funds rate by 25 basis points four times during 2018. The 10-year 
U.S. Treasury note finished the year yielding 2.69% versus 2.40% at December 31, 2017. We expect rates to continue to rise in 
2019. Global quantitative easing and lack of inflation, combined with continued gradual federal funds rate increases by the 
Federal Reserve are contributing to a flattening of the yield curve; however, a yield curve inversion is not expected. Higher 
long-term interest rates are likely in 2019. 

19

Performance Summary

Net income for the year ended December 31, 2018 totaled $445.6 million or $6.63 per diluted share compared with net income 
of $334.6 million or $5.11 per diluted share for the year ended December 31, 2017. 

On October 1, 2018, the Company acquired CoBiz Financial, Inc. ("CoBiz"). CoBiz is headquartered in Denver with a presence 
in Colorado and Arizona. The Company paid total consideration of $944 million, which included $243 million in cash along 
with the issuance of 7.2 million shares of BOK Financial stock valued at $701 million, in exchange for all outstanding shares of 
CoBiz stock. We anticipate a full bank consolidation in the first quarter of 2019.

We incurred $16.6 million of closing and integration costs, which resulted in an $0.18 per share reduction in 2018. A fee earned 
through the sale of client assets of $15.4 million was recognized in 2018 accounting for a $0.17 per share addition. The 
fluctuation discussion in the highlights below exclude the impact of these items.

Highlights of 2018 included:

•

•

•

•

•

•

•

•

•

•

Net interest revenue totaled $984.9 million for 2018, up from $841.7 million for 2017. CoBiz added $43.1 million to net
interest revenue. The remaining increase was driven by both widening spreads and growth in average assets. Net interest
margin was 3.20% for 2018 compared to 2.92% for 2017. Average earning assets were $31.0 billion for 2018, up $1.4
billion over 2017 with $950 million due to CoBiz.

Fees and commissions revenue was $643.6 million for 2018, a decrease of $14.1 million compared to 2017. Brokerage
and trading revenue decreased $23.3 million primarily due to the cost of financial instruments used to hedge our trading
portfolio. Mortgage banking revenue decreased $6.9 million affected by the impact of rising interest rates on mortgage
loan origination volumes. Fiduciary and asset management revenue increased $6.4 million.

The change in the fair value of mortgage servicing rights, net of economic hedges, decreased other operating revenue by
$20.4 million in 2018, compared to $1.9 million in 2017. This increase is due to the combination of unhedgeable factors
and significant mortgage rate volatility. This amount does not include hedge-related net interest revenue of $4.8 million.

Other operating expense totaled $1.0 billion, a $24.9 million increase compared to 2017, including $29.7 million of costs
related to CoBiz operations in the fourth quarter of 2018. Excluding CoBiz operating costs, personnel expense decreased
$15.2  million. Annual  merit  increases  were  offset  by  a  decrease  in  incentive  compensation  expense.  Non-personnel
expense increased $10.4 million. Increases in occupancy and equipment, data processing and communications, and net
losses and expenses on repossessed assets were partially offset by a decrease in mortgage banking costs.

The Company recorded an $8.0 million provision for credit losses in 2018, compared to a $7.0 million negative provision
for credit losses in 2017. The 2018 provision reflected loan growth partially offset by continued improvement in credit
metrics. Nonaccruing loans not guaranteed by U.S. government agencies decreased $23 million compared to December 31,
2017. Potential problem loans decreased $26 million while other loans especially mentioned increased $64 million. Net
charge-offs were $33 million or 0.18% of average loans for 2018, compared to net charge-offs of $16 million or 0.09%
of average loans for 2017. The combined allowance for credit losses totaled $209 million or 0.97% of outstanding loans
and 1.12%, excluding loans from CoBiz, at December 31, 2018.

Period-end outstanding loan balances were $21.7 billion at December 31, 2018, a $4.5 billion increase over the prior
year. CoBiz added $2.9 billion of loans during 2018. Excluding acquired loans, commercial loan balances grew by $1.1
billion or 10% and commercial real estate loans grew by $447 million or 13%.

Period-end deposits totaled $25.3 billion at December 31, 2018, a $3.2 billion increase compared to December 31, 2017.
Excluding $3.3 billion of acquired deposits, interest-bearing transaction deposits increased $244 million, while demand
deposit balances decreased $330 million.

Common equity Tier 1 capital ratio was 10.92% at December 31, 2018. In addition, the Tier 1 capital ratio was 10.92%,
total capital ratio was 12.50% and leverage ratio was 8.96% at December 31, 2018. At December 31, 2017, the Tier 1
capital ratio was 12.05%, the total capital ratio was 13.54% and the leverage ratio was 9.31%.

The Company repurchased 615,840 shares at an average price of $86.82 per share during 2018 and 80,000 shares at an
average price of $92.54 during 2017.

The Company paid cash dividends of $1.90 per common share during 2018 and $1.77 per common share in 2017.

20

Net income for the fourth quarter of 2018 totaled $108 million or $1.50 per diluted share, up from $72.5 million or $1.11 per 
diluted share for the fourth quarter of 2017. The fourth quarter earnings per share included a $0.15 per share reduction as a 
result of CoBiz closing and integration costs of $14.5 million. The highlights below exclude this amount.

Income tax expense was $20.1 million or 15.7%  of net income before taxes for the fourth quarter of 2018 and $54.3 million or 
42.9% of net income before taxes for the fourth quarter of 2017. The Tax Reform Act enacted in 2017 added $11.7 million of 
expense to the fourth quarter of 2017 largely due to the revaluation of net deferred taxes. The 2017 tax returns were finalized in 
the fourth quarter of 2018. This resolved several uncertainties caused by last year's Tax Cuts and Jobs Act. Resolution of these 
uncertainties and other routine adjustments reduced tax expense for the quarter by $8.6 million.

Highlights of the fourth quarter of 2018 included:

•

•

•

•

Net interest revenue totaled $285.7 million for the fourth quarter of 2018, up $68.8 million over the fourth quarter of
2017. CoBiz added $43.1 million to net interest revenue in the fourth quarter of 2018. Net interest margin was 3.40% for
the fourth quarter of 2018, up from 2.97% for the fourth quarter of 2017. Net interest revenue increased primarily due to
four 25 basis point increases in the federal funds rate by the Federal Reserve during 2018 and growth in average loan
balances.

Fees and commissions revenue totaled $160.1 million, up $2.2 million over the fourth quarter of 2017. Increases in trust
fees and commissions, service charges, and other revenue were partially offset by decreases in brokerage and trading and
mortgage banking revenue. This amount does not include hedge-related net interest revenue of $695 thousand.

The loss in the fair value of mortgage servicing rights, net of economic hedges, was $12.4 million in the fourth quarter
of 2018 compared to $1.4 million in the fourth quarter of 2017. This increase is due primarily to the combination of
unhedgeable factors and significant mortgage volatility in the fourth quarter of 2018.

Operating expenses in the fourth quarter totaled $270.1 million, a $15.6 million increase compared to the prior year,
including $29.7 million related to CoBiz operations. Excluding these costs, personnel expense decreased $9.6 million
primarily due to changes in vesting assumptions related to share-based compensation. Non-personnel expenses decreased
$4.5 million. An increase in occupancy and equipment and net losses and expenses of repossessed assets was offset by
a decrease in mortgage banking costs and professional fees and services.

21

Critical Accounting Policies & Estimates

The Consolidated Financial Statements and accompanying notes are prepared in accordance with generally accepted 
accounting principles in the United States of America (“GAAP”). The Company's accounting policies are more fully described 
in Note 1 of the Consolidated Financial Statements. Management makes significant assumptions and estimates in the 
preparation of the Consolidated Financial Statements and accompanying notes in conformity with GAAP that may be highly 
subjective, complex and subject to variability. Actual results could differ significantly from these assumptions and estimates. 
The following discussion addresses the most critical areas where these assumptions and estimates could affect the financial 
condition, results of operations and cash flows of the Company. These critical accounting policies and estimates have been 
discussed with the appropriate committees of the Board of Directors.

Allowance for Loan Losses and Accrual for Off-Balance Sheet Credit Risk 

The appropriateness of the allowance for loan losses and accrual for off-balance sheet credit risk is assessed quarterly by 
management based on an ongoing evaluation of the probable estimated losses inherent in the loan portfolio and probable 
estimated losses on unused commitments to provide financing. A consistent, well-documented methodology has been 
developed and is applied by an independent Credit Administration department to ensure consistency across the Company. The 
allowance for loan losses consists of specific allowances attributed to certain impaired loans that have not yet been charged 
down to amounts we expect to recover, general allowances for unimpaired loans that are based on estimated loss rates by loan 
class and nonspecific allowances for risks beyond factors specific to a particular portfolio segment or loan class. There have 
been no material changes in the approach or techniques utilized in developing the allowance for loan losses and accrual for off-
balance sheet credit risk during 2018.

Loans are considered impaired when it is probable that we will not collect all amounts due according to the contractual terms of 
the loan agreements, including loans modified in a troubled debt restructuring. Internally risk graded loans are evaluated 
individually for impairment. Substantially all commercial and commercial real estate loans and certain residential mortgage and 
personal loans are risk graded through a quarterly evaluation of the borrower's ability to repay. 

Specific allowances for impaired loans that have not yet been charged down to amounts we expect to recover are measured by 
an evaluation of estimated future cash flows discounted at the loan's initial effective interest rate or the fair value of collateral 
for certain collateral dependent loans. Collateral value of real property is generally based on third party appraisals that conform 
to Uniform Standards of Professional Appraisal Practice, less estimated selling costs. Appraised values are on an “as-is” basis 
and generally are not adjusted by the Company. Updated appraisals are obtained at least annually or more frequently if market 
conditions indicate collateral values may have declined. Collateral value of mineral rights is determined by our internal staff of 
engineers based on projected cash flows under current market conditions. The value of other collateral is generally determined 
by our special assets staff based on liquidation cash flows under current market conditions. Collateral values and available cash 
resources that support impaired loans are evaluated quarterly. Historical statistics may be used as a practical way to estimate 
impairment in limited situations, such as when a collateral dependent loan is identified as impaired near the end of a reporting 
period until an updated appraisal of collateral value is received or a full assessment of future cash flows is completed. Estimates 
of future cash flows and collateral values require significant judgments and may be volatile. 

General allowances for unimpaired loans are based on estimated loss rates by loan class. The appropriate historical gross loss 
rate for each loan class is determined by the greater of the current loss rate based on the most recent twelve months or a ten-
year average gross loss rate. Recoveries are not directly considered in the estimation of historical loss rates. Recoveries 
generally do not follow predictable patterns and are not received until well-after the charge-off date as a result of protracted 
legal proceedings. For risk graded loans, historical loss rates are adjusted for changes in risk rating. For each loan class, the 
weighted average current risk grade is compared to the weighted average long-term risk grade. This comparison determines 
whether the risk in each loan class is increasing or decreasing. Historical loss rates are adjusted upward or downward in 
proportion to changes in weighted average risk grading. General allowances for unimpaired loans also consider inherent risks 
identified for a given loan class. Inherent risks include consideration of the loss rates that most appropriately represent the 
current credit cycle and other factors attributable to a specific loan class which have not yet been represented in the historical 
gross loss rates or risk grading. Examples of these factors include changes in commodity prices or engineering imprecision, 
which may affect the value of reserves that secure our energy loan portfolio, construction risk that may affect commercial real 
estate loans, changes in regulations and public policy that may disproportionately impact health care loans and changes in loan 
product types.  

Nonspecific allowances are maintained for risks beyond factors specific to a particular portfolio segment or loan class. These 
factors include trends in the economy in our primary lending areas, concentrations in loans with large balances and other 
relevant factors. 

22

Fair Value Measurement

Certain assets and liabilities are recorded at fair value in the Consolidated Financial Statements. Fair value is defined by 
applicable accounting guidance as the price to sell an asset or transfer a liability in an orderly transaction between market 
participants in the principal markets for the given asset or liability at the measurement date based on market conditions at that 
date. An orderly transaction assumes exposure to the market for a customary period for marketing activities prior to the 
measurement date and not a forced liquidation or distressed sale.

A hierarchy for fair value has been established that prioritizes the inputs of valuation techniques used to measure fair value into 
three broad categories: unadjusted quoted prices in active markets for identical assets or liabilities (Level 1), other observable 
inputs that can be observed either directly or indirectly (Level 2) and unobservable inputs for assets or liabilities (Level 3). Fair 
value may be recorded for certain assets and liabilities every reporting period on a recurring basis or under certain 
circumstances on a non-recurring basis. Fair value adjustments of significant assets or liabilities that are based on unobservable 
inputs (Level 3) are considered Critical Accounting Policies and Estimates. Additional discussion of fair value measurement 
and disclosure is included in Notes 7 and 19 of the Consolidated Financial Statements. 

Mortgage Servicing Rights

We have a significant investment in mortgage servicing rights. Our mortgage servicing rights are primarily retained 
from sales in the secondary market of residential mortgage loans we have originated or purchased from correspondent 
lenders. Occasionally, mortgage servicing rights may be purchased from other lenders. Both originated and purchased 
mortgage servicing rights are initially recognized at fair value. We carry all mortgage servicing rights at fair value. 
Changes in fair value are recognized in earnings as they occur.

Mortgage servicing rights are not traded in active markets. The fair value of mortgage servicing rights is determined 
by discounting the projected cash flows. Certain significant assumptions and estimates used in valuing mortgage 
servicing rights are based on current market sources including projected prepayment speeds, assumed servicing costs, 
earnings on escrow deposits, ancillary income and discount rates. Assumptions used to value our mortgage servicing 
rights are considered significant unobservable inputs and represent our best estimate of assumptions that market 
participants would use to value this asset. A separate third party model is used to estimate prepayment speeds based on 
interest rates, housing turnover rates, estimated loan curtailment, anticipated defaults and other relevant factors. The 
prepayment model is updated periodically for changes in market conditions and adjusted to better correlate with actual 
performance of our servicing portfolio. The discount rate is based on benchmark rates for mortgage loans plus a 
market spread expected by investors in servicing rights. Significant assumptions used to determine the fair value of 
our mortgage servicing rights are presented in Note 7 to the Consolidated Financial Statements. At least annually, we 
request estimates of fair value from outside sources to corroborate the results of the valuation model.

The assumptions used in this model are primarily based on mortgage interest rates. Evaluation of the effect of a 
change in one assumption without considering the effect of that change on other assumptions is not meaningful. 
Considering all related assumptions, we expect a 50 basis point increase in primary mortgage interest rates to increase 
the fair value of our servicing rights by $19 million. We expect a $27 million decrease in the fair value of our 
mortgage servicing rights from a 50 basis point decrease in primary mortgage interest rates.  

Valuation of Impaired Loans and Real Estate and Other Repossessed Assets

The fair value of collateral for certain impaired loans and real estate and other repossessed assets is measured on a 
non-recurring basis. The fair value of real estate is generally based on unadjusted third-party appraisals derived 
principally from or corroborated by observable market data. Fair value measurements based on these appraisals are 
considered to be based on Level 2 inputs. Fair value measurements based on appraisals that are not based on 
observable inputs or that require significant adjustments by us or fair value measurements that are not based on third-
party appraisals are considered to be based on Level 3 inputs. Significant unobservable inputs include listing prices for 
comparable assets, uncorroborated expert opinions or management's knowledge of the collateral or industry.

23

The fair value of mineral rights is generally determined by our internal staff of engineers based on projected cash 
flows from proven oil and gas reserves under existing economic and operating conditions. Proven oil and gas reserves 
are estimated quantities that geological and engineering data demonstrate, with reasonable certainty, to be recoverable 
in future years from known reservoirs using existing prices and costs. Projected cash flows incorporate assumptions 
related to a number of factors including production, sales prices, operating expenses, severance, ad valorem taxes, 
capital costs and appropriate discount rate. Fair values determined through this process are considered to be based on 
Level 3 inputs.  

Income Taxes

Determination of income tax expense and related assets and liabilities is complex and requires estimates and judgments when 
applying tax laws, rules, regulations and interpretations. It also requires judgments as to future earnings and the timing of future 
events. Accrued income taxes represent an estimate of net amounts due to or from taxing jurisdictions based upon these 
estimates, interpretations and judgments.

Management evaluates the Company's current tax expense or benefit based upon estimates of taxable income, tax credits and 
statutory tax rates. Annually, we file tax returns with each jurisdiction where we conduct business and adjust recognized income 
tax expense or benefit to filed tax returns.

We recognize deferred tax assets and liabilities based upon the differences between the values of assets and liabilities as 
recognized in the financial statements and their related tax basis using enacted tax rates in effect for the year in which the 
differences are expected to be recovered or settled. A valuation allowance is provided when it is more likely than not that some 
portion of the entire deferred tax asset may not be realized.  

We also recognize the benefit of uncertain tax positions when based upon all relevant evidence, it is more-likely-than-not that 
our position would prevail upon examination, including resolution of related appeals or litigation, based upon the technical 
merits of the position. Unrecognized tax benefits, including estimated interest and penalties, are part of our current accrued 
income tax liability. Estimated penalties and interest are recognized in income tax expense. Income tax expense in future 
periods may decrease if an uncertain tax position is favorably resolved, generally upon completion of an examination by the 
taxing authorities, expiration of a statute of limitations, or changes in facts and circumstances.

24

Results of Operations

Net Interest Revenue and Net Interest Margin

Net interest revenue is the interest earned on debt securities, loans and other interest-earning assets less interest paid for 
interest-bearing deposits and other borrowings. The net interest margin is calculated by dividing tax-equivalent net interest 
revenue by average interest-earning assets. Net interest spread is the difference between the average rate earned on interest-
earning assets and the average rate paid on interest-bearing liabilities. Net interest margin is typically greater than net interest 
spread due to interest income earned on assets funded by non-interest bearing liabilities such as demand deposits and equity.

Tax-equivalent net interest revenue totaled $993.8 million for 2018, up from $858.9 million for 2017. Tax-equivalent net 
interest revenue increased $134.9 million over the prior year. The acquisition of CoBiz in the fourth quarter of 2018 added 
$43.1 million to net interest revenue, including $6.4 million of net purchase accounting discount accretion. Net interest revenue 
increased $55.5 million due to rates and $79.4 million from growth in earning assets. The benefit of an increase in short-term 
interest rates on floating-rate earning assets was partially offset by higher borrowing costs. Table 2 shows the effects on net 
interest revenue due to changes in average balances and interest rates for the various types of earning assets and interest-
bearing liabilities. In addition, see the Annual and Quarterly Financial Summary of consolidated daily average balances, yields 
and rates following the Consolidated Financial Statements.

Net interest margin was 3.20% for 2018 and 2.92% for 2017. The tax-equivalent yield on earning assets was 3.98% for 2018, 
up from 3.36% in 2017, primarily due to increases in short-term interest rates resulting from four 25 basis point increases in the 
federal funds rate by the Federal Reserve during the year. Loan yields increased 67 basis points to 4.80%. The available for sale 
securities portfolio yield increased 22 basis points to 2.35%. The yield on interest-bearing cash and cash equivalents increased 
70 basis points to 1.80%. Funding costs increased 52 basis points over 2017. The cost of interest-bearing deposits increased 30 
basis points. The cost of other borrowed funds increased 86 basis points. The benefit to net interest margin from earning assets 
funded by non-interest bearing liabilities was 41 basis points for 2018, up from 23 basis points for 2017.

Average earning assets for 2018 increased $1.4 billion or 5% over 2017 with $950 million due to CoBiz. Average loans, net of 
allowance for loan losses, increased $1.6 billion led by growth in average commercial and commercial real estate loans. 
Average trading securities balances increased $1.0 billion primarily related to expanded U.S. mortgage-backed securities 
trading activity. Average interest-bearing cash and cash equivalents decreased $768 million as we reduced our balances held at 
the Federal Reserve, including cash used in our purchase of CoBiz. The average balance of available for sale securities, which 
consists largely of residential and commercial mortgage-backed securities guaranteed by U.S. government agencies, decreased 
$144 million. We purchase securities to supplement earnings and to manage interest rate risk. We have reduced the size of our 
bond portfolio during the past four years through normal monthly runoff to better position the balance sheet for an environment 
of rising longer-term rates. 

Total average deposits grew by $624 million over the prior year, including $859 million from the CoBiz acquisition. Excluding 
acquired deposits, average demand deposit balances decreased $131 million, average interest-bearing transaction account 
balances decreased $62 million and average time deposit balances decreased $81 million. Average borrowed funds increased 
$709 million over the prior year. Borrowings from the Federal Home Loan Banks increased $325 million and average funds 
purchased and repurchase agreement balances increased $392 million over the prior year. 

Our overall objective is to manage the Company’s balance sheet to be relatively neutral to changes in interest rates as is further 
described in the Market Risk section of this report. As shown in Table 21, approximately 79% of our commercial and 
commercial real estate loan portfolios are either variable rate loans or fixed rate loans that will re-price within one year. These 
loans are funded primarily by deposit accounts that are either non-interest bearing, or that re-price more slowly than the 
loans. The result is a balance sheet that would be asset sensitive, which means that assets generally re-price more quickly than 
liabilities. Among the strategies that we use to manage toward a relatively rate-neutral position, we purchase fixed rate 
residential mortgage-backed securities issued primarily by U.S. government agencies and fund them with market rate sensitive 
liabilities. The liability-sensitive nature of this strategy provides an offset to the asset-sensitive characteristics of our loan 
portfolio. We also may use derivative instruments to manage our interest rate risk. 

The effectiveness of these strategies is reflected in the overall change in net interest revenue due to changes in interest rates as 
shown in Table 2 and in the interest rate sensitivity projections as shown in the Market Risk section of this report. 

25

Fourth Quarter 2018 Net Interest Revenue

Tax-equivalent net interest revenue totaled $288.8 million for the fourth quarter of 2018, an increase of $67.8 million over the 
fourth quarter of 2017. CoBiz added $43.1 million to net interest revenue, including $6.4 million of net purchase accounting 
discount accretion. Net interest revenue increased $18.3 million primarily due to four 25 basis point increases in the federal 
funds rate by the Federal Reserve during 2018 and $49.4 million primarily due to the growth in average loan balances. 

Net interest margin was 3.40% for the fourth quarter of 2018 compared to 2.97% for the fourth quarter of 2017. The tax-
equivalent yield on earning assets was 4.33% for the fourth quarter of 2018, up 84 basis points over the fourth quarter of 
2017. Loan yields increased 80 basis points to 5.09%, including 12 basis points from net purchase accounting discount 
accretion. The remaining increase is due mainly to short-term market interest rates related to the Federal Reserve's four 25 basis 
point increases in 2018. The available for sale securities portfolio yield increased 30 basis points to 2.51%. The yield on 
interest-bearing cash and cash equivalents increased 96 basis points to 2.23%. Yield on trading securities increased 72 basis 
points to 4.10%. Funding costs were up 63 basis points over the fourth quarter of 2017. The cost of interest-bearing deposits 
increased 39 basis points over the fourth quarter of 2017. The cost of other borrowed funds increased 105 basis points. The 
benefit to net interest margin from earning assets funded by non-interest bearing liabilities was 49 basis points in the fourth 
quarter of 2018, up from 27 basis points in the fourth quarter of 2017.

Average earning assets for the fourth quarter of 2018 increased $4.0 billion over the fourth quarter of 2017. Average loans, net 
of allowance for loan losses, increased $4.4 billion, including acquired loans. The legacy BOKF loan portfolio grew $1.3 
billion. Commercial and commercial real estate loan balances were the primary drivers. 

Average deposits increased $2.9 billion over the fourth quarter of 2017, including $3.4 billion related to Cobiz. Excluding 
acquired deposits, average demand deposit balances decreased $387 million, average interest-bearing transaction accounts 
decreased $48 million and average time deposits decreased $72 million. Average borrowed funds increased $868 million. 

2017 Net Interest Revenue

Tax-equivalent net interest revenue for 2017 was $858.9 million, up from $764.8 million for 2016. Tax-equivalent net interest 
revenue increased $94.1 million over the prior year. Net interest revenue increased $61.2 million due to rates and $32.9 million 
from growth in earning assets. The benefit of an increase in short-term interest rates during 2017 on the loan portfolio and 
interest-bearing cash and cash equivalents yields was offset by higher borrowing costs. 

Net interest margin was 2.92% for 2017 compared to 2.66% for 2016. The tax-equivalent yield on average earning assets 
increased 41 basis points over 2016. Loan yields increased 50 basis points primarily due an increase in short-term interest rates. 
The yield on interest-bearing cash and cash equivalents increased 57 basis points. The available for sale securities portfolio 
yield increased 10 basis points. The cost of interest-bearing liabilities increased 25 basis points. The cost of interest-bearing 
deposits increased 9 basis points due to a lack of market pricing pressure. The cost of other borrowed funds increased 55 basis 
points, primarily due to increases in federal funds rates by the Federal Reserve. The cost of subordinated debentures increased 
275 basis points due to the full year impact of higher fixed rate debt issued in the second quarter of 2016. The benefit to net 
interest margin from earning assets funded by non-interest bearing liabilities was 23 basis points for 2017, compared to 13 basis 
points for 2016.

Average earning assets increased $646 million or 2% during 2017. Average loans, net of allowance for loan losses, increased 
$812 million. Growth in average commercial, residential and personal loans was partially offset by a decrease in average 
commercial real estate loan balances. The average balance of available for sale securities, which consists largely of residential 
and commercial mortgage-backed securities guaranteed by U.S. government agencies, decreased $414 million. We reduced the 
size of our bond portfolio through normal monthly runoff to better position the balance sheet for an environment of rising 
longer-term rates. Growth in average assets was funded by growth in demand and interest-bearing deposits, partially offset by 
decreased repurchase agreements and borrowings from the Federal Home Loan Banks. Average demand deposit account 
balances grew by $839 million and average interest-bearing transaction deposits increased $475 million. Average borrowed 
funds balances decreased $275 million compared to 2016. Funds purchased and repurchase agreements decreased $176 million 
compared to 2016. 

26

Table 2 – Volume/Rate Analysis 
(In thousands)

Year Ended

Year Ended

December 31, 2018 / 2017

December 31, 2017 / 2016

Change Due To1

Change Due To1

Change

Volume

Yield /
Rate

Change

Volume

Yield /
Rate

Tax-equivalent interest revenue:

Interest-bearing cash and cash equivalents

$

205

$

(11,155) $

11,360

$

11,402

$

(252) $

11,654

Trading securities

Investment securities

Available for sale securities

Fair value option securities

Restricted equity securities

Residential mortgage loans held for sale

Loans

Total tax-equivalent interest revenue

Interest expense:

Transaction deposits

Savings deposits

Time deposits

Funds purchased and repurchase agreements

Other borrowings

Subordinated debentures

Total interest expense

Tax-equivalent net interest revenue

Change in tax-equivalent adjustment

40,311

(2,944)

19,404

(1,550)

3,065

(583)

189,518

247,426

37,232

80

4,402

8,351

60,856

1,588

112,509

134,917

(8,249)

37,008

(2,504)

581

(3,541)

1,880

(1,645)

68,882

89,506

1,748

35

(769)

2,369

5,023

1,665

10,071

79,435

3,303

(440)

18,823

1,991

1,185

1,062

120,636

157,920

35,484

45

5,171

5,982

55,833

(77)

102,438

55,482

8,424

(1,043)

1,443

10,032

1,252

(3,952)

115,678

143,236

14,721

(27)

(1,385)

422

33,270

2,160

49,161

94,075

(398)

8,122

(1,763)

(7,895)

5,886

(257)

(4,389)

29,407

28,859

851

27

(728)

(213)

(1,001)

(2,892)

(3,956)

32,815

302

720

9,338

4,146

1,509

437

86,271

114,377

13,870

(54)

(657)

635

34,271

5,052

53,117

61,260

Net interest revenue
1 Changes attributable to both volume and yield/rate are allocated to both volume and yield/rate on an equal basis.

143,166

94,473

$

$

27

Table 2 – Volume/Rate Analysis (continued)
(In thousands)

Tax-equivalent interest revenue:

Interest-bearing cash and cash equivalents

Trading securities

Investment securities

Available for sale securities

Fair value option securities

Restricted equity securities

Residential mortgage loans held for sale

Loans

Total tax-equivalent interest revenue

Interest expense:

Transaction deposits

Savings deposits

Time deposits

Funds purchased and repurchase agreements

Other borrowings

Subordinated debentures

Total interest expense

Tax-equivalent net interest revenue

Change in tax-equivalent adjustment

Three Months Ended

December 31, 2018 / 2017

Change Due To1

Change

Volume

Yield /
Rate

$

(3,141) $

(6,234) $

15,007

(719)

9,462

(3,192)

842

(594)

91,097

108,762

14,429

61

2,013

3,795

18,978

1,727

41,003

67,759

(1,064)

12,843

(760)

2,391

(4,103)

438

(751)

52,006

55,830

2,310

12

29

1,486

748

1,816

6,401

49,429

3,093

2,164

41

7,071

911

404

157

39,091

52,932

12,119

49

1,984

2,309

18,230

(89)

34,602

18,330

Net interest revenue
1 Changes attributable to both volume and yield/rate are allocated to both volume and yield/rate on an equal basis.

68,823

$

28

Other Operating Revenue

Other operating revenue was $616.8 million for 2018, a decrease of $39.5 million or 6% compared 2017. The change in the fair 
value of mortgage servicing rights, net of economic hedges, decreased other operating revenue by $20.4 million in 2018 and 
$1.9 million in 2017. This increase is primarily as a result of mortgage rate volatility. 

A $15.4 million fee earned through the sale of client assets was recognized as fiduciary and asset management revenue in 2018. 
This fee is excluded from the fluctuation discussion below.

Table 3 – Other Operating Revenue 
(In thousands)

Brokerage and trading revenue
Transaction card revenue1
Fiduciary and asset management revenue

Deposit service charges and fees

Mortgage banking revenue

Other revenue

Total fees and commissions revenue

Other gains (losses), net

Gain (loss) on derivatives, net

Gain (loss) on fair value option securities, net

Change in fair value of mortgage servicing rights

Gain (loss) on available for sale securities, net

Total other-than-temporary impairment

Portion of loss recognized in (reclassified from) other

comprehensive income

Net impairment losses recognized in earnings

Year Ended December 31,

2018

2017

2016

2015

2014

$

108,323

$

131,601

$

138,377

$

129,556

$

134,437

84,025

184,703

112,153

97,787

56,651

643,642

(2,731)

(422)

(25,572)

4,668

(2,801)

—

—

—

81,143

162,889

112,079

104,719

49,959

642,390

11,213

779

(2,733)

172

4,428

—

—

—

78,347

135,387

111,589

133,914

50,112

647,726

4,947

(15,685)

(10,555)

(2,193)

11,675

—

—

—

73,650

126,034

109,592

126,002

50,126

614,960

5,459

430

(3,684)

(4,853)

12,058

(2,443)

624

(1,819)

71,671

115,529

109,783

109,093

47,499

588,012

2,991

2,776

10,189

(16,445)

1,539

(373)

—

(373)

Total other operating revenue

$

616,784

$

656,249

$

635,915

$

622,551

$

588,689

Non-GAAP Reconciliation:1
Transaction card revenue on income statement

Netting adjustment

84,025

119,988

116,452

109,579

—

(38,845)

(38,105)

(35,929)

104,940

(33,269)

Transaction card revenue after netting adjustment
1   Non-GAAP measure to net interchange charges from prior years between transaction card revenue and data processing and communications expense as a 

84,025

78,347

81,143

73,650

71,671

result of the recent revenue recognition standard. This measure has no effect on net income or earnings per share. 

Fees and commissions revenue

Diversified sources of fees and commissions revenue are a significant part of our business strategy and represented 40% of total 
revenue for 2018, excluding provision for credit losses and gains and losses on asset sales, securities and derivatives and the 
change in the fair value of mortgage servicing rights. We believe that a variety of fee revenue sources provides an offset to 
changes in interest rates, values in the equity markets, commodity prices and consumer spending, all of which can be 
volatile. As an example of this strength, many of the economic factors such as rising interest rates resulting in growth in net 
interest revenue or fiduciary and asset management revenue, may also decrease mortgage banking production volumes. We 
expect growth in other operating revenue to come through offering new products and services and by further development of 
our presence in other markets. However, current and future economic conditions, regulatory constraints, increased competition 
and saturation in our existing markets could affect the rate of future increases.

Brokerage and trading revenue, which includes revenues from trading, customer hedging, retail broker and investment banking, 
decreased $23.3 million or 18% compared to the prior year. 

29

Trading revenue includes net realized and unrealized gains and losses primarily related to sales of U.S. government securities, 
residential mortgage-backed securities guaranteed by U.S. government agencies and municipal securities to institutional 
customers and related derivative instruments. Trading revenue also includes gains and losses on instruments we hold as 
economic hedges of changes in the fair value of trading securities. During 2018, we significantly expanded our U.S. 
government residential mortgage-backed securities trading activities. Average trading securities increased $1.0 billion over the 
previous year. Net interest revenue earned on our trading portfolio grew $37.0 million. However, trading revenue decreased 
$15.5 million to $28.1 million in 2018 primarily due to an $18.3 million increase in hedging costs.

Customer hedging revenue is based primarily on realized and unrealized changes in the fair value of derivative contracts held 
for customer risk management programs. As more fully discussed under Customer Derivative Programs in Note 3 of the 
Consolidated Financial Statements, we offer commodity, interest rate, foreign exchange and equity derivatives to our 
customers. Derivative contracts executed with customers are offset with contracts between selected counterparties and 
exchanges to minimize market risk from changes in commodity prices, interest rates or foreign exchange rates. Customer 
hedging revenue totaled $38.8 million for 2018, a decrease of $5.3 million or 12% compared to 2017. The volume of derivative 
contracts sold to our mortgage banking customers used to hedge their pipelines of mortgage loan originations decreased as 
average mortgage rates rose during 2018. 

Revenue earned from retail brokerage transactions totaled $22.2 million for 2018, a decrease of $766 thousand or 3% compared 
to the prior year. Retail brokerage revenue is primarily based on fees and commissions earned on sales of fixed income 
securities, annuities, mutual funds and other financial instruments to retail customers. Revenue is primarily based on the 
volume of customer transactions and applicable commission rate for each type of product. We expect retail brokerage revenue 
to continue to decline as more relationships are transitioned to managed accounts, which are included in fiduciary and asset 
management revenue.

Investment banking, which includes fees earned upon completion of underwriting, financial advisory services and loan 
syndication fees, totaled $19.3 million for 2018, a decrease of $1.7 million or 8% compared to 2017, related to the timing and 
volume of completed transactions. 

Transaction card revenue depends largely on the volume and amount of transactions processed, the number of TransFund 
automated teller machine (“ATM”) locations and the number of merchants served. Transaction card revenue totaled $84.0 
million for 2018, a $2.9 million or 4% increase over 2017. Revenues from the processing of transactions on behalf of the 
members of our TransFund electronic funds transfer ("EFT") network totaled $76.2 million, up $2.7 million or 4% over 
2017. The number of TransFund ATM locations totaled 2,426 at December 31, 2018 compared to 2,223 at December 31, 2017. 
Merchant services fees paid by customers for account management and electronic processing of card transactions totaled $7.8 
million, relatively consistent with the prior year. 

Fiduciary and asset management revenue is earned through managing or holding of assets for customers and executing 
transactions or providing related services. Approximately 80% of fiduciary and asset management revenue is primarily based 
on the fair value of assets. Rates applied to those asset values vary based on the nature of the relationship. Fiduciary and 
managed asset relationships generally have a higher fee rate than non-fiduciary and/or managed relationships.

Fiduciary and asset management revenue grew $6.4 million or 4% over 2017 primarily due to growth in managed fiduciary 
assets. 

30

A distribution of assets under management or administration and related fiduciary and asset management revenue follows:

Table 4 -- Assets Under Management or Administration 

Managed fiduciary assets:

Personal

Institutional

Total managed fiduciary assets

Non-managed assets:

Fiduciary

Non-fiduciary

Safekeeping and brokerage assets under

administration

Total non-managed assets

Year Ended December 31,

Balance

2018
Revenue1

Margin2

Balance

Revenue1 Margin2

2017

$ 8,115,503

$

92,633

1.14% $ 7,801,968

$

85,328

13,119,497

22,488

21,235,000

115,121

0.17%

0.54%

13,192,969

21,630

20,994,937

106,958

23,606,339

15,964,854

15,473,584

55,044,777

67,460

2,122

—

69,582

0.22% 3
0.01%

27,766,540

16,969,222

53,511

2,420

—%

16,097,098

—

0.10%

60,832,860

55,931

1.09%

0.16%

0.51%

0.19%

0.01%

—%

0.09%

Total assets under management or administration
1  Fiduciary and asset management revenue includes asset-based and other fees associated with the assets.
2  Revenue divided by period-end balance.
3   Excludes $15.4 million fee earned through client asset management.

$ 76,279,777

$ 184,703

0.22% 3 $ 81,827,797

$ 162,889

0.20%

A summary of changes in assets under management or administration for the year ended December 31, 2018 and 2017 follows:

Table 5 -- Changes in Assets Under Management or Administration 

Beginning balance

Net inflows (outflows)

Change in assets from acquisitions

Net change in fair value

Ending balance

Year Ended
December 31,

2018

2017

$

81,827,797

$

75,407,863

(6,812,199)

(406,469)

998,705

265,474

—

6,826,403

$

76,279,777

$

81,827,797

The Tax Cuts and Jobs Act eliminated the ability for bond issuers to use tax-exempt bonds to advance refund their outstanding 
debt; thus putting downward pressure on our Corporate Trust asset balance through most of the year. This, combined with 
larger than expected departures in our retirement plan space, led to higher asset outflows in 2018.

Mortgage banking revenue totaled $97.8 million for 2018, a $6.9 million or 7% decrease compared to 2017. Production volume 
is down $666 million as primary interest rates increased 56 basis points compared to 2017. While increased market competition 
has negatively impacted our gain on sale margins, this was more than offset by improved hedging performance and better 
pricing discipline. Mortgage servicing revenue was $66.1 million, consistent with the prior year. The outstanding principal 
balance of mortgage loans serviced for others totaled $21.7 billion at December 31, 2018, a $388 million decrease compared to 
December 31, 2017.

31

Table 6 – Mortgage Banking Revenue 
(In thousands)

Mortgage production revenue

$

31,690

$

38,498

$

69,628

$

69,587

$

61,061

2018

2017

2016

2015

2014

Year Ended December 31,

Mortgage loans funded for sale

$ 2,587,297

$ 3,286,873

$ 6,117,417

$ 6,372,956

$ 4,484,394

Add: Current year end outstanding commitments

Less: Prior year end outstanding commitments

160,848

222,919

222,919

318,359

318,359

601,147

601,147

627,505

627,505

258,873

Total mortgage production volume

2,525,226

3,191,433

5,834,629

6,346,598

4,853,026

Gain on sale margin

1.25%

1.21%

1.19%

1.10%

1.26%

Mortgage loan refinances to mortgage loans funded

for sale

Primary mortgage interest rates:

28%

40%

51%

42%

30%

Average

Period end

4.54%

4.55%

3.99%

3.99%

3.65%

4.32%

3.85%

3.96%

4.17%

3.83%

Mortgage servicing revenue

$

66,097

$

66,221

$

64,286

$

56,415

$

48,032

Average outstanding principal balance of mortgage

loans serviced for others

21,891,749

22,055,002

20,837,897

17,920,557

14,940,915

Average mortgage servicing fee rates

0.30%

0.30%

0.31%

0.31%

0.32%

Primary rates disclosed in Table 6 above represent rates generally available to borrowers on 30 year conforming mortgage 
loans. 

Net gains on securities, derivatives and other assets

As discussed in the Market Risk section following, the fair value of our mortgage servicing rights ("MSRs") changes in 
response to changes in primary mortgage loan rates and other assumptions. We attempt to mitigate the earnings volatility 
caused by changes in the fair value of MSRs by designating certain financial instruments as an economic hedge. Changes in the 
fair value of these instruments are generally expected to partially offset changes in the fair value of MSRs. 

The net economic cost of the changes in fair value of mortgage servicing rights and related economic hedges was $15.6 million 
in 2018, including a $4.7 million increase in the fair value of mortgage servicing rights, offset by a $25.0 million decrease in 
the fair value of securities and derivative contracts held as an economic hedge and $4.8 million of related net interest revenue. 
This increase is due to the combination of unhedgeable factors and significant mortgage rate volatility during the year, 
particularly in the fourth quarter. 

The net economic cost of changes in the fair value of mortgage servicing rights and related economic hedges was $6.6 million 
for 2017. The fair value of mortgage servicing rights increased $172 thousand. The fair value of securities and interest rate 
derivative contracts held as an economic hedge decreased $2.1 million. Net interest earned on securities held as an economic 
hedge was $8.4 million. 

32

Table 7 – Gain (Loss) on Mortgage Servicing Rights, Net of Economic Hedge 
(In thousands)

Year Ended December 31,

2018

2017

2016

2015

2014

Gain (loss) on mortgage hedge derivative contracts, net

$

551

$

681

$ (15,696) $

634

$

2,776

Gain (loss) on fair value option securities, net

Gain (loss) on economic hedge of mortgage servicing rights

Gain (loss) on change in fair value of mortgage servicing rights

Gain (loss) on changes in fair value of mortgage servicing rights, net of

economic hedges included in other operating revenue

Net interest revenue on fair value option securities1
Total economic benefit (cost) of changes in the fair value of mortgage

servicing rights, net of economic hedges

(25,572)

(25,021)

4,668

(2,733)

(2,052)

172

(10,555)

(26,251)

(2,193)

(20,353)

(1,880)

(28,444)

4,798

8,435

4,356

(3,684)

(3,050)

(4,853)

(7,903)

8,001

10,003

12,779

(16,445)

(3,666)

3,253

$ (15,555) $

6,555

$ (24,088) $

98

$

(413)

1  Actual interest earned on fair value option securities less internal transfer-priced cost of funds.

Fourth Quarter 2018 Other Operating Revenue

Other operating revenue was $136.5 million for the fourth quarter of 2018, a decrease of $20.9 million compared to the fourth 
quarter of 2017. CoBiz added $5.8 million to other operating revenue in the fourth quarter of 2018. Excluding Cobiz, other 
operating revenue decreased $29.4 million. The fourth quarter of 2018 included a $12.4 million decrease in the fair value of 
mortgage servicing rights, net of economic hedges, while the fourth quarter of 2017 included a $1.4 million decrease. Other 
gains and losses, net, decreased $9.6 million primarily due to changes in the fair value of assets related to the deferred 
compensation plan and equity securities not held for trading purposes. 

Brokerage and trading revenue was $28.1 million for the fourth quarter of 2018, a decrease of $8.4 million, excluding CoBiz. 
Trading revenue decreased $4.1 million largely due to increased cost of hedging a larger trading portfolio. Net interest revenue 
on the trading portfolio increased $12.0 million over the same period of 2017.  Investment banking revenue decreased $3.4 
million primarily related to the timing and volume of completed transactions.

Mortgage banking revenue was $21.9 million for the fourth quarter of 2018, a decrease of $2.5 million compared to the fourth 
quarter of 2017 due primarily to a decrease in mortgage loan production volume as a result of higher interest rates and 
increased market competition. Mortgage loan production volumes were $460 million for the fourth quarter of 2018, compared 
to $729 million in the fourth quarter of 2017. 

2017 Other Operating Revenue

Other operating revenue totaled $656.2 million for 2017, up $20.3 million or 3% over 2016. The change in the fair value of 
mortgage servicing rights, net of economic hedges, decreased operating revenue in 2017 by $1.9 million and decreased 
operating revenue by $28.4 million in 2016. 

Transaction card revenue grew by $2.8 million over 2016 primarily due to growth in transaction volumes. Fiduciary and asset 
management fees increased $27.5 million primarily due to growth in assets under management, improved pricing discipline and 
decreased fee waivers. 

Mortgage banking revenue decreased by $29.2 million compared 2016 mainly due to a decrease in production volume. This 
was largely related to the Company's strategic decision to exit the correspondent lending channel during 2016.

Brokerage and trading revenue for 2017 decreased $6.8 million compared to 2016. Excluding a $5.0 million decrease in the 
value of trading securities due to the unexpected increase in interest rates in 2016, brokerage and trading revenue decreased 
$11.8 million or 9%. The revenue decrease generally resulted from customer reaction to rising interest rates along with changes 
in regulations.

Other gains, net totaled $11.2 million for 2017 mainly due to the sale of certain merchant banking investments during the year.

33

Other Operating Expense

Other operating expense for 2018 totaled $1.0 billion, a $41.5 million or 4% increase over the prior year. CoBiz added $16.6 
million in closing and integration costs during 2018, primarily affecting professional fees and services and personnel expenses. 
Operations related to CoBiz added $29.7 million to other operating expense. Excluding those costs, operating expense 
decreased $4.8 million, largely consistent with 2017.  The fluctuation discussion below excludes closing and integration costs.

Table 8 – Other Operating Expense 
(In thousands)

Regular compensation

Incentive compensation:

Cash-based compensation

Share-based compensation

Deferred compensation

Total incentive compensation

Employee benefits

Total personnel expense

Business promotion

Charitable contributions to BOKF Foundation

Professional fees and services

Net occupancy and equipment

Insurance
Data processing & communications1
Printing, postage and supplies

Net losses & operating expenses of repossessed assets

Amortization of intangible assets

Mortgage banking costs

Other expense

Total other operating expense

Year Ended December 31,

2018

2017

2016

2015

2014

$

358,280

$

333,226

$

332,740

$

313,403

$

298,420

132,593

127,964

128,077

3,572

(419)

135,746

89,105

583,131

30,523

2,846

59,099

97,981

23,318

114,796

17,169

17,052

9,620

46,298

26,333

23,602

4,091

155,657

84,525

573,408

28,877

2,000

51,067

86,477

19,653

108,125

15,689

9,687

6,779

52,856

32,054

10,464

1,687

140,228

80,151

553,119

26,582

2,000

56,783

80,024

32,489

93,736

15,584

3,359

6,862

61,387

47,560

114,305

12,358

111,748

10,875

361

(13,692)

127,024

74,871

515,298

27,851

796

40,123

76,016

20,375

86,454

13,498

1,446

4,359

38,813

35,233

108,931

69,580

476,931

26,649

4,267

44,440

77,232

18,578

81,956

13,518

6,019

3,965

31,705

28,993

$ 1,028,166

$

986,672

$

979,485

$

860,262

$

814,253

Average number of employees (full-time equivalent)

4,993

4,900

4,872

4,797

4,679

Non-GAAP Reconciliation:1
Data processing and communications expense on income

statement

Netting adjustment

114,796

—

146,970

(38,845)

131,841

(38,105)

122,383

(35,929)

115,225

(33,269)

Data processing and communications expense after netting

adjustment

114,796

108,125

93,736

86,454

81,956

1  Non-GAAP measure to net interchange charges from prior quarters between transaction card revenue and data processing and 

communications expense as a result of the recent revenue recognition standard. This measure has no effect on net income or earnings per 
share.

34

Personnel expense

Personnel expense increased $4.0 million in 2018. An increase in regular compensation expense largely as a result of the 
addition of CoBiz employees in the fourth quarter was partially offset by a decrease in incentive compensation due to changes 
in vesting assumptions.

Regular compensation expense, which consists of salaries and wages, overtime pay and temporary personnel costs, increased 
$24.9 million or 7% over 2017, which included $13.5 million related to the addition of CoBiz employees. The remaining 
increase is primarily due to standard annual merit increases, which were effective for the majority of our staff on March 1. The 
average number of employees increased with the addition of CoBiz employees in the fourth quarter of 2018. 

Incentive compensation decreased $24.6 million or 16% compared to 2017. Cash-based incentive compensation plans, which 
are either intended to provide current rewards to employees who generate long-term business opportunities for the Company 
based on growth in loans, deposits, customer relationships and other measurable metrics or intended to compensate employees 
with commissions on completed transactions, remained consistent compared to 2017. 

Share-based compensation expense represents expense for equity awards based on the grant-date fair value. Non-vested shares 
generally cliff vest in 3 years and are subject to a two year holding period after vesting. The number of shares that will 
ultimately vest is determined by BOKF's change in earnings per share relative to a defined group of peer banks. In addition, 
compensation costs related to certain shares is variable based on changes in the fair value of BOK Financial common shares. 
Share-based compensation expense for equity awards decreased $20.0 million or 85% compared to 2017, primarily due to a 
decrease in the vesting probability of certain performance-based share awards. 

The Company currently offers a deferred compensation plan for certain executive and senior officers. Deferred compensation 
expense decreased $4.5 million compared to the prior year. Deferred compensation expense is largely offset by changes in the 
fair value of assets held in rabbi trusts for the benefit of participants, which is included other gains (losses), net in the 
Consolidated Statements of Earnings.

Non-personnel operating expense

Non-personnel expense increased $20.9 million or 5% over the prior year.

Occupancy and equipment expense increased $11.4 million or 13%, including $3.2 million related to CoBiz operations. The 
remaining increase is largely due to our new Oklahoma City headquarters. Data processing and communications expense 
increased $6.3 million or 6% primarily due to technology project costs.

Insurance expense increased $3.7 million or 19%. The Company received $5.1 million in credits during 2017 related to the 
revision of certain inputs to the assessment calculation filed for years 2013 through 2016. This was partially offset by the 
elimination of a large bank deposit insurance surcharge assessed by the FDIC in the fourth quarter of 2018.

Mortgage banking expense decreased $6.6 million or 12%, primarily due to a decrease in accruals related to default servicing 
and loss mitigation costs on loans serviced for others.

Net losses and operating expenses of repossessed assets increased $7.4 million over the prior year mainly due to write-downs 
on a set of oil and gas properties and a healthcare property in 2018. 

Other expense decreased $5.7 million compared to the prior year primarily due to reductions in litigation expenses and 
expenses related to merchant banking investments that were sold in 2017. 

Fourth Quarter 2018 Operating Expenses

Other operating expense for the fourth quarter of 2018 totaled $284.6 million, an increase of $30.2 million compared to the 
fourth quarter of 2017. The fourth quarter of 2018 included $14.5 million of CoBiz closing and acquisition costs. The 
discussion following excludes these costs.

35

Personnel expense increased $9.7 million over the fourth quarter of 2017. Regular compensation expense increased $17.8 
million compared to the fourth quarter of 2017. The addition of CoBiz employees added $13.5 million. The remaining increase 
is due primarily to annual merit increases. Incentive compensation decreased $13.4 million. Share-based compensation expense 
decreased $8.1 million mainly due to changes in vesting assumptions related to the Company's earnings per share growth 
relative to a defined peer group. Deferred compensation expense decreased $4.8 million, which is largely offset by changes in 
the fair value of assets held in rabbi trusts for the benefit of participants. 

Non-personnel expense increased $5.9 million compared to the fourth quarter of 2017. Occupancy and equipment costs 
increased $5.3 million due primarily to our new Oklahoma City headquarters. Net losses and operating expenses of repossessed 
assets increased $2.2 million mainly due to gains in the fourth quarter of 2017. Intangible amortization increased $3.9 million 
primarily related to fourth quarter 2018 amortization of the CoBiz identifiable intangible assets. Professional fees and services 
decreased $3.0 million largely as a result of one-time technology assessments and a large project that was implemented in the 
fourth quarter of 2017. Mortgage banking costs decreased $2.8 million primarily due to a decrease in accruals related to default 
servicing and loss mitigation costs on loans serviced for others. Insurance expense decreased $2.3 million primarily due to the 
elimination of a large bank deposit insurance surcharge assessed by the FDIC. 

2017 Operating Expenses

Other operating expense totaled $986.7 million for 2017, a $7.2 million or 1% increase over 2016.

Personnel expense increased $20.3 million or 4%. Incentive compensation expense increased $15.4 million or 11%, mainly due 
to the the increase in the vesting probability of certain performance-based share awards and increase in the fair value of BOK 
Financial common shares. Employee benefit expense increased $4.4 million primarily due to employee medical costs. 

Non-personnel expense decreased $13.1 million or 3% compared to 2016. Insurance expense decreased $12.8 million due to a 
credit received in 2017 related to the revision of certain inputs to the assessment calculation along with the benefit from 
decreased criticized and classified asset levels. Mortgage banking expense decreased $8.5 million primarily related to actual 
mortgage loan prepayments. Professional fees and services expense decreased $5.7 million due to Mobank integration costs 
incurred in 2016. Other expense decreased $15.5 million due primarily to higher litigation and settlement expenses in 2016.

Data processing and communications expense increased $14.4 million and net occupancy and equipment expense increased  
$6.5 million primarily related to continued upgrades of our information technology infrastructure and cybersecurity. Net losses 
and operation expenses of repossessed assets increased $6.3 million mainly due to a write-down of a set of oil and gas 
properties.

Income Taxes

Income tax expense was $119.1 million or 21.1% of net income before taxes for 2018, $182.6 million or 35.2% of net income 
before taxes for 2017 and $106.4 million or 31.4% of net income before taxes for 2016. Tax Reform enacted in 2017 added 
$11.7 million of expense in 2017 largely due to the revaluation of net deferred tax assets. Excluding the effect of adjustments 
for tax reform, the 2017 income tax expense would have been 33.0% of net income before taxes. 

In 2018, we completed our accounting for uncertainties that resulted from the Tax Reform Act. Resolution of these 
uncertainties and revaluation of deferred taxes decreased 2018 tax expense by $1.7 million. Excluding these adjustments, the 
2018 effective tax rate would have been 21.4%.  

Net deferred tax assets totaled $35 million at December 31, 2018 compared to net deferred tax assets of $15 million at 
December 31, 2017. We have evaluated the recoverability of our deferred tax assets based on the generation of future taxable 
income during the periods in which those temporary differences become deductible and determined that no valuation allowance 
was required in 2018 and 2017.

Unrecognized tax benefits totaled $19 million at December 31, 2018 compared to $18 million at December 31, 2017. BOK 
Financial operates in numerous jurisdictions, which requires judgment regarding the allocation of income, expense, and 
earnings under various laws and regulations of each of these taxing jurisdictions. Each jurisdiction may audit our tax returns 
and may take different positions with respect to these allocations. 

36

Income tax expense was $20.1 million or 15.7% of net income before taxes for the fourth quarter of 2018 compared to $54.3 
million or 42.9% of net income before taxes for the fourth quarter of 2017. The 2017 tax returns were finalized in the fourth 
quarter resolving uncertainties caused by last year's Tax Cuts and Jobs Act. Resolution of these uncertainties and other routine 
adjustments reduced tax expense for the quarter by $8.6 million.

Table 9 – Selected Quarterly Financial Data (Unaudited) 
(In thousands, except per share data) 

Interest revenue

Interest expense

Net interest revenue

Provision for credit losses

Net interest revenue after provision for credit losses

Fees and commissions revenue

Gain (loss) on financial instruments and other assets, net

Change in fair value of mortgage servicing rights

Other operating revenue

Personnel expense

Other non-personnel expense

Total other operating expense

Net income before taxes

Federal and state income taxes

Net income

Net income (loss) attributable to non-controlling interests

2018

First

Second

Third

Fourth

$

265,407

$

294,180

$

303,247

$

365,592

45,671

219,736

(5,000)

224,736

159,913

(25,130)

21,206

155,989

139,947

104,483

244,430

136,295

30,948

105,347

(215)

55,618

238,562

—

238,562

62,364

240,883

4,000

236,883

79,906

285,686

9,000

276,686

157,331

166,265

160,133

(2,655)

1,723

(4,296)

5,972

156,399

167,941

138,947

107,529

246,476

148,485

33,330

115,155

783

143,531

109,086

252,617

152,207

34,662

117,545

289

555

(24,233)

136,455

160,706

123,937

284,643

128,498

20,121

108,377

(79)

Net income attributable to shareholders of BOK Financial Corp. shareholders $

105,562

$

114,372

$

117,256

$

108,456

Earnings per share:

Basic

Diluted

Average shares:

Basic

Diluted

$

$

1.61

1.61

$

$

1.75

1.75

$

$

1.79

1.79

$

$

1.50

1.50

64,847,334

64,901,975

64,901,095

71,808,029

64,888,033

64,937,226

64,934,351

71,833,334

37

Net income attributable to shareholders of BOK Financial Corp. shareholders $

88,356

Table 9 – Selected Quarterly Financial Data (Unaudited) (continued)
(In thousands, except per share data)

Interest revenue

Interest expense

Net interest revenue

Provision for credit losses

Net interest revenue after provision for credit losses

Fees and commissions revenue1
Gain (loss) on financial instruments and other assets, net

Change in fair value of mortgage servicing rights

Other operating revenue

Personnel expense
Other non-personnel expense1
Total other operating expense

Net income before taxes

Federal and state income taxes

Net income

Net income (loss) attributable to non-controlling interests

Earnings per share:

Basic

Diluted

Average shares:

Basic

2017

First

Second

Third

Fourth

$

226,390

$

235,181

$

255,413

$

255,767

25,208

201,182

—

29,977

205,204

—

36,961

218,452

—

201,182

205,204

218,452

38,904

216,863

(7,000)

223,863

154,712

166,617

163,163

157,900

4,525

1,856

12,359

(6,943)

3,271

(639)

(6,470)

5,898

161,093

172,033

165,795

157,328

136,425

99,083

235,508

126,767

38,103

88,664

308

$

$

$

1.35

1.35

143,744

96,922

240,666

136,571

47,705

147,910

108,109

256,019

128,228

42,438

88,866

$

85,790

$

719

88,147

141

85,649

145,329

109,150

254,479

126,712

54,347

72,365

(127)

72,492

1.35

1.35

$

$

1.31

1.31

$

$

1.11

1.11

$

$

$

$

64,715,964

64,729,752

64,742,822

64,793,005

Diluted

64,805,172
1   Non-GAAP measure to net interchange charges from prior years between transaction card revenue and data processing and 

64,793,134

64,783,737

64,843,179

communications expense as a result of the recent revenue recognition standard. This measure has no effect on net income or earnings per 
share. 

Lines of Business

We operate three principal lines of business: Commercial Banking, Consumer Banking and Wealth Management. Commercial 
Banking includes lending, treasury and cash management services and customer risk management products for small 
businesses, middle market and larger commercial customers. Commercial Banking also includes the TransFund EFT 
network. Consumer Banking includes retail lending and deposit services, lending and deposit services to small businesses 
served through our consumer branch network and all mortgage banking activities. Wealth Management provides fiduciary 
services, private bank services and investment advisory services in all markets. Wealth Management also underwrites state and 
municipal securities and engages in brokerage and trading activities.

38

In addition to our lines of business, we have a Funds Management unit. The primary purpose of this unit is to manage our 
overall liquidity needs and interest rate risk. Each line of business borrows funds from and provides funds to the Funds 
Management unit as needed to support their operations. Operating results for Funds Management and other include the effect of 
interest rate risk positions and risk management activities, securities gains and losses including impairment charges, the 
provision for credit losses in excess of net loans charged off, tax planning strategies and certain executive compensation costs 
that are not attributed to the lines of business. The Funds Management unit also initially recognizes accruals for loss 
contingencies when losses become probable. Actual losses are recognized by the lines of business if the accruals are settled. 

We allocate resources and evaluate the performance of our lines of business using the net direct contribution which includes the 
allocation of funds, actual net credit losses and capital costs. In addition, we measure the performance of our business lines 
after allocations of certain direct expenses and taxes based on statutory rates. 

The cost of funds borrowed from the Funds Management unit by the operating lines of business is transfer priced at rates that 
approximate market rates for funds with similar interest rate and liquidity risk characteristics. Market rates are generally based 
on the applicable LIBOR or interest rate swap rates, adjusted for prepayment risk. This method of transfer-pricing funds that 
support assets of the operating lines of business tends to insulate them from interest rate risk. 

The value of funds provided by the operating lines of business to the Funds Management unit is also based on rates which 
approximate wholesale market rates for funds with similar duration and re-pricing characteristics. Market rates are generally 
based on LIBOR or interest rate swap rates. The funds credit formula applied to deposit products with indeterminate maturities 
is established based on their re-pricing characteristics reflected in a combination of the short-term LIBOR rate and a moving 
average of an intermediate term swap rate, with an appropriate spread applied to both. Shorter duration products are weighted 
towards the short term LIBOR rate and longer duration products are weighted towards the intermediate swap rates. The 
expected duration ranges from 30 days for certain rate-sensitive deposits to five years.

Economic capital is assigned to the business units by a capital allocation model that reflects management’s assessment of 
risk. This model assigns capital based upon credit, operating, interest rate and market risk inherent in our business lines and 
recognizes the diversification benefits among the units. The level of assigned economic capital is a combination of the risk 
taken by each business line, based on its actual exposures and calibrated to its own loss history where possible. Average 
invested capital includes economic capital and amounts we have invested in the lines of business.

As shown in Table 10 following, net income attributable to our lines of business increased $102.3 million or 29% over the prior 
year. Net interest revenue grew by $89.5 million over the prior year. Other operating revenue decreased $57.5 million and other 
operating expenses decreased $44.5 million. Net charge-offs were up $17.2 million over the prior year. 

The operations of CoBiz, acquired on October 1, 2018, were not yet allocated to the operating segments at December 31, 2018. 
Accordingly, the operations, assets and liabilities of CoBiz were included in Funds Management and other for 2018.

Table 10 – Net Income by Line of Business 
(In thousands)

Commercial Banking

Consumer Banking

Wealth Management

Subtotal

Funds Management and other

Total

Year Ended December 31,

2018

2017

2016

$

336,376

$

270,504

$

204,140

26,581

86,544

449,501

(3,855)

16,886

59,849

347,239

(12,595)

(5,323)

31,681

230,498

2,170

$

445,646

$

334,644

$

232,668

39

Commercial Banking

Commercial Banking contributed $336.4 million to consolidated net income in 2018, up $65.9 million or 24% over the prior 
year, primarily due to the positive impact of the Tax Cuts and Jobs Act. Income before taxes was unchanged from the previous 
year. Growth in net interest revenue from improved loan yields and growth in average balances of loans attributed to 
Commercial Banking was offset by increased credit costs and higher corporate expense allocations. 

Table 11 – Commercial Banking 
(Dollars in thousands)

Net interest revenue from external sources

Net interest expense from internal sources

Total net interest revenue

Net loans charged off

Net interest revenue after net loans charged off

Fees and commissions revenue1
Other gains, net

Other operating revenue

Personnel expense
Non-personnel expense1
Other operating expense

Net direct contribution

Gain on financial instruments, net

Gain (loss) on repossessed assets, net

Corporate expense allocations

Income before taxes

Federal and state income taxes

Net income

Average assets

Average loans

Average deposits

Year Ended December 31,

2018

2017

2016

$

726,856

$

618,325

$

501,042

(156,254)

570,602

30,358

540,244

161,949

752

162,701

121,686

71,125

192,811

(89,106)

529,219

13,877

515,342

163,107

7,192

170,299

116,684

73,330

190,014

(62,655)

438,387

32,961

405,426

158,664

1,393

160,057

113,192

65,956

179,148

510,134

495,627

386,335

26

(6,532)

45,818

457,810

121,434

336,376

18,431,411

15,073,484

8,517,137

$

$

52

(2,681)

34,253

458,745

188,241

270,504

17,730,654

14,373,830

8,725,920

$

$

10

669

36,134

350,880

146,740

204,140

17,175,325

13,757,245

8,477,829

$

$

Average invested capital
1   Fees and commission revenue for 2017 and 2016 has been adjusted on a comparable basis with 2018 (Non-GAAP measure) to net  
interchange fees paid to issuing banks on card transactions processed by our TransFund merchant processing services for the twelve 
months ended December 31, 2017 and December 31, 2016 as a result of the recent revenue recognition standard. The discussion following 
is based on this comparable basis.

1,256,211

1,312,438

1,525,077

Net interest revenue increased $41 million or 8% over 2017. Growth in net interest revenue was due to improved yields and a 
$700 million increase in average loan balances as discussed further in the Loans section of Management's Discussion and 
Analysis of Financial Condition. Commercial and commercial real estate loans are primarily attributed to the Commercial 
Banking segment. 

Average deposits attributed to Commercial Banking were $8.5 billion for 2018, a decrease of $209 million or 2% compared to 
2017. See additional discussion concerning changes in Commercial Banking deposits in the Liquidity and Capital section of 
Management's Discussion and Analysis following. 

40

Fees and commissions revenue were relatively unchanged compared to 2017. Transaction card revenue generated by the 
TransFund EFT network increased $2.3 million or 3% largely due to a $2.7 million increase in revenues from the processing of 
transactions on behalf of the members of our TransFund EFT network as well as a 9% increase in TransFund ATM locations. 
Other revenue decreased $3.8 million or 14% as a result of a sale of a merchant banking investment in 2017. 

Operating expense increased $2.8 million or 1% compared to 2017. Personnel costs increased $5.0 million or 4% primarily due 
to an increase in incentive compensation expense. Non-personnel expense decreased $2.2 million or 3% compared to the prior 
year. Decreases in miscellaneous expenses and intangible asset amortization were partially offset by an increase in net 
repossession expense.

Corporate expense allocations increased $11.6 million compared to the prior year primarily due to enhancements of activity 
based costing drivers to better reflect services being utilized by the Commercial Banking line of business.

Consumer Banking

Consumer Banking services are provided through four primary distribution channels: traditional branches, the 24-hour 
ExpressBank call center, Internet banking and mobile banking. Consumer Banking also conducts mortgage banking activities 
through offices located outside of our consumer banking markets and through HomeDirect Mortgage, an online origination 
channel. 

Net income attributed to Consumer Banking totaled $26.6 million for 2018, compared to $16.9 million in the prior year. 
Increased net income was largely due to net interest revenue partially offset by changes in the fair value of our mortgage 
servicing rights, net of economic hedges. 

41

Table 12 – Consumer Banking 
(Dollars in thousands)

Net interest revenue from external sources

Net interest revenue from internal sources

Total net interest revenue

Net loans charged off

Net interest revenue after net loans charged off

Fees and commissions revenue

Other losses, net

Other operating revenue

Personnel expense

Other non-personnel expense

Total other operating expense

Net direct contribution

Loss on financial instruments, net

Change in fair value of mortgage servicing rights

Gain on repossessed assets, net

Corporate expense allocations

Net income before taxes

Federal and state income taxes

Net income

Average assets

Average loans

Average deposits

Average invested capital

Year Ended December 31,

2018

2017

2016

$

83,231

$

84,286

$

73,448

156,679

5,143

151,536

178,174

(51)

178,123

95,427

114,760

210,187

119,472

(25,021)

4,668

247

63,700

35,666

9,085

26,581

8,303,262

1,731,894

6,560,145

285,521

$

$

53,916

138,202

4,786

133,416

185,030

(152)

184,878

99,889

121,790

221,679

96,615

(2,054)

172

223

67,320

27,636

10,750

16,886

8,544,117

1,734,836

6,610,134

298,243

$

$

$

$

77,283

43,156

120,439

4,925

115,514

216,324

(39)

216,285

101,295

146,183

247,478

84,321

(26,252)

(2,193)

979

65,567

(8,712)

(3,389)

(5,323)

8,254,666

1,736,260

6,607,816

351,750

Net interest revenue from Consumer Banking activities grew by $18.5 million or 13% over 2017, primarily related to increased 
yields on deposit balances sold to the Funds Management unit. Average loans were largely unchanged while average deposits 
decreased $50 million. 

Fees and commissions revenue decreased $6.9 million or 4% compared to the prior year. Mortgage banking revenue decreased
$6.8 million or 6% compared the prior year due to rising mortgage rates that have slowed production. Mortgage loan 
production volumes decreased $666 million compared to 2017. 

Operating expense decreased $11.5 million or 5% compared to 2017. Personnel expense was down $4.5 million or 4%, 
primarily due to incentive compensation expense and efforts to right size the business as mortgage production volume is down. 
Non-personnel expense decreased $7.0 million or 6%. Mortgage banking costs were down $6.6 million compared to the prior 
year. 

Corporate expense allocations decreased $3.6 million compared to 2017.

Changes in the fair value of our mortgage servicing rights, net of economic hedges as more fully presented in Table 7, resulted 
in a $20.4 million decrease to pre-tax net income for 2018 compared to a $1.9 million decrease to pre-tax net income in 2017. 

42

Wealth Management

Wealth Management contributed $86.5 million to consolidated net income in 2018, up $26.7 million or 45% over the prior year, 
including a $15.4 million fee on the sale of client assets in 2018. The fluctuation discussion below excludes this fee. The 
remaining increase was primarily due to growth in net interest revenue and favorable impact of the Tax Cut and Jobs Act.

Table 13 – Wealth Management 
(Dollars in thousands)

Net interest revenue from external sources

Net interest revenue from internal sources

Total net interest revenue

Net loans charged off (recovered)

Net interest revenue after net loans charged off (recovered)

Fees and commissions revenue

Other gains (losses), net

Other operating revenue

Personnel expense

Other non-personnel expense

Other operating expense

Net direct contribution

Loss on financial instruments, net

Gain (loss) on repossessed assets, net

Corporate expense allocations

Net income before taxes

Federal and state income tax

Net income

Average assets

Average loans

Average deposits

Average invested capital

Year Ended December 31,

2018

2017

2016

$

81,527

$

45,024

$

31,505

113,032

(288)

113,320

38,344

83,368

(696)

84,064

33,006

29,043

62,049

(801)

62,850

296,465

301,485

282,710

(96)

(51)

512

296,369

301,434

283,222

184,144

64,815

248,959

183,727

62,899

246,626

190,756

60,239

250,995

160,730

138,872

95,077

7

—

44,190

116,547

30,003

—

387

40,562

98,697

38,848

(42)

—

42,378

52,657

20,976

86,544

$

59,849

$

31,681

8,446,006

$

7,072,622

$

7,373,080

1,423,126

5,617,325

252,961

1,314,441

5,516,214

236,815

1,352,694

5,457,566

351,750

$

$

Net interest revenue increased $30 million or 36% over the prior year driven by growth in trading securities and loans along 
with net interest margin expansion. Average trading securities increased $1.0 billion over 2017. Average loan balances were up 
$109 million or 8% over the prior year and average deposit balances increased $101 million or 2%.

Fees and commissions revenue decreased $20.4 million or 7% compared to the prior year. Fiduciary and asset management 
revenue increased $4.8 million compared to 2017. Brokerage and trading revenue decreased $29.7 million compared to the 
prior year due to an increase in the cost of hedging the larger trading portfolio.

Operating expenses increased $2.3 million or 1% compared to the prior year. Personnel expense was relatively consistent with 
2017 and non-personnel expense was well controlled, up $1.9 million or 3% over 2017. 

Corporate expense allocations increased $3.6 million or 9% over the prior year due to enhancements of activity based costing 
drivers to better reflect services being utilized by the Wealth Management line of business.

43

Financial Condition

Securities

We maintain a securities portfolio to enhance profitability, manage interest rate risk, provide liquidity and comply with 
regulatory requirements. Securities are classified as trading, held for investment, or available for sale. 

Table 14 – Securities 
(In thousands)

Trading:

U.S. government agency debentures
U.S. government agency residential

mortgage-backed securities

Municipal and other tax-exempt securities
Asset-backed securities
Other trading securities

Total trading securities

Investment:

Municipal and other tax-exempt securities
U.S. government agency residential

mortgage-backed securities

Other debt securities

Total investment securities

Available for sale:

U.S. Treasury securities
Municipal and other tax-exempt securities
Residential mortgage-backed securities:

2018

December 31,

2017

2016

Amortized
Cost

Fair
Value

Amortized
Cost

Fair
Value

Amortized
Cost

Fair
Value

$

63,511

$

63,765

$

21,188

$

21,196

$

6,238

$

6,234

1,781,618
34,508
41,971
24,346
$ 1,945,954

1,791,584
34,507
42,656
24,411
$ 1,956,923

$

393,190
13,476
23,911
11,359
463,124

$

392,673
13,559
23,885
11,363
462,676

$

309,432
14,377
—
6,843
336,890

$

310,067
14,427
—
6,900
337,628

$

137,296

$

138,562

$

228,186

230,349

$

320,364

$

321,225

12,612
205,279
355,187

496
2,782

$

$

12,770
215,966
367,298

493
2,864

$

$

15,891
217,716
461,793

1,000
27,182

$

$

16,242
233,444
480,035

1,000
27,080

$

$

20,777
205,004
546,145

1,000
41,050

$

$

21,473
222,795
565,493

999
40,993

$

$

U.S. government agencies
Private issue

5,886,323
40,948

5,804,708
59,736

5,355,148
74,311

5,309,152
93,221

5,475,351
101,192

5,460,386
115,535

Total residential mortgage-backed

securities

Commercial mortgage-backed securities

guaranteed by U.S. government
agencies

Other debt securities
Perpetual preferred stock1
Equity securities and mutual funds1
Total available for sale securities

Fair value option securities:

5,927,271

5,864,444

5,429,459

5,402,373

5,576,543

5,575,921

2,986,297
35,545
—
—
$ 8,952,391

2,953,889
35,430
—
—
$ 8,857,120

2,858,885
25,500
12,562
14,487
$ 8,369,075

2,834,961
25,481
15,767
14,916
$ 8,321,578

3,035,750
4,400
15,561
17,424
$ 8,691,728

3,017,933
4,152
18,474
18,357
$ 8,676,829

U.S. government agency residential

mortgage-backed securities

77,046
1  As a result of the recent measurement accounting standard effective January 1, 2018, equity securities are no longer considered part of the 

280,469

755,054

756,931

283,235

78,823

$

$

$

$

$

$

available for sale portfolio and have been moved to other assets.

We maintain an inventory of trading securities in support of sales to a variety of customers, including banks, corporations, 
insurance companies, money managers and others. As discussed in the Market Risk section of this report, trading activities 
involve risk of loss from adverse price movement. We mitigate this risk within board-approved limits through the use of 
derivative contracts, short-sales and other techniques. These limits remain unchanged from levels set before our expanded 
trading activities. 

44

Investment securities consist primarily of intermediate and long-term, fixed rate Oklahoma and Texas municipal bonds and 
taxable Texas school construction bonds. The investment security portfolio is diversified among issuers. 

Available for sale securities, which may be sold prior to maturity, are carried at fair value. Unrealized gains or losses, net of 
deferred taxes, are recorded as accumulated other comprehensive income in shareholders’ equity. The amortized cost of 
available for sale securities totaled $9.0 billion at December 31, 2018, an increase of $583 million compared to December 31, 
2017. Available for sale securities consist primarily of U.S. government agency residential mortgage-backed securities and U.S. 
government agency commercial mortgage-backed securities. Both residential and commercial mortgage-backed securities have 
credit risk from delinquency or default of the underlying loans. We mitigate this risk by primarily investing in securities issued 
by U.S. government agencies. Principal and interest payments on the underlying loans are fully guaranteed. Commercial 
mortgage-backed securities have prepayment penalties similar to commercial loans. At December 31, 2018, residential 
mortgage-backed securities represented 66% of total available for sale securities. 

A primary risk of holding residential mortgage-backed securities comes from extension during periods of rising interest rates or 
prepayment during periods of falling interest rates. We evaluate this risk through extensive modeling of risk both before making 
an investment and throughout the life of the security. Our best estimate of the effective duration of the combined residential 
mortgage-backed securities portfolio held in investment and available for sale securities portfolios at December 31, 2018 is 3.2 
years. Management estimates the combined portfolios' duration extends to 3.8 years assuming an immediate 200 basis point 
upward shock. The estimated duration contracts to 2.6 years assuming a 100 basis point decline in the current low rate 
environment. 

The aggregate gross amount of unrealized losses on available for sale securities totaled $138 million at December 31, 2018, a 
$49 million increase compared to December 31, 2017. On a quarterly basis, we perform an evaluation on debt securities to 
determine if the unrealized losses are temporary as more fully described in Note 2 of the Consolidated Financial 
Statements. No other-than-temporary impairment charges were recognized in earnings in 2018.

Certain residential mortgage-backed securities issued by U.S. government agencies and included in Fair value option securities 
on the Consolidated Balance Sheets, have been segregated and designated as economic hedges of changes in the fair value of 
our mortgage servicing rights. We have elected to carry these securities at fair value with changes in fair value recognized in 
current period income. These securities are held with the intent that gains or losses will offset changes in the fair value of 
mortgage servicing rights and related derivative contracts. 

Bank-Owned Life Insurance

We have approximately $382 million of bank-owned life insurance at December 31, 2018. This investment is expected to 
provide a long-term source of earnings to support existing employee benefit programs. Approximately $295 million is held in 
separate accounts. Our separate account holdings are invested in diversified portfolios of investment-grade fixed income 
securities and cash equivalents, including U.S. Treasury and Agency securities, residential mortgage-backed securities, 
corporate debt, asset-backed and commercial mortgage-backed securities. The portfolios are managed by unaffiliated 
professional managers within parameters established in the portfolio’s investment guidelines. The cash surrender value of 
certain life insurance policies is further supported by a stable value wrap, which protects against changes in the fair value of the 
investments. At December 31, 2018, the fair value of investments held in separate accounts was approximately $294 
million. As the underlying fair value of the investments held in a separate account at December 31, 2018 was less than the 
aggregate book value of the investments, approximately $813 thousand cash surrender value was supported by the stable value 
wrap. The stable value wrap is provided by a domestic financial institution. The remaining cash surrender value of $87 million 
primarily represents the cash surrender value of policies held in general accounts and other amounts due from various insurance 
companies.

45

Loans

The aggregate loan portfolio before allowance for loan losses totaled $21.7 billion at December 31, 2018, an increase of $4.5 
billion over December 31, 2017. Excluding $2.9 billion of loans, net of fair value adjustments, added by the CoBiz acquisition, 
loans grew by $1.6 billion or 9%, primarily due to commercial and commercial real estate loans. CoBiz added $1.8 billion to 
our commercial loan portfolio, primarily in the services and public finance loan classes, and $838 million to our commercial 
real estate portfolio. Substantially all CoBiz loans are attributed to Colorado and Arizona.

Table 15 – Loans 
(In thousands)

Commercial:

Energy

Services

Healthcare

Wholesale/retail

Public finance

Manufacturing

Other commercial and industrial

Total commercial

Commercial real estate:

Multifamily

Office

Retail

Industrial

Residential construction and land development

Other commercial real estate

Total commercial real estate

Residential mortgage:

Permanent mortgage

Permanent mortgages guaranteed by U.S.

government agencies

Home equity

2018

2017

2016

2015

2014

December 31,

$

3,590,333

$

2,930,156

$

2,497,868

$

3,097,328

$

2,860,428

3,252,146

2,733,537

1,621,158

876,336

730,521

832,047

2,522,025

2,243,487

1,471,256

541,775

496,774

528,502

2,632,036

2,120,722

1,576,818

568,214

514,975

480,191

2,480,361

1,867,172

1,418,024

324,922

556,729

507,995

2,033,082

1,397,912

1,435,650

428,302

532,594

407,702

13,636,078

10,733,975

10,390,824

10,252,531

9,095,670

1,288,065

1,072,920

919,082

778,106

148,584

558,056

980,017

831,770

691,532

573,014

117,245

286,409

903,272

798,888

761,888

871,749

135,533

337,716

751,085

637,707

796,499

563,169

160,426

350,147

704,298

415,544

666,889

428,817

143,591

369,011

4,764,813

3,479,987

3,809,046

3,259,033

2,728,150

1,320,165

1,043,435

1,006,820

945,336

969,951

190,866

719,002

197,506

732,745

199,387

743,625

196,937

734,620

205,950

773,611

Total residential mortgage

2,230,033

1,973,686

1,949,832

1,876,893

1,949,512

Personal

Total

Commercial

1,025,806

965,776

839,958

552,697

434,705

$

21,656,730

$ 17,153,424

$

16,989,660

$

15,941,154

$

14,208,037

Commercial loans represent loans for working capital, facilities acquisition or expansion, purchases of equipment and other 
needs of commercial customers primarily located within our geographical footprint. Commercial loans are underwritten 
individually and represent ongoing relationships based on a thorough knowledge of the customer, the customer’s industry and 
market. While commercial loans are generally secured by the customer’s assets including real property, inventory, accounts 
receivable, operating equipment, interests in mineral rights and other property and may also include personal guarantees of the 
owners and related parties, the primary source of repayment of the loans is the on-going cash flow from operations of the 
customer’s business. Inherent lending risks are centrally monitored on a continuous basis from underwriting throughout the life 
of the loan for compliance with commercial lending policies.

46

Commercial loans totaled $13.6 billion or 63% of the loan portfolio at December 31, 2018, growing $1.1 billion or 10% over 
December 31, 2017, excluding the impact of acquired loans. This growth was led by a $640 million or 22% increase in energy 
sector loans. Healthcare sector loans were up $174 million or 8%. Service sector loans increased $126 million or 5% and other 
commercial and industrial loans increased $107 million or 20%. 

Table 16 presents our commercial loan portfolio distributed primarily by collateral location. Loans for which the collateral 
location is less relevant, such as unsecured loans and reserve-based energy loans, are distributed by the borrower’s primary 
operating location.

Table 16 – Commercial Loans by Collateral Location 
(In thousands)

Oklahoma

Texas

New
Mexico

Arkansas Colorado

Arizona

Kansas/
Missouri

Other

Total

$ 803,550

$1,935,449

$ 35,021

$

2,615

$ 368,819

$

6,517

$ 82,914

$ 355,448

$ 3,590,333

637,835

221,520

204,660

98,705

95,539

695,096

167,297

362,984

123,372

615,880

185,817

166,072

36,299

42,908

189

14,281

80,046

30,711

—

5,115

656,504

331,458

179,976

165,320

187,979

405,450

282,613

393,070

3,252,146

217,383

202,688

1,194,086

2,733,537

113,878

113,427

126,634

70,220

55,207

71,362

369,534

214,952

77,631

1,621,158

876,336

730,521

94,259

184,290

3,585

67,413

142,692

54,483

62,265

223,060

832,047

Energy

Services

Healthcare

Wholesale/retail

Public finance

Manufacturing

Other commercial
and industrial

Total commercial

loans

$2,156,068

$4,145,588

$408,671

$ 200,181

$2,032,748

$1,037,772

$ 827,269

$2,827,781

$13,636,078

The majority of our commercial portfolio is located within our geographic footprint. At December 31, 2018, the Other category 
is composed primarily of California totaling $524 million or 4% of the commercial portfolio, Florida totaling $302 million or 
2% of the commercial portfolio, Pennsylvania totaling $153 million or 1% of the commercial portfolio, Ohio totaling $150 
million or 1% of the commercial portfolio and Louisiana totaling $142 million or 1%. All other states individually represent 
less than one percent of the total commercial loan portfolio. 

Supporting the energy industry with loans to producers and other energy-related entities has been a hallmark of the Company 
since its founding and represents a large portion of our commercial loan portfolio. In addition, energy production and related 
industries have a significant impact on the economy in our primary markets. Loans collateralized by oil and gas properties are 
subject to a semi-annual engineering review by our internal staff of petroleum engineers. This review is utilized as the basis for 
developing the expected cash flows supporting the loan amount. The projected cash flows are discounted according to risk 
characteristics of the underlying oil and gas properties. Loans are evaluated to demonstrate with reasonable certainty that crude 
oil, natural gas and natural gas liquids can be recovered from known oil and gas reservoirs under existing economic and 
operating conditions at current pricing levels and with existing conventional equipment and operating methods and costs. As 
part of our evaluation of credit quality, we analyze rigorous stress tests over a range of commodity prices and take proactive 
steps to mitigate risk when appropriate.

Outstanding energy loans totaled $3.6 billion or 17% of total loans at December 31, 2018. Unfunded energy loan commitments 
increased by $335 million during the year to $3.2 billion at December 31, 2018. Approximately $2.9 billion or 82% of energy 
loans were to oil and gas producers, a $454 million increase over December 31, 2017. The majority of this portfolio is first lien, 
senior secured, reserve-based lending, which we believe is the lowest risk form of energy lending. Approximately 57% of the 
committed production loans are secured by properties primarily producing oil and 43% of the committed production loans are 
secured by properties primarily producing natural gas. Loans to borrowers in the midstream sector of the industry totaled $420 
million or 12% of energy loans, an increase of $159 million over the prior year. Loans to borrowers that provide services to the 
energy industry totaled $176 million or 5% of energy loans, an increase of $46 million during 2018. Loans to other energy 
borrowers, including those engaged in wholesale or retail energy sales totaled $62 million or 2% of energy loans, an increase of 
$987 thousand compared to the prior year.

The services sector of the loan portfolio totaled $3.3 billion or 15% of total loans and consists of a large number of loans to a 
variety of businesses, including commercial services, Native American tribal governments, financial services, entertainment 
and recreation and education. Approximately $2.3 billion of the services category is made up of loans with individual balances 
of less than $10 million. Service sector loans are generally secured by the assets of the borrower with repayment coming from 
the cash flows of ongoing operations of the customer’s business. 

47

The healthcare sector of the loan portfolio totaled $2.7 billion or 13% of total loans and consists primarily of loans for the 
development and operation of senior housing and care facilities, including independent living, assisted living and skilled 
nursing. Healthcare also includes loans to hospitals and other medical service providers. 

We participate in shared national credits when appropriate to obtain or maintain business relationships with local customers. 
Shared national credits are defined by banking regulators as credits of more than $100 million and with three or more non-
affiliated banks as participants. At December 31, 2018, the outstanding principal balance of these loans totaled $4.1 billion. 
Approximately 86% of these loans are to borrowers with local market relationships. We serve as the agent lender in 
approximately 17% of our shared national credits, based on dollars committed. We hold shared credits to the same standard of 
analysis and perform the same level of review as internally originated credits. Our lending policies generally avoid loans in 
which we do not have the opportunity to maintain or achieve other business relationships with the customer. In addition to 
management’s quarterly assessment of credit risk, banking regulators annually review a sample of shared national credits for 
proper risk grading.

Commercial Real Estate

Commercial real estate represents loans for the construction of buildings or other improvements to real estate and property held 
by borrowers for investment purposes. The majority of commercial real estate loans are secured by properties within our 
geographic footprint, with the larger concentrations in Texas and Colorado, which represent 26% and 16% of the total 
commercial real estate portfolio at December 31, 2018, respectively. We require collateral values in excess of the loan amounts, 
demonstrated cash flows in excess of expected debt service requirements, equity investment in the project and a portion of the 
project already sold, leased or permanent financing already secured. The expected cash flows from all significant new or 
renewed income producing property commitments are stress tested to reflect the risks in varying interest rates, vacancy rates 
and rental rates. As with commercial loans, inherent lending risks are centrally monitored on a continuous basis from 
underwriting throughout the life of the loan for compliance with applicable lending policies.

Commercial real estate loans totaled $4.8 billion or 22% of the loan portfolio at December 31, 2018. The outstanding balance 
of commercial real estate loans increased $447 million over 2017, excluding the impact of acquired loans. Loans secured by 
multifamily residential properties were up $180 million or 18%. Loans secured by industrial facilities increased $126 million or 
22%. Loans secured by retail facilities and office buildings also grew over the prior year. The commercial real estate loan 
balance as a percentage of our total loan portfolio has ranged from 19% to 22% over the past five years. The commercial real 
estate segment of our loan portfolio distributed by collateral location follows in Table 17.

Table 17 – Commercial Real Estate Loans by Collateral Location 
(In thousands)

Oklahoma

Texas

New
Mexico

Arkansas Colorado Arizona

Kansas/
Missouri

Other

Total

Multifamily

$ 138,803

$ 491,322

$ 30,288

$ 57,008

$ 134,394

$121,218

$ 166,680

$ 148,352

$ 1,288,065

Office

Retail

Industrial

Residential

construction and
land
development

Other commercial

real estate

Total commercial
real estate loans

107,725

278,001

86,370

56,863

81,096

258,957

133,155

168,792

21,048

15,000

5,524

97

153,545

146,038

79,733

91,913

80,349

33,830

55,395

14,560

40,027

284,971

223,636

353,483

1,072,920

919,082

778,106

8,592

17,449

14,974

555

63,818

11,564

12,152

19,480

148,584

47,992

36,574

11,722

1,484

180,151

106,195

26,282

147,656

558,056

$ 441,071

$1,251,095

$ 297,557

$ 79,668

$ 757,679

$445,069

$ 315,096

$1,177,578

$ 4,764,813

The Other category includes California with $291 million or 6% of total commercial real estate loans, Utah with $109 million 
or 2% of total commercial real estate loans, Florida with $98 million or 2% of total commercial real estate loans and Nevada 
with $92 million or 2% of total commercial real estate loans. All other states individually represent less than 2% of the total 
commercial real estate loan population.

While recent changes nationally in consumer purchasing trends from brick-and-mortar stores to online has created concern with 
regards to retail lending, our credit quality remains very good. The portfolio is highly diversified with no material exposure to a 
single borrower or tenant. 

48

Residential Mortgage and Personal

Residential mortgage loans provide funds for our customers to purchase or refinance their primary residence or to borrow 
against the equity in their home. Residential mortgage loans are secured by a first or second-mortgage on the customer’s 
primary residence. Personal loans consist primarily of loans to Wealth Management clients secured by the cash surrender value 
of insurance policies and marketable securities. It also includes direct loans secured by and for the purchase of automobiles, 
recreational and marine equipment as well as unsecured loans. Residential mortgage and personal loans are made in accordance 
with underwriting policies we believe to be conservative and are fully documented. Credit scoring is assessed based on 
significant credit characteristics including credit history, residential and employment stability.

Residential mortgage loans totaled $2.2 billion, a $33 million or 2% increase over December 31, 2017, excluding the impact of 
purchased loans. In general, we sell the majority of our fixed rate loan originations that conform to U.S. government agency 
standards in the secondary market and retain the majority of our non-conforming and adjustable-rate mortgage loans. We have 
no concentration in sub-prime residential mortgage loans. Our mortgage loan portfolio does not include payment option 
adjustable rate mortgage loans or adjustable rate mortgage loans with initial rates that are below market. Collateral for 95% of 
our residential mortgage portfolio is located within our geographic footprint. 

The majority of our permanent mortgage loan portfolio is primarily composed of various non-conforming mortgage programs 
to support customer relationships including jumbo mortgage loans, non-builder construction loans and special loan programs 
for high net worth individuals or certain professionals. Jumbo loans may be fixed or variable rate and are fully amortizing. The 
size of jumbo loans exceed maximums set under government sponsored entity standards, but otherwise generally conform to 
those standards. These loans generally require a minimum FICO score of 720 and a maximum debt-to-income ratio (“DTI”) of 
38%. Loan-to-value ratios (“LTV”) are tiered from 60% to 100%, depending on the market. Special mortgage programs include 
fixed and variable rate fully amortizing loans tailored to the needs of certain healthcare professionals. Variable rate loans are 
fully indexed at origination and may have fixed rates for three to ten years, then adjust annually thereafter.

At December 31, 2018, $191 million of permanent residential mortgage loans are guaranteed by U.S. government agencies. We 
have minimal credit exposure on loans guaranteed by the agencies. This amount includes residential mortgage loans previously 
sold into GNMA mortgage pools that are eligible to be repurchased. We may repurchase these loans when certain defined 
delinquency criteria are met. Because of this repurchase right, the Company is deemed to have regained effective control over 
these loans and must include them in the Consolidated Balance Sheets. Permanent residential mortgage loans guaranteed by 
U.S. government agencies decreased $6.6 million or 3% compared to December 31, 2017.

Home equity loans totaled $719 million at December 31, 2018, a $40 million or 5% decrease compared to December 31, 2017, 
excluding $26 million of loans added by CoBiz. Our home equity portfolio is primarily composed of first-lien, fully amortizing 
home equity loans. Home equity loans generally require a minimum FICO score of 700 and a maximum DTI of 50%. The 
maximum loan amount available for our home equity loan products is generally $400 thousand. Revolving loans have a 10 year 
revolving period followed by 15 year term of amortizing repayments. Interest-only home equity loans have a 5 year revolving 
period followed by a 15 year term of amortizing repayments and may not be extended for any additional revolving time. All 
other home equity loans may be extended at management's discretion for an additional 5 year revolving term subject to an 
update of certain credit information. 

A summary of our home equity loan portfolio at December 31, 2018 by lien position and amortizing status follows in Table 18.

Table 18 – Home Equity Loans 
(In thousands)

First lien

Junior lien

Total home equity

Revolving

Amortizing

Total

$

$

87,866

$

337,234

$

425,100

175,728

118,174

293,902

263,594

$

455,408

$

719,002

49

Personal loans totaled $1.0 billion, growing by $38 million or 4% over the prior year, excluding the impact of acquired loans. 
This growth is primarily due to loans to Wealth Management customers for investment in businesses that will be repaid from 
personal income. 

The distribution of residential mortgage and personal loans at December 31, 2018 is presented in Table 19. Residential 
mortgage loans are distributed by collateral location. Personal loans are generally distributed by borrower location.

Table 19 – Residential Mortgage and Personal Loans by Collateral Location 
(In thousands)

Residential mortgage:
Permanent mortgage

Permanent

mortgages guaranteed
by U.S. government
agencies
Home equity

Total residential
mortgage

Oklahoma

Texas

New
Mexico

Arkansas Colorado Arizona

Kansas/
Missouri

Other

Total

$ 173,991

$448,594

$ 60,396

$ 13,565

$ 353,510

$146,173

$ 67,010

$ 56,926

$ 1,320,165

47,810
364,838

30,524
135,486

33,534
81,985

9,350
6,430

4,924
63,692

1,233
14,478

15,355
49,308

48,136
2,785

190,866
719,002

$ 586,639

$614,604

$ 175,915

$ 29,345

$ 422,126

$161,884

$ 131,673

$107,847

$ 2,230,033

Personal

$ 313,077

$418,214

$ 11,844

$ 12,360

$ 79,475

$ 61,840

$ 62,064

$ 66,932

$ 1,025,806

50

The Company secondarily evaluates loan portfolio performance based on the primary geographical market managing the loan. 
Loans attributed to a geographical market may not represent the location of the borrower or the collateral. All permanent 
mortgage loans serviced by our mortgage banking unit and held for investment by BOKF, NA are centrally managed by the 
Bank of Oklahoma division.

Table 20 – Loans Managed by Primary Geographical Market 
(In thousands)

Oklahoma:

Commercial
Commercial real estate
Residential mortgage
Personal

Total Oklahoma

Texas:

Commercial
Commercial real estate
Residential mortgage
Personal

Total Texas

New Mexico:
Commercial
Commercial real estate
Residential mortgage
Personal

Total New Mexico

Arkansas:

Commercial
Commercial real estate
Residential mortgage
Personal

Total Arkansas

Colorado:

Commercial
Commercial real estate
Residential mortgage
Personal

Total Colorado

Arizona:

Commercial
Commercial real estate
Residential mortgage
Personal

Total Arizona

Kansas/Missouri:
Commercial
Commercial real estate
Residential mortgage
Personal

Total Kansas/Missouri

$

2018

2017

December 31,
2016

2015

2014

$

3,491,117
700,756
1,440,566
375,543
6,007,982

5,438,133
1,341,783
266,805
394,743
7,441,464

340,489
383,670
87,346
10,662
822,167

111,338
141,898
7,537
11,955
272,728

2,275,069
963,575
251,849
72,916
3,563,409

1,320,139
889,903
97,959
68,546
2,376,547

659,793
343,228
77,971
91,441
1,172,433

$

3,238,720
682,037
1,435,432
342,212
5,698,401

4,520,401
1,261,864
233,675
375,084
6,391,024

343,296
341,282
98,018
11,721
794,317

95,644
87,393
6,596
9,992
199,625

1,130,714
174,201
63,350
63,115
1,431,380

687,792
660,094
41,771
57,140
1,446,797

717,408
273,116
94,844
106,512
1,191,880

$

3,370,259
684,381
1,407,197
303,823
5,765,660

4,022,455
1,415,011
233,981
306,748
5,978,195

399,256
284,603
108,058
11,483
803,400

86,577
73,616
7,015
6,524
173,732

1,018,208
265,264
59,631
50,372
1,393,475

686,253
747,409
36,265
52,553
1,522,480

807,816
338,762
97,685
108,455
1,352,718

$

3,782,687
739,829
1,409,114
255,387
6,187,017

3,908,425
1,204,202
219,126
203,496
5,535,249

375,839
313,422
120,507
11,557
821,325

92,359
69,320
8,169
819
170,667

987,076
223,946
53,782
23,384
1,288,188

606,733
507,523
44,047
31,060
1,189,363

499,412
200,791
22,148
26,994
749,345

3,142,689
603,610
1,467,096
206,115
5,419,510

3,549,128
1,027,817
235,948
154,363
4,967,256

383,439
296,358
127,999
10,899
818,695

95,510
88,301
7,261
5,169
196,241

977,961
194,553
57,119
27,918
1,257,551

547,524
355,140
35,872
12,883
951,419

399,419
162,371
18,217
17,358
597,365

Total BOK Financial loans

$

21,656,730

$ 17,153,424

$

16,989,660

$

15,941,154

$

14,208,037

51

Table 21 – Loan Maturity and Interest Rate Sensitivity at December 31, 2018 
(In thousands)

Loan maturity:

Commercial

Commercial real estate

Total

Interest rate sensitivity for selected loans with:

Predetermined interest rates

Floating or adjustable interest rates

Total

Loan Commitments

Remaining Maturities of Selected Loans

Total

Within 1
Year

1-5 Years

After 5
Years

$ 13,636,078

$

1,094,732

$

7,760,989

$

4,780,357

4,764,813

639,755

2,956,080

$ 18,400,891

$

1,734,487

$ 10,717,069

$

3,929,368

14,471,523

$ 18,400,891

$

$

156,147

$

1,186,339

1,578,340

9,530,730

1,734,487

$ 10,717,069

$

5,949,335

$

$

1,168,978

5,949,335

2,586,882

3,362,453

We enter into certain off-balance sheet arrangements in the normal course of business as shown in Table 22. Loan commitments 
may be unconditional obligations to provide financing or conditional obligations that depend on the borrower’s financial 
condition, collateral value or other factors. Standby letters of credit are unconditional commitments to guarantee the 
performance of our customer to a third party. Since some of these commitments are expected to expire before being drawn 
upon, the total commitment amounts do not necessarily represent future cash requirements. None of the outstanding standby 
letters of credit were issued on behalf of customers whose loans are nonperforming at December 31, 2018.

Table 22 – Off-Balance Sheet Credit Commitments 
(In thousands)

Loan commitments

Standby letters of credit

Mortgage loans sold with recourse

December 31,

2018

2017

2016

2015

2014

$ 11,944,525

$

9,958,080

$

9,404,665

$

8,455,037

$

8,328,416

582,196

98,623

647,653

125,127

585,472

139,486

507,988

155,489

447,599

179,822

We have off-balance sheet commitments related to certain residential mortgage loans originated under community development 
loan programs that were sold to a U.S. government agency with full recourse. These mortgage loans were underwritten to 
standards approved by the agencies, including full documentation and originated under programs available only for owner-
occupied properties. We no longer sell residential mortgage loans with recourse other than obligations under standard 
representations and warranties. We are obligated to repurchase these loans for the life of these loans in the event of foreclosure 
for the unpaid principal and interest at the time of foreclosure. Substantially all of these loans are to borrowers in our primary 
markets including $61 million to borrowers in Oklahoma and $11 million to borrowers in Arkansas. At December 31, 2018, 
approximately 2% of these loans were nonperforming and 7% were past due 30 to 89 days. A separate accrual for credit risk of 
$2.9 million is available to absorb losses on these loans.

We also have an off-balance sheet obligation to repurchase residential mortgage loans sold to government sponsored entities 
through our mortgage banking activities due to standard representations and warranties made under contractual agreements and 
to service loans in accordance with investor guidelines. The Company has established accruals for losses related to these 
obligations that are included in Other liabilities in the Consolidated Balance Sheets and in Mortgage banking costs in the 
Consolidated Statements of Earnings.

In 2018, the Company repurchased 7 loans from the agencies for $1.9 million and paid indemnification for 5 loans. Losses on 
both repurchases and indemnifications were insignificant. For the period from 2010 through 2018, approximately 21% of 
repurchase requests have currently resulted in actual repurchases or indemnification by the Company. 

52

A summary of unresolved deficiency requests from U.S. government agencies follows (in thousands, except for number of 
unresolved deficiency requests):

Table 23 -  Summary of Unresolved Deficiency Requests 
(In thousands, except number of unresolved deficiency requests)

Number of unresolved deficiency requests

169

Aggregate outstanding principal balance subject to unresolved deficiency requests

$

5,896

$

Unpaid principal balance subject to indemnification by the Company

6,916

191

9,737

4,519

The accrual for credit losses related to potential loan repurchases under representations and warranties totaled $1.6 million at 
December 31, 2018 and $1.4 million at December 31, 2017. 

December 31,

2018

2017

Customer Derivative Programs

We offer programs that permit our customers to hedge various risks, including fluctuations in energy, cattle and other 
agricultural product prices, interest rates and foreign exchange rates. Each of these programs work essentially the same 
way. Derivative contracts are executed between the customers and the Company. Offsetting contracts are executed between the 
Company and selected counterparties or exchanges to minimize market risk to us from changes in commodity prices, interest 
rates or foreign exchange rates. The counterparty contracts are identical to the customer contracts, except for a fixed pricing 
spread or a fee paid to us as compensation for administrative costs, credit risk and profit.

The customer derivative programs create credit risk for potential amounts due to the Company from our customers and from 
the counterparties. Customer credit risk is monitored through existing credit policies and procedures. The effects of changes in 
commodity prices, interest rates or foreign exchange rates are evaluated across a range of possible options to determine the 
maximum exposure we are willing to have individually to any customer. Customers may also be required to provide cash 
margin or other collateral in conjunction with our credit agreements to further limit our credit risk.

Counterparty credit risk is evaluated through existing policies and procedures. This evaluation considers the total relationship 
between BOK Financial and each of the counterparties. Individual limits are established by management, approved by Credit 
Administration and reviewed by the Asset/Liability Committee. Margin collateral is required if the exposure between the 
Company and any counterparty exceeds established limits. Based on declines in the counterparties’ credit ratings, these limits 
may be reduced and additional margin collateral may be required.

A deterioration of the credit standing of one or more of the customers or counter-parties to these contracts may result in BOK 
Financial recognizing a loss as the fair value of the affected contracts may no longer move in tandem with the offsetting 
contracts. This occurs if the credit standing of the customer or counterparty deteriorated such that either the fair value of 
underlying collateral no longer supports the contract or the customer or counterparty’s ability to provide margin collateral was 
impaired. Credit losses on customer derivatives reduce brokerage and trading revenue in the Consolidated Statements of 
Earnings.

Derivative contracts are carried at fair value. At December 31, 2018, the net fair values of derivative contracts, before 
consideration of cash margin, reported as assets under these programs totaled $427 million compared to $225 million at 
December 31, 2017. Derivative contracts carried as assets include foreign exchange contracts with fair values of $184 million, 
energy contracts with fair values of $145 million, to-be-announced residential mortgage-backed securities with fair values of 
$65 million and interest rate swaps primarily sold to loan customers with fair values of $29 million. Before consideration of 
cash margin paid to counterparties, the aggregate net fair values of derivative contracts held under these programs reported as 
liabilities totaled $413 million.

At December 31, 2018, total derivative assets were reduced by $115 million of cash collateral received from counterparties and 
total derivative liabilities were reduced by $69 million of cash collateral paid to counterparties related to instruments executed 
with the same counterparty under a master netting agreement.

A table showing the notional and fair value of derivative assets and liabilities on both a gross and net basis is presented in Note 
3 to the Consolidated Financial Statements.

53

The fair value of derivative contracts reported as assets under these programs, net of cash margin held by the Company, by 
category of debtor at December 31, 2018 follows in Table 24.

Table 24 – Fair Value of Derivative Contracts 
(In thousands)

Customers

Banks and other financial institutions

Exchanges and clearing organizations

Fair value of customer hedge asset derivative contracts, net

$

140,973

128,526

41,891

$

311,390

The largest exposure to a single counterparty was to an exchange organization for energy swaps which totaled $36 million at 
December 31, 2018. 

Our customer derivative program also introduces liquidity and capital risk. We are required to provide cash margin to certain 
counterparties when the net negative fair value of the contracts exceeds established limits. Also, changes in commodity prices 
affect the amount of regulatory capital we are required to hold as support for the fair value of our derivative assets. These risks 
are modeled as part of the management of these programs. Based on current prices, the fair value of derivative assets would not 
be materially impacted by either a decrease in market prices equivalent to $20.88 per barrel of oil nor an increase in prices 
equivalent to $55.34 per barrel of oil as the Company generally is in a derivative asset position with counterparties fully offset 
by cash margin received from those counterparties. Liquidity requirements of this program are also affected by our credit 
rating. A decrease in credit rating to below investment grade would increase our obligation to post cash margin on existing 
contracts by approximately $10 million. The fair value of our to-be-announced residential mortgage-backed securities and 
interest rate swap derivative contracts is affected by changes in interest rates. Based on our assessment as of December 31, 
2018, changes in interest rates would not materially impact regulatory capital or liquidity needed to support this portion of our 
customer derivative program.

Summary of Loan Loss Experience

We maintain an allowance for loan losses and an accrual for off-balance sheet credit risk. At December 31, 2018, the combined 
allowance for loan losses and accrual for off-balance sheet credit risk totaled $209 million or 0.97% of outstanding loans and 
134.03% of nonaccruing loans, excluding loans guaranteed by U.S. government agencies. Excluding acquired loans measured 
at acquisition date fair value, the combined allowance for loan losses was 1.12% of outstanding loans and 145.66% of 
nonaccruing loans. The allowance for loan losses was $207 million and the accrual for off-balance sheet credit risk was $1.8 
million. At December 31, 2017, the combined allowance for credit losses was $234 million or 1.37% of outstanding loans and 
131% of nonaccruing loans, excluding loans guaranteed by U.S. government agencies. The allowance for loan losses was $231 
million and the accrual for off-balance sheet credit risk was $3.7 million. 

The provision for credit losses is the amount necessary to maintain the allowance for loan losses and an accrual for off-balance 
sheet credit risk at an amount determined by management to be appropriate based on its evaluation. The provision includes the 
combined charge or credit to expense for both the allowance for loan losses and the accrual for off-balance sheet credit risk. All 
losses incurred from lending activities will ultimately be reflected in charge-offs against the allowance for loan losses following 
funds advanced against outstanding commitments. Based on an evaluation of all credit factors, including sustained 
improvement in nonaccruing and potential problem loans during the year, net charge-offs and growth in the loan portfolio 
during the year, the Company determined that an $8.0 million provision for credit losses was appropriate for 2018. The 
Company recorded a $7.0 million negative provision for loan losses for 2017.

54

Table 25 – Summary of Loan Loss Experience 
(In thousands)

Allowance for loan losses:

Beginning balance

Loans charged off:

Commercial

Commercial real estate

Residential mortgage

Personal

Total

Recoveries of loans previously charged off:

Commercial

Commercial real estate

Residential mortgage

Personal

Total

Net loans recovered (charged off )

Provision for loan losses

Ending balance

Accrual for off-balance sheet credit risk:

Beginning balance

Provision for off-balance sheet credit risk

Ending balance

Total combined provision for credit losses

Allowance for loan losses to loans outstanding at period end

Net charge-offs (recoveries) to average loans

Total provision for credit losses to average loans

Recoveries to gross charge-offs

Allowance for loan losses as a multiple of net charge-offs

Accrual for off-balance sheet credit risk to off-balance sheet

credit commitments

Combined allowance for credit losses to loans outstanding at

period-end

Allowance for Loan Losses

Year Ended December 31,

2018

2017

2016

2015

2014

$ 230,682

$ 246,159

$

225,524

$ 189,056

$ 185,396

(42,588)

(15,171)

(16,232)

(37,880)

(19,810)

(35,828)

—

(378)

(5,325)

(43,583)

3,316

3,552

1,047

2,499

10,414

(76)

(649)

(5,064)

(25,599)

4,461

1,940

760

2,451

9,612

—

(1,312)

(5,448)

1,727

1,283

1,999

2,747

7,756

(6,734)

(944)

(2,205)

(5,288)

(3,569)

(2,047)

(4,448)

(6,168)

2,729

11,079

1,260

3,052

18,120

2,949

33,519

5,703

7,003

2,000

4,328

19,034

2,802

858

(33,169)

(15,987)

9,944

510

(34,832)

55,467

$

$

$

$

$ 207,457

$ 230,682

$

$

$

3,734

$ 11,244

(1,944)

(7,510)

1,790

8,000

0.96%

0.18%

0.04%

23.89%

6.25x

$

3,734

$ (7,000)

1.34 %

0.09 %

(0.04)%

37.55 %

14.43x

246,159

$ 225,524

$ 189,056

1,711

9,533

11,244

65,000

$

$

$

1,230

481

1,711

34,000

$

$

$

1.41 %

(0.02)%

0.23 %

1.45%

0.21%

0.40%

18.21%

7.07x

2,088

(858)

1,230

—

1.33 %

(0.02)%

— %

119.44 %

117.26 %

(76.47)x

(67.47)x

0.01%

0.04 %

0.11%

0.02 %

0.01 %

0.97%

1.37 %

1.52%

1.43 %

1.34 %

The appropriateness of the allowance for loan losses is assessed by management based on an ongoing quarterly evaluation of 
the probable estimated losses inherent in the portfolio. The allowance consists of specific allowances attributed to certain 
impaired loans, general allowances based on estimated loss rates by loan class and non-specific allowances based on general 
economic conditions, concentration in loans with large balances and other relevant factors.

Loans are considered to be impaired when it is probable that we will not collect all amounts due according to the original 
contractual terms of the loan agreements. This includes all nonaccruing loans, all loans modified in trouble debt restructurings 
and all government guaranteed loans repurchased from GNMA pools. A specific allowance is required when the outstanding 
principal balance of the loan is not supported by either the discounted cash flows expected to be received from the borrower or 
the fair value of collateral for collateral dependent loans. At December 31, 2018, impaired loans totaled $347 million, including 
$35 million with specific allowances of $8.7 million and $312 million with no specific allowances because the loan balances 
represent the amounts we expect to recover. At December 31, 2017, impaired loans totaled $376 million, including $51 million 
of impaired loans with specific allowances of $8.8 million and $325 million with no specific allowances. 

55

General allowances for unimpaired loans are based on an estimated loss rate by loan class. Estimated loss rates for risk-graded 
loans are either increased or decreased based on changes in risk grading for each loan class. Estimated loss rates for both risk-
graded and non-risk graded loans may be further adjusted for inherent risks identified for the given loan class which have not 
yet been captured in the loss rate.

The aggregate amount of general allowances for all unimpaired loans totaled $181 million at December 31, 2018, compared to 
$200 million at December 31, 2017. The decrease was primarily due to improved risk grading and inherent risk factors related 
to energy loans. 

Nonspecific allowances are maintained for risks beyond factors specific to a particular portfolio segment or loan class. These 
factors include trends in the economy in our primary lending areas, concentrations in loans with large balances and other 
relevant factors. Nonspecific allowances totaled $18 million at December 31, 2018, down from $22 million at December 31, 
2017. 

An allocation of the allowance for loan losses by loan category follows in Table 26.

Table 26 – Allowance for Loan Losses Allocation 
(Dollars in thousands)

2018

2017

December 31,

2016

2015

2014

Allowance

% of 
Loans1

Allowance

% of 
Loans1

Allowance

% of 
Loans1

Allowance

% of 
Loans1

Allowance

% of 
Loans1

Loan category:

Commercial

$ 102,226

62.96% $ 124,269

62.58% $ 140,213

61.16% $ 130,334

64.32% $

90,875

64.02%

Commercial
real estate

Residential
mortgage

Personal

Nonspecific
allowance

60,026

22.00%

56,621

20.29%

50,749

22.42%

41,391

20.44%

42,445

19.20%

10.30%

4.74%

17,964

9,473

17,768

18,451

9,124

22,217

11.50%

5.63%

18,224

8,773

28,200

11.48%

4.94%

11.77%

3.47%

19,509

4,164

30,126

13.72%

3.06%

23,458

4,233

28,045

Total

$ 207,457

100.00% $ 230,682

100.00% $ 246,159

100.00% $ 225,524

100.00% $ 189,056

100.00%

1 Represents ratio of loan category balance to total loans.

Our loan monitoring process also identified certain accruing substandard loans, based on regulatory guidelines, that possess 
more than the normal amount of risk due to deterioration in the financial condition of the borrower or the value of the 
collateral. Because the borrowers are still performing in accordance with the original terms of the loan agreements, and no loss 
of principal or interest is anticipated, these loans were not included in nonperforming assets. Known information does, 
however, cause management concern as to the borrowers’ continued ability to comply with current repayment terms. These 
potential problem loans totaled $215 million at December 31, 2018 composed primarily of $87 million or 2% of energy loans, 
$38 million or 1% of healthcare loans, $33 million or 1% of services loans and $22 million or 3% of manufacturing loans. 
Potential problem loans totaled $241 million at December 31, 2017.

Based on regulatory guidelines, other loans especially mentioned are in compliance with the original terms of the agreement, 
but may have a weakness that deserves management's close attention. Other loans especially mentioned totaled $182 million at 
December 31, 2018 and were composed primarily of $50 million or 2% of service sector loans, $42 million or 1% of energy 
loans, $31 million or 4% of manufacturing sector loans, $19 million or 1% of wholesale/retail sector loans and $15 million or 
1% of healthcare sector loans. Other loans especially mentioned totaled $118 million at December 31, 2017. 

Net Loans Charged Off

Loans are charged off against the allowance for loan losses when the loan balance or a portion of the loan balance is no longer 
covered by the paying capacity of the borrower based on an evaluation of available cash resources and collateral 
value. Internally risk graded loans are evaluated quarterly and charge-offs are taken in the quarter in which the loss is 
identified. Non-risk graded loans are generally charged off when payments are between 60 days and 180 days past due, 
depending on loan class. In addition, non-risk graded loans are generally charged-down to collateral value within 60 days of 
being notified of a borrower's bankruptcy filing, regardless of payment status.

56

BOK Financial had net loans charged off of $33 million or 0.18% of average loans for 2018, compared to net loans charged off 
of $16 million or 0.09% of average loans in 2017. 

Net commercial loans charged off totaled $35 million, primarily from $16 million of net charge-offs from energy loans, $12 
million from wholesale sector loans and $6.6 million of net charge-offs from healthcare loans. Net commercial real estate loan 
recoveries totaled $3.6 million. Net recoveries of residential mortgage loans totaled $669 thousand for the year and net charge-
offs of personal loans were $2.8 million.

57

$

$

$

$

Table 27  - Nonperforming Assets 
(Dollars in Thousands)

Nonaccruing loans:

Commercial

Commercial real estate

Residential mortgage

Personal

Total nonaccruing loans

Accruing renegotiated loans guaranteed by U.S.

government agencies

Real estate and other repossessed assets:

Guaranteed by U.S. government agencies1
Other

Real estate and other repossessed assets

Total nonperforming assets

Total nonperforming assets excluding those
guaranteed by U.S. government agencies

Nonaccruing loans by loan class:

Commercial:

Energy

Healthcare

Manufacturing

Services

Wholesale/retail

Public finance

Other commercial and industrial

Total commercial

Commercial real estate:

Retail

Residential construction and land development

Multifamily

Office

Industrial

Other commercial real estate

Total commercial real estate

Residential mortgage:

Permanent mortgage

Permanent mortgages guaranteed by U.S.

government agencies

Home equity

Total residential mortgage

Personal

Total nonaccruing loans

2018

2017

2016

2015

2014

December 31,

$

137,303

$

178,953

$

76,424

$

99,841

21,621

41,555

230

2,855

47,447

269

5,521

46,220

290

230,984

9,001

61,240

463

147,128

163,247

187,874

86,428

73,994

81,370

74,049

13,527

18,557

48,121

566

80,771

73,985

49,898

51,963

101,861

256,617

129,022

1,416

1,380

450

5,201

4,149

—

931

1,072

331

10,290

2,919

—

623

76,424

13,527

1,319

4,409

274

651

76

2,272

9,001

28,984

21,900

10,356

61,240

463

3,926

5,299

—

3,420

—

5,912

18,557

34,845

3,712

9,564

48,121

566

—

44,287

44,287

356,641

263,425

$

$

—

30,731

30,731

251,908

155,959

$

$

$

$

$

132,499

$

61,189

$

—

17,487

17,487

267,162

173,602

47,494

16,538

8,919

8,567

1,316

—

17,007

99,841

20,279

350

301

—

—

691

$

$

$

—

28,437

28,437

290,305

207,132

92,284

14,765

5,962

2,620

2,574

—

19,098

137,303

276

1,832

—

275

—

472

21,621

2,855

23,951

25,193

7,132

10,472

41,555

230

9,179

13,075

47,447

269

825

4,931

8,173

11,407

—

21,118

178,953

326

3,433

38

426

76

1,222

5,521

22,855

11,846

11,519

46,220

290

$

163,247

$

187,874

$

230,984

$

147,128

$

80,771

58

2018

2017

2016

2015

2014

December 31,

Allowance for loan losses to nonaccruing loans2
Accruing loans 90 days or more past due2
Foregone interest on nonaccruing loans3
8,170
1  Approximately $50 million was reclassified from Real estate and other repossessed assets to Receivables on the balance sheet on January 

132.89%

180.09%

129.09%

112.33%

15,990

16,496

15,502

7,432

1,338

1,207

633

125

$

$

$

$

$

5

245.34%

1, 2015 with the adoption of Financial Accounting Standards Board Update No. 2014-14, Classification of Certain Government-
Guaranteed Mortgage Loans Upon Foreclosure ("ASU 2014-14"). With the implementation of ASU 2014-14, upon foreclosure of loans 
for which the loan balance is expected to be recovered from the guarantee by a U.S. government agency, the loan balance is directly 
reclassified to other receivables without including such foreclosed assets in real estate and other repossessed assets. 

2  Excludes residential mortgages guaranteed by agencies of the U.S. government.
3  Interest collected and recognized on nonaccruing loans was not significant in 2018 and previous years.

Nonperforming assets totaled $267 million or 1.23% of outstanding loans and repossessed assets at December 31, 2018, a $23 
million decrease compared to the prior year. Nonaccruing loans totaled $163 million, accruing renegotiated residential 
mortgage loans totaled $86 million and real estate and other repossessed assets totaled $17 million. All accruing renegotiated 
residential mortgage loans and $7.1 million of nonaccruing loans are guaranteed by U.S. government agencies. Excluding 
assets guaranteed by U.S. government agencies, nonperforming assets decreased $34 million to $174 million or 0.81% of 
outstanding non-guaranteed loans and repossessed assets. The acquisition of CoBiz Financial in 2018 added $18 million to 
nonperforming assets, net of  fair value adjustments. The remaining decrease was primarily due to nonaccruing energy loans 
and real estate and other repossessed assets, partially offset by an increase in nonaccruing commercial real estate loans secured 
by retail facilities. The Company generally retains nonperforming assets to maximize potential recovery, which may cause 
future nonperforming assets to decrease more slowly.

Loans are generally classified as nonaccruing when it becomes probable that we will not collect the full contractual principal 
and interest. As more fully discussed in Note 4 to the Consolidated Financial Statements, we may modify loans in a troubled 
debt restructuring. Modifications may include extension of payment terms and rate concessions. We generally do not forgive 
principal or accrued but unpaid interest. All loans modified in troubled debt restructurings, except residential mortgage loans 
guaranteed by U.S. government agencies, are classified as nonaccruing. We may renew matured nonaccruing loans. All 
nonaccruing loans, including those renewed or modified in troubled debt restructurings, are charged off when the loan balance 
is no longer covered by the paying capacity of the borrower based on a quarterly evaluation of available cash resources and 
collateral value. Nonaccruing loans generally remain on nonaccruing status until full collection of principal and interest in 
accordance with the original terms, including principal previously charged off, is probable. We generally do not voluntarily 
modify personal loans to troubled borrowers. Personal loans modified at the direction of bankruptcy court orders are identified 
as troubled debt restructurings and classified as nonaccruing. 

As of December 31, 2018, renegotiated loans consist solely of accruing residential mortgage loans guaranteed by U.S. 
government agencies that have been modified in troubled debt restructurings. Generally, we modify residential mortgage loans 
primarily by reducing interest rates and extending the number of payments in accordance with U.S. government agency 
guidelines. No unpaid principal or interest is forgiven. Interest continues to accrue based on the modified terms of the 
loan. Modified loans guaranteed by U.S. government agencies under residential mortgage loan programs may be sold once they 
become eligible according to U.S. government agency guidelines. 

59

A rollforward of nonperforming assets for the year ended December 31, 2018 follows in Table 28.

Table 28 – Rollforward of Nonperforming Assets 
(In thousands)

Year Ended December 31, 2018

Nonaccruing 
Loans

Renegotiated 
Loans

Real Estate
and Other
Repossessed
Assets

Total
Nonperforming
Assets

Balance, December 31, 2017

$

187,874

$

73,994

$

28,437

$

Additions

Payments

Charge-offs

Net losses and write-downs

Foreclosure of nonaccruing loans

Foreclosure of loans guaranteed by U.S. government agencies

Proceeds from sales

Acquisitions

Net transfers to nonaccruing loans

Return to accrual status

Other, net

Balance, December 31, 2018

116,372

(94,755)

(43,583)

—

(9,880)

(5,403)

—

12,687

1,793

(1,858)

—

55,521

(3,055)

—

—

—

(8,684)

(31,075)

—

(1,793)

—

1,520

—

—

—

(6,009)

9,880

—

(20,676)

5,155

—

—

700

290,305

171,893

(97,810)

(43,583)

(6,009)

—

(14,087)

(51,751)

17,842

—

(1,858)

2,220

$

163,247

$

86,428

$

17,487

$

267,162

We foreclose on loans guaranteed by U.S. government agencies in accordance with agency guidelines. Generally these loans 
are not eligible for modification programs or have failed to comply with modified loan terms. Principal is guaranteed by 
agencies of the U.S. government, subject to limitations and credit risk is minimal. At foreclosure, these amounts are transferred 
to claims receivable accounts. These properties will be conveyed to the agencies and receivables collected once applicable 
criteria have been met. 

Nonaccruing loans totaled $163 million or 0.75% of outstanding loans at December 31, 2018, compared to $188 million or 
1.10% of outstanding loans at December 31, 2017. Nonaccruing loans decreased $25 million compared to December 31, 2017. 
Newly identified nonaccruing loans totaled $116 million and the acquisition of CoBiz Financial added $13 million of 
nonaccruing loans in 2018. This was offset by $95 million of payments, $44 million of charge-offs and $10 million of 
foreclosures during the year.

Commercial

Nonaccruing commercial loans totaled $100 million or 0.73% of total commercial loans at December 31, 2018, down from 
$137 million or 1.28% of total commercial loans at December 31, 2017. Newly identified nonaccruing commercial loans 
totaled $76 million and acquired nonaccruing commercial loans totaled $13 million, offset by $81 million in payments, $38 
million of charge-offs and $5.3 million of repossessions.  

Nonaccruing commercial loans at December 31, 2018 were primarily composed of $47 million or 1.32% of total energy loans, 
$17 million or 2.04% of other commercial and industrial loans and $17 million or 0.61% of healthcare sector loans. 

Commercial Real Estate

Nonaccruing commercial real estate loans were $22 million or 0.45% of outstanding commercial real estate loans at 
December 31, 2018, compared to $2.9 million or 0.08% of outstanding commercial real estate loans at December 31, 2017. The 
$19 million increase was primarily due to $22 million of newly identified commercial real estate loans during the year, partially 
offset by $3.6 million of cash payments received.

Nonaccruing commercial real estate loans were primarily composed of $20 million or 2.21% of commercial real estate loans 
secured by retail facilities. 

60

Residential Mortgage and Personal

Nonaccruing residential mortgage loans totaled $42 million or 1.86% of outstanding residential mortgage loans at 
December 31, 2018, compared to $47 million or 2.40% of outstanding residential mortgage loans at December 31, 2017. Newly 
identified nonaccruing residential mortgage loans of $13 million were offset by $10 million of cash payments, $4.5 million of 
foreclosures and $378 thousand of loans charged off during the year. Nonaccruing residential mortgage loans primarily 
consisted of $24 million or 1.81% of non-guaranteed permanent residential mortgage loans and $10 million or 1.46% of total 
home equity loans. 

Payments on accruing residential mortgage loans and personal loans may be delinquent. The composition of residential 
mortgage loans and personal loans past due but still accruing is included in the following Table 29. Substantially all non-
guaranteed residential loans past due 90 days or more are nonaccruing. At December 31, 2018, residential mortgage loans 30 to 
59 days past due was $4.3 million, down $1.3 million compared to the prior year. Residential mortgage loans 60 to 89 days past 
due increased $59 thousand from December 31, 2017. Personal loans 30 to 59 days past due decreased $202 thousand and 
personal loans 60 to 89 days past due increased $605 thousand compared to December 31, 2017. Personal loans 90 days or 
more past due decreased $258 thousand.

Table 29 – Residential Mortgage and Personal Loans Past Due 
(In thousands)

December 31, 2018
60 to 89
Days

90 Days
or More

30 to 59
Days

December 31, 2017

90 Days
or More

60 to 89
Days

30 to 59
Days

Residential mortgage:
   Permanent mortgage1

Home equity

Total residential mortgage

Personal

$

$

$

— $
59
59

$

366
352
718

3

$

796

$

$

$

3,196
1,102
4,298

479

$

$

$

— $
17
17

$

219
440
659

261

$

191

$

$

$

3,435
2,206
5,641

681

1  Excludes past due residential mortgage loans guaranteed by agencies of the U.S. government.

Real Estate and Other Repossessed Assets

Real estate and other repossessed assets are assets acquired in partial or total forgiveness of loans. The assets are carried at the 
lower of cost as determined by fair value at date of foreclosure or current fair value, less estimated selling costs.

Real estate and other repossessed assets totaled $17 million at December 31, 2018, composed primarily $6.1 million of oil and 
gas properties, $4.4 million of 1-4 family residential properties, $3.5 million of developed commercial real estate and $3.4 
million of undeveloped land primarily zoned for commercial development. The residential properties and undeveloped land are 
widely disbursed across our geographical footprint. Real estate and other repossessed assets decreased $11 million compared to 
December 31, 2017. 

61

Liquidity and Capital

Based on the average balances for 2018, approximately 65% of our funding was provided by deposit accounts, 20% from 
borrowed funds, less than 1% from long-term subordinated debt and 11% from equity. Our funding sources, which primarily 
include deposits and borrowings from the Federal Home Loan Banks, provide adequate liquidity to meet our operating needs.

Subsidiary Banks

Deposits and borrowed funds are the primary sources of liquidity for the subsidiary banks. Deposit accounts represent our 
largest funding source. We compete for retail and commercial deposits by offering a broad range of products and services and 
focusing on customer convenience. Retail deposit growth is supported through personal and small business checking, online 
bill paying services, mobile banking services, an extensive network of branch locations and ATMs and our ExpressBank call 
center. Commercial deposit growth is supported by offering treasury management and lockbox services. We also acquire 
brokered deposits when the cost of funds is advantageous to other funding sources.

Table 30 - Average Deposits by Line of Business 
(In thousands)

Commercial Banking

Consumer Banking

Wealth Management

Subtotal

Funds Management and other

Total

Year Ended December 31,

2018

2017

$

8,517,137

$

8,725,920

6,560,145

5,617,325

6,610,134

5,516,214

20,694,607

20,852,268

2,114,604

1,332,513

$ 22,809,211

$ 22,184,781

Average deposits for 2018 totaled $22.8 billion and represented approximately 65% of total liabilities and capital compared 
with $22.2 billion and 67% of total liabilities and capital for 2017. Average deposits increased $624 million over the prior year, 
including $859 million related to the fourth quarter impact of the CoBiz acquisition. CoBiz deposits are currently located in 
Funds Management and other. These will be allocated to the reporting segments in 2019. Demand deposits grew by $277 
million, including $408 million of acquired deposits. Interest-bearing transaction deposit account balances increased by $362 
million, including $423 million of acquired deposits. This growth was partially offset by a $60 million decrease in time 
deposits. 

Average deposits attributed to Commercial Banking were $8.5 billion for 2018, a $209 million or 2% decrease compared to 
2017. Demand deposit balances decreased $110 million or 2% and interest-bearing transaction account balances decreased $98 
million or 4%. Despite the series of federal funds rate increases from the Federal Reserve, as well as a modest increase in our 
earnings credit, Commercial Banking continues to retain large cash reserves primarily due to a combination of factors including 
uncertainty about the economic environment and potential for growth, lack of preferable liquid alternatives and a desire to 
minimize deposit charges through the earnings credit. The earnings credit is a non-cash method that enables commercial 
customers to offset deposit service charges based on account balances. Commercial deposit balances may continue to decrease 
as the economic outlook continues to improve and if short-term rates continue to move higher, enhancing their investment 
alternatives. As short-term rates move higher, related increases to the earnings credit rate may be appropriate, which will reduce 
the amount of deposits required to offset service charges.

Average Consumer Banking deposit balances were largely unchanged compared to the prior year. Average demand deposit 
balances grew by $113 million or 6% while average interest-bearing transaction accounts decreased $163 million or 3%. 
Higher costing time deposit balances decreased $106 million or 10%. 

Average Wealth Management deposit balances grew by $101 million or 2% over the prior year. Interest-bearing transaction 
balances increased $170 million or 5%. Non-interest-bearing demand deposits decreased $107 million or 8%, and time deposit 
balances were up $37 million or 5%. 

62

Table 31 - Maturity of Domestic CDs and Public Funds in Amounts of $100,000 or More 
(In thousands)

Months to maturity:

3 or less

Over 3 through 6

Over 6 through 12

Over 12

Total

December 31,

2018

2017

$

$

380,315

$

298,692

299,346

618,413

368,584

278,607

253,277

661,074

1,596,766

$

1,561,542

Brokered deposits included in time deposits averaged $251 million for 2018, compared to $588 million for 2017. Brokered 
deposits included in time deposits totaled $247 million at December 31, 2018 and $573 million at December 31, 2017. 

Average interest-bearing transaction accounts for 2018 included $821 million of brokered deposits compared to $1.4 billion for 
2017. Brokered deposits included in interest-bearing transaction accounts totaled $832 million at December 31, 2018 and $1.5 
billion at December 31, 2017. 

The decrease in average brokered deposits balances was largely driven by a change in the regulatory definition of brokered 
deposits in the second quarter of 2018. 

63

The distribution of our period end deposit account balances among principal markets follows in Table 32.

Table 32 - Period End Deposits by Principal Market Area 
(In thousands)

Oklahoma:

Demand

Interest-bearing:

Transaction

Savings

Time

Total interest-bearing

Total Oklahoma

Texas:

Demand

Interest-bearing:

Transaction

Savings

Time

Total interest-bearing

Total Texas

New Mexico:

Demand

Interest-bearing:

Transaction

Savings

Time

Total interest-bearing

Total New Mexico

Arkansas:

Demand

Interest-bearing:

Transaction

Savings

Time

Total interest-bearing

Total Arkansas

2018

2017

2016

2015

2014

December 31,

$

3,610,593

$

3,885,008

$

3,993,170

$ 4,133,520

$

3,828,819

6,445,831

288,210

1,118,643

7,852,684

5,901,293

265,870

1,092,133

7,259,296

6,345,536

5,971,819

241,696

1,118,355

7,705,587

226,733

1,202,274

7,400,826

6,117,886

206,357

1,301,194

7,625,437

11,463,277

11,144,304

11,698,757

11,534,346

11,454,256

3,289,659

3,239,098

3,137,009

2,627,764

2,639,732

2,294,740

2,397,071

2,388,812

2,132,099

2,065,723

99,624

423,880

2,818,244

6,107,903

93,620

502,879

2,993,570

6,232,668

83,101

535,642

3,007,555

6,144,564

77,902

549,740

2,759,741

5,387,505

72,037

547,316

2,685,076

5,324,808

691,692

663,353

627,979

487,286

487,819

571,347

58,194

224,515

854,056

552,393

55,647

216,743

824,783

590,571

49,963

238,408

878,942

563,723

43,672

267,821

875,216

519,544

37,471

295,798

852,813

1,545,748

1,488,136

1,506,921

1,362,502

1,340,632

36,800

30,384

26,389

27,252

35,996

91,593

1,632

8,726

101,951

138,751

85,095

1,881

14,045

101,021

131,405

105,232

2,192

16,696

124,120

150,509

202,857

1,747

24,983

229,587

256,839

158,115

1,936

28,520

188,571

224,567

64

Colorado:

Demand

Interest-bearing:

Transaction

Savings

Time

Total interest-bearing

Total Colorado

Arizona:

Demand

Interest-bearing:

Transaction

Savings

Time

Total interest-bearing

Total Arizona

Kansas/Missouri:

Demand

Interest-bearing:

Transaction

Savings

Time

Total interest-bearing

Total Kansas/Missouri

2018

2017

2016

2015

2014

December 31,

1,658,473

633,714

576,000

497,318

445,755

1,899,203

57,289

274,877

2,231,369

3,889,842

657,629

35,223

224,962

917,814

616,679

32,866

242,782

892,327

616,697

31,927

296,224

944,848

1,551,528

1,468,327

1,442,166

631,874

29,811

353,998

1,015,683

1,461,438

709,176

334,701

366,755

326,324

369,115

575,996

10,545

43,051

629,592

1,338,768

274,846

3,343

20,394

298,583

633,284

305,099

2,973

27,765

335,837

702,592

358,556

2,893

29,498

390,947

717,271

347,214

2,545

36,680

386,439

755,554

418,199

457,080

508,418

197,424

259,121

327,866

13,721

19,688

361,275

779,474

382,066

13,574

27,260

422,900

879,980

513,176

12,679

42,152

568,007

1,076,425

153,203

1,378

35,524

190,105

387,529

273,999

1,274

45,210

320,483

579,604

Total BOK Financial deposits

$

25,263,763

$

22,061,305

$ 22,748,095

$ 21,088,158

$

21,140,859

See Note 9 to the Consolidated Financial Statements for a summary of other borrowings.

In addition to deposits, liquidity for the subsidiary banks is provided primarily by federal funds purchased, securities 
repurchase agreements and Federal Home Loan Bank borrowings. Federal funds purchased consist primarily of unsecured, 
overnight funds acquired from other financial institutions. Funds are primarily purchased from bankers’ banks and Federal 
Home Loan Banks from across the country. The largest source of wholesale federal funds purchased totaled $300 million at 
December 31, 2018. There were no wholesale federal funds purchased outstanding at December 31, 2017. Securities repurchase 
agreements generally mature within 90 days and are secured by certain available for sale securities. Federal Home Loan Bank 
borrowings are generally short term and are secured by a blanket pledge of eligible collateral (generally unencumbered U.S. 
Treasury and mortgage-backed securities, 1-4 family residential mortgage loans, multifamily and other qualifying commercial 
real estate loans). Amounts borrowed from the Federal Home Loan Bank of Topeka averaged $6.2 billion during 2018 and $5.9 
billion during 2017.

At December 31, 2018, the estimated unused credit available to BOKF, NA from collateralized sources was approximately $7.1 
billion.

BOKF, NA also has a liability related to the repurchase of certain delinquent residential mortgage loans previously sold in 
GNMA mortgage pools. Interest is payable monthly at rates contractually due to investors.

65

Parent Company and Other Non-Bank Subsidiaries

The primary sources of liquidity for BOK Financial are cash on hand and dividends from the subsidiary banks. Cash and cash 
equivalents totaled $167 million at December 31, 2018. Dividends from the subsidiary banks are limited by various banking 
regulations to net profits, as defined, for the year plus retained profits for the two preceding years. Dividends are further 
restricted by minimum capital requirements. At December 31, 2018, based on the most restrictive limitations as well as 
management’s internal capital policy, BOKF, NA could declare up to $71 million of dividends without regulatory 
approval. Dividend constraints may be alleviated through increases in retained earnings, capital issuances or changes in risk 
weighted assets. Future losses or increases in required regulatory capital could also affect its ability to pay dividends to the 
parent company. 

On June 27, 2016, the parent company issued $150 million of subordinated debt that will mature on June 30, 2056. This debt 
bears interest at the rate of 5.375%, payable quarterly. On June 30, 2021, we will have the option to redeem the debt at the 
principal amount plus accrued interest, subject to regulatory approval.

As a result of the acquisition of CoBiz Financial, we obtained $60 million of subordinated debt issued in June 2015 that will 
mature on June 25, 2030. This debt bears interest at the rate of 5.625% through June 25, 2025 and thereafter, the notes will bear 
an annual floating rate equal to 3-month LIBOR plus 317 basis points. We also acquired $72 million of junior subordinated 
debentures. Interest is based on spreads over 3 month LIBOR ranging from 145 basis points to 295 basis points and mature 
September 17, 2033 through September 30, 2035. The junior subordinated debentures are subject to early redemption prior to 
maturity.

Shareholders' equity at December 31, 2018 was $4.4 billion, an increase of $937 million over December 31, 2017. The 
Company issued 7.2 million shares in conjunction with the acquisition of CoBiz Financial. Net income less cash dividends paid 
increased equity $318 million during 2018. Changes in interest rates resulted in an increase in the accumulated other 
comprehensive loss to $73 million at December 31, 2018, compared to $36 million at December 31, 2017. Capital is managed 
to maximize long-term value to the shareholders. Factors considered in managing capital include projections of future earnings 
including expected benefits from lower federal income tax rates, asset growth and acquisition strategies, and regulatory and 
debt covenant requirements. Capital management may include subordinated debt issuance, share repurchase and stock and cash 
dividends. 

On October 27, 2015, the Board of Directors authorized the Company to purchase up to five million common shares, subject to 
market conditions, securities laws and other regulatory compliance limitations. As of December 31, 2018, a cumulative total of 
3,575,083 shares have been repurchased under this authorization. The Company repurchased 615,840 shares during 2018 at an 
average price of $86.82 per share.

BOK Financial and the subsidiary banks are subject to various capital requirements administered by federal agencies. Failure to 
meet minimum capital requirements, including capital conservation buffer, can result in certain mandatory and additional 
discretionary actions by regulators that could have a material impact on operations including restrictions on capital distributions 
from dividends and share repurchases and executive bonus payments. These capital requirements include quantitative measures 
of assets, liabilities and off-balance sheet items. The capital standards are also subject to qualitative judgments by the 
regulators.

A summary of minimum capital requirements, including capital conservation buffer, follows for BOK Financial on a 
consolidated basis in Table 33. 

66

Table 33 – Capital Ratios 

Risk-based capital:

Common equity Tier 1

Tier 1 capital

Total capital

Tier 1 Leverage

Average total equity to average assets

Tangible common equity ratio

Minimum
Capital
Requirement

Capital
Conservation
Buffer

Minimum
Capital
Requirement
Including
Capital
Conservation
Buffer

4.50%

6.00%

8.00%

4.00%

2.50%

2.50%

2.50%

N/A

7.00%

8.50%

10.50%

4.00%

December 31,

2018

2017

10.92%

10.92%

12.50%

8.96%

10.70%

8.82%

12.05%
12.05%

13.54%

9.31%

10.43%

9.50%

At March 31, 2018, the Company exceeded the $1 billion regulatory capital rules threshold for trading assets plus liabilities. 
This subjected the Company to the market risk rule, which imposed additional modeling, systems, oversight and reporting 
requirements effective beginning the second quarter of 2018 and resulted in an increase in risk weighted assets associated with 
trading.

Capital resources of financial institutions are also regularly measured by the tangible common shareholders’ equity 
ratio. Tangible common shareholders’ equity is shareholders’ equity as defined by generally accepted accounting principles in 
the United States of America (“GAAP”), including unrealized gains and losses on available for sale securities, less intangible 
assets and equity which does not benefit common shareholders. Equity that does not benefit common shareholders includes 
preferred equity. This non-GAAP measure is a valuable indicator of a financial institution’s capital strength since it eliminates 
intangible assets from shareholders’ equity and retains the effect of unrealized losses on securities and other components of 
accumulated other comprehensive income in shareholders’ equity.

Table 34 following provides a reconciliation of the non-GAAP measures with financial measures defined by GAAP.

Table 34 – Non-GAAP Measures 
(Dollars in thousands)

Tangible common equity ratio:
Total shareholders' equity
Less: Goodwill and intangible assets, net
Tangible common equity
Total assets
Less: Goodwill and intangible assets, net
Tangible assets
Tangible common equity ratio

Off-Balance Sheet Arrangements

December 31,

2018

2017

$ 4,432,109
1,184,112
3,247,997
38,020,504
1,184,112
$ 36,836,392

$

3,495,367
476,088
3,019,279
32,272,160
476,088
$ 31,796,072

8.82%

9.50%

See Note 14 to the Consolidated Financial Statements for a discussion of the Company’s significant off-balance sheet 
commitments.

Aggregate Contractual Obligations

BOK Financial has numerous contractual obligations in the normal course of business. These obligations include time deposits 
and other borrowed funds, premises used under various operating leases, commitments to extend credit to borrowers and to 
purchase securities, derivative contracts and contracts for services such as data processing that are integral to our operations. 
Table 35 following summarizes payments due on contractual obligations with initial terms in excess of one year. 

67

Table 35 – Contractual Obligations as of December 31, 2018
(In thousands)

Time deposits

Other borrowings

Subordinated debentures

Lease obligations

Derivative contracts

Data processing services

Total

Loan commitments

Standby letters of credit

Mortgage loans sold with recourse

Alternative investment commitments

Less Than 
1 Year

1 to 3
Years

4 to 5
Years

More Than
5 Years

Total

$

980,971

$

367,887

$

257,811

$

258,112

$

1,864,781

575

15,068

25,794

132,147

15,561

1,150

30,136

46,121

35,837

21,128

1,200

30,136

28,147

6,563

16,941

7,557

581,255

78,598

6,511

21,224

10,482

656,595

178,660

181,058

74,854

$

1,170,116

$

502,259

$

340,798

$

953,257

$

2,966,430

$

11,944,525

582,196

98,623

73,885

Payments on time deposits, other borrowed funds and subordinated debentures include interest which has been calculated from 
rates at December 31, 2018. These obligations may have variable interest rates and actual payments will differ from the 
amounts shown on this table. 

Payments on time deposits are based on contractual maturity dates. These funds may be withdrawn prior to maturity. We may 
charge the customer a penalty for early withdrawal.

Lease commitments generally represent real property we rent for branch offices, corporate offices and operations 
facilities. Payments presented represent the minimum lease payments and exclude related costs such as utilities and property 
taxes.

Obligations under derivative contracts are used in customer hedging programs. As previously discussed, we have entered into 
derivative contracts which are expected to substantially offset the cash payments due on these obligations. 

Data processing and communications contracts represent the minimum obligations under the contracts. Additional payments 
that are based on the volume of transactions processed are excluded.

Loan commitments represent legally binding obligations to provide financing to our customers. Some of these commitments 
are expected to expire before being drawn upon and the total commitment amounts do not necessarily represent future cash 
requirements. Approximately $2.3 billion of the loan commitments expire within one year.

The Company has funded $253 million and has commitments to fund an additional $74 million for various alternative 
investments. Alternative investments primarily consist of limited partnership interests in entities that invest in low income 
housing projects. Legally binding commitments to fund alternative investments are recognized as liabilities in the Consolidated 
Financial Statements.

Recently Issued Accounting Standards

See Note 1 of the Consolidated Financial Statements for disclosure of newly adopted and pending accounting standards.

68

Forward-Looking Statements

This 10-K contains forward-looking statements that are based on management's beliefs, assumptions, current expectations, 
estimates and projections about BOK Financial, the financial services industry and the economy generally. Words such as 
“anticipates,” “believes,” “estimates,” “expects,” “forecasts,” “plans,” “projects,” “will,” “intends,” variations of such words 
and similar expressions are intended to identify such forward-looking statements. Management judgments relating to and 
discussion of the provision and allowance for credit losses, allowance for uncertain tax positions, accruals for loss 
contingencies and valuation of mortgage servicing rights involve judgments as to expected events and are inherently forward-
looking statements. Assessments that BOK Financial's acquisitions, including its latest acquisition of CoBiz Financial, Inc., and 
other growth endeavors will be profitable are necessary statements of belief as to the outcome of future events based in part on 
information provided by others which BOK Financial has not independently verified. These statements are not guarantees of 
future performance and involve certain risks, uncertainties, and assumptions which are difficult to predict with regard to timing, 
extent, likelihood and degree of occurrence. Therefore, actual results and outcomes may materially differ from what is 
expected, implied or forecasted in such forward-looking statements. Internal and external factors that might cause such a 
difference include, but are not limited to changes in commodity prices, interest rates and interest rate relationships, inflation, 
demand for products and services, the degree of competition by traditional and nontraditional competitors, changes in banking 
regulations, tax laws, prices, levies and assessments, the impact of technological advances, and trends in customer behavior as 
well as their ability to repay loans. There may also be difficulties and delays in integrating CoBiz Financial Inc.'s business or 
fully realizing cost savings and other benefits including, but not limited to, business disruption and customer acceptance of 
BOK Financial Corporation's products and services. BOK Financial and its affiliates undertake no obligation to update, amend 
or clarify forward-looking statements, whether as a result of new information, future events, or otherwise.

Legal Notice

As used in this report, the term “BOK Financial” and such terms as “the Company,” “the Corporation,” “our,” “we” and “us” 
may refer to one or more of the consolidated subsidiaries or all of them taken as a whole. All these terms are used for 
convenience only and are not intended as a precise description of any of the separate companies, each of which manages its 
own affairs.

69

ITEM 7A.  QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK

Market Risk

Market risk is a broad term for the risk of economic loss due to adverse changes in the fair value of a financial instrument. 
These changes may be the result of various factors, including interest rates, foreign exchange rates, commodity prices or equity 
prices. Financial instruments that are subject to market risk can be classified either as held for trading or held for purposes other 
than trading. Market risk excludes changes in fair value due to credit of the individual issuers of financial instruments.

BOK Financial is subject to market risk primarily through the effect of changes in interest rates on both its assets held for 
purposes other than trading and trading assets. The effects of other changes, such as foreign exchange rates, commodity prices 
or equity prices do not pose significant market risk to BOK Financial. BOK Financial has no material investments in assets that 
are affected by changes in foreign exchange rates or equity prices. Energy and agricultural product derivative contracts, which 
are affected by changes in commodity prices, are matched against offsetting contracts as previously discussed.

The Asset/Liability Committee is responsible for managing market risk in accordance with policy limits established by the 
Board of Directors. The Committee monitors projected variation in net interest revenue, net income and economic value of 
equity due to specified changes in interest rates. These limits also set maximum levels for short-term borrowings, short-term 
assets, public funds and brokered deposits and establish minimum levels for un-pledged assets, among other things. Further, the 
Board approved market risk limits for fixed income trading, mortgage pipeline and mortgage servicing assets inclusive of 
economic hedge benefits. Exposure is measured daily and compliance is reviewed monthly. Deviations from the Board 
approved limits, which periodically occur throughout the reporting period, may require management to develop and execute 
plans to reduce exposure. These plans are subject to escalation to and approval by the Board.

The simulations used to manage market risk are based on numerous assumptions regarding the effects of changes in interest 
rates on the timing and extent of repricing characteristics, future cash flows and customer behavior. These assumptions are 
inherently uncertain and, as a result, models cannot precisely estimate or precisely predict the impact of higher or lower interest 
rates. Actual results will differ from simulated results due to timing, magnitude and frequency of interest rate changes, market 
conditions and management strategies, among other factors.

Interest Rate Risk – Other than Trading

As previously noted in the Net Interest Revenue section of this report, management has implemented strategies to manage the 
Company’s balance sheet to have relatively limited exposure to changes in interest rates over a twelve-month period. The 
effectiveness of these strategies in managing the overall interest rate risk is evaluated through the use of an asset/liability 
model. BOK Financial performs a sensitivity analysis to identify more dynamic interest rate risk exposures, including 
embedded option positions, on net interest revenue. A simulation model is used to estimate the effect of changes in interest rates 
on our performance across multiple interest rate scenarios. Our current internal policy limit for net interest revenue variation 
due to a 200 basis point parallel change in market interest rates over twelve months is a maximum decline of 5%. The results of 
a 200 basis point decrease in interest rates in the current low-rate environment are not meaningful. Until such time as it 
becomes meaningful, we will instead report the effect of a 100 basis point decrease in interest rates.

The Company’s primary interest rate exposures include the Federal Funds rate, which affects short-term borrowings, and the 
prime lending rate and LIBOR, which are the basis for much of the variable rate loan pricing. Additionally, residential 
mortgage rates directly affect the prepayment speeds for residential mortgage-backed securities and mortgage servicing 
rights. Derivative financial instruments and other financial instruments used for purposes other than trading are included in this 
simulation. In addition, the impact on the level and composition of demand deposit accounts and other core deposit balances 
resulting from a significant increase in short-term market interest rates and the overall interest rate environment is likely to be 
material. The simulation incorporates assumptions regarding the effects of such changes based on a combination of historical 
analysis and expected behavior. The impact of planned growth and new business activities is factored into the simulation 
model. 

70

Table 36 – Interest Rate Sensitivity
(Dollar in thousands)

200 bp Increase

100 bp Decrease

2018

2017

2018

2017

Anticipated impact over the next twelve months on net interest revenue

$

(4,248)

$

(2,692)

$ (42,483)

$

(37,072)

(0.36)%

(0.30)%

(3.57)%

(4.16)%

BOK Financial is also subjected to market risk through changes in the fair value of mortgage servicing rights. Changes in the fair 
value of mortgage servicing rights are highly dependent on changes in primary mortgage rates offered to borrowers, intermediate-
term interest rates that affect the value of custodial funds, and assumptions about servicing revenues, servicing costs and discount 
rates. As primary mortgage rates increase, prepayment speeds slow and the value of our mortgage servicing rights increases. As 
primary mortgage rates fall, prepayment speeds increase and the value of our mortgage servicing rights decreases.

We maintain a portfolio of financial instruments, which may include debt securities issued by the U.S. government or its 
agencies and interest rate derivative contracts held as an economic hedge of the changes in the fair value of our mortgage 
servicing rights. Composition of this portfolio will change based on our assessment of market risk. Changes in the fair value of 
residential mortgage-backed securities are highly dependent on changes in secondary mortgage rates required by investors, and 
interest rate derivative contracts are highly dependent on changes in other market interest rates. While primary and secondary 
mortgage rates generally move in the same direction, the spread between them may widen and narrow due to market conditions 
and government intervention. Changes in the forward-looking spread between the primary and secondary rates can cause 
significant earnings volatility. 

Management performs a stress test to measure market risk due to changes in interest rates inherent in its MSR portfolio and 
hedges. The stress test shocks applicable interest rates up and down 50 basis points and calculates an estimated change in fair 
value, net of economic hedging activity, that may result. The Board has approved a $20 million market risk limit for mortgage 
servicing rights, net of economic hedges. 

Table 37 - MSR Asset and Hedge Sensitivity Analysis 
(In thousands)

MSR Asset

MSR Hedge

Net Exposure

Trading Activities

December 31,

2018

2017

Up 50 bp

Down 50 bp

Up 50 bp

Down 50 bp

$

18,619

$

(27,154) $

25,818

$

(32,856)

(21,838)

(3,219)

21,922

(5,232)

(29,501)

(3,683)

25,021

(7,835)

The Company bears market risk by originating residential mortgages held for sale ("RMHFS"). RMHFS are generally 
outstanding for 60 to 90 days, which represents the typical period from commitment to originate a loan to sale of the closed 
loan to an investor. Primary mortgage interest rate changes during this period affect the value of RMHFS commitments and 
loans. We use forward sale contracts to mitigate market risk on all closed mortgage loans held for sale and on an estimate of 
mortgage loan commitments that are expected to result in closed loans. 

A variety of methods are used to monitor market risk of mortgage origination activities. These methods include daily marking 
of all positions to market value, independent verification of inventory pricing, and revenue sensitivity limits. 

Management performs a stress test to measure market risk due to changes in interest rates inherent in the mortgage production 
pipeline. The stress test shocks applicable interest rates up and down 50 basis points and calculates an estimated change in fair 
value, net of economic hedging activity that may result. The Board has approved a $7 million market risk limit for the 
mortgage production pipeline, net of forward sale contracts. 

71

Table 38  - Mortgage Pipeline Sensitivity Analysis 
(In thousands)

Year Ended
December 31,

2018

2017

Up 50 bp Down 50 bp Up 50 bp Down 50 bp

Average1
Low2
High3
Period End
1   Average represents the simple average of each daily value observed during the reporting period. 
2  Low represents least risk of loss in fair value measured as the smallest negative value or the largest positive value observed daily during the reporting period.
3  High represents the greatest risk of loss in fair value measured as the largest negative value or the smallest positive value observed daily during the reporting 

(697) $

(1,015)

(2,447)

(1,979)

(1,040)

(2,377)

2,077

1,314

(420)

(263)

(114)

(16)

789

223

699

23

$

$

$

period.

BOK Financial enters into trading activities both as an intermediary for customers and for its own account. As an intermediary, 
we take positions in securities, generally residential mortgage-backed securities, government agency securities and municipal 
bonds. These securities are purchased for resale to customers, which include individuals, corporations, foundations and 
financial institutions. On a limited basis, we may also take trading positions in U.S. Treasury securities, residential mortgage-
backed securities, and municipal bonds to enhance returns on securities portfolios. Both of these activities involve interest rate, 
liquidity and price risk. BOK Financial has an insignificant exposure to foreign exchange risk and does not take positions in 
commodity derivatives.

A variety of methods are used to monitor the interest rate risk of trading activities. These methods include daily marking of all 
positions to market value, independent verification of inventory pricing, and position limits for each trading activity. Economic 
hedges in either the futures or cash markets may be used to reduce the risk associated with some trading programs.

Management performs a stress test to measure market risk from changes in interest rates on its trading portfolio. The stress test 
shocks applicable interest rates up and down 50 basis points and calculates an estimated change in fair value, net of economic 
hedging activity that may result. The Board has approved an $8 million market risk limit for the trading portfolio, net of 
economic hedges. 

Table 39 –Trading Securities Sensitivity Analysis 
(In thousands)

Average1
Low2
High3
Period End

Year Ended
December 31,

2018

2017

Up 50 bp Down 50 bp Up 50 bp Down 50 bp

$ (1,133) $

649

$ (1,702) $

2,041

(4,534)

1,470

4,423

(3,463)

(1,081)

668

(4,386)

(488)

1,799

5,210

(1,046)

539

1   Average represents the simple average of each daily value observed during the reporting period. 
2  Low represents least risk of loss in fair value measured as the smallest negative value or the largest positive value observed daily during the reporting period.
3  High represents the greatest risk of loss in fair value measured as the largest negative value or the smallest positive value observed daily during the reporting 

period.

72

ITEM 8.  FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA

Report of Management on Internal Control over Financial Reporting

Management of BOK Financial Corporation is responsible for establishing and maintaining adequate internal control over 
financial reporting and for assessing the effectiveness of internal control over financial reporting, as such term is defined in 
Exchange Act Rules 13a-15(f) and 15d-15(f), as amended. Management has assessed the effectiveness of the Company’s 
internal control over financial reporting based on the criteria established in “Internal Control – Integrated Framework,” issued 
by the Committee of Sponsoring Organizations (“COSO”) of the Treadway Commission in 2013. Based on that assessment and 
criteria, management has determined that the Company maintained effective internal control over financial reporting as of 
December 31, 2018.

As permitted, management excluded from its assessment the operations of CoBiz Financial, which was acquired on October 1, 
2018. As described in Note 6 to the Consolidated Financial Statements, assets acquired and excluded from management's 
assessment of internal control over financial reporting comprised approximately 12% and 20% of consolidated total and net 
assets, respectively, at December 31, 2018.  Operations of CoBiz Financial comprised approximately 3% and 3% of revenues 
and net income, respectively, for the year ended December 31, 2018.

Ernst & Young LLP, the independent registered public accounting firm that audited the Consolidated Financial Statements of 
the Company included in this annual report has issued an audit report on the effectiveness of the Company’s internal control 
over financial reporting as of December 31, 2018. Their report, which expresses unqualified opinion on the effectiveness of the 
Company’s internal control over financial reporting as of December 31, 2018, is included in this annual report.

73

Report of Independent Registered Public Accounting Firm

To the Shareholders and Board of Directors of BOK Financial Corporation

Opinion on Internal Control over Financial Reporting

We have audited BOK Financial Corporation’s internal control over financial reporting as of December 31, 2018, based on 
criteria established in Internal Control-Integrated Framework issued by the Committee of Sponsoring Organizations of the 
Treadway Commission (2013 framework) (the COSO criteria). In our opinion, BOK Financial Corporation (the Company) 
maintained, in all material respects, effective internal control over financial reporting as of December 31, 2018, based on the 
COSO criteria.

As indicated in the accompanying Report of Management on Internal Control over Financial Reporting, management’s 
assessment of and conclusion on the effectiveness of internal control over financial reporting did not include the internal 
controls of CoBiz Financial, which is included in the 2018 consolidated financial statements of the Company and constituted 
12% and 20% of total and net assets, respectively, as of December 31, 2018 and 3% and 3% of revenues and net income, 
respectively, for the year then ended. Our audit of internal control over financial reporting of the Company also did not include 
an evaluation of the internal control over financial reporting of CoBiz Financial.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) 
(PCAOB), the consolidated balance sheets of BOK Financial Corporation as of December 31, 2018 and 2017, and the related 
consolidated statements of earnings, comprehensive income, changes in equity, and cash flows for each of the three years in the 
period ended December 31, 2018, and the related notes and our report dated March 1, 2019 expressed an unqualified opinion 
thereon.

Basis for Opinion

The Company’s management is responsible for maintaining effective internal control over financial reporting and for its 
assessment of the effectiveness of internal control over financial reporting included in the accompanying Report of 
Management on Internal Control over Financial Reporting. Our responsibility is to express an opinion on the Company’s 
internal control over financial reporting based on our audit. We are a public accounting firm registered with the PCAOB and are 
required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable 
rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the 
audit to obtain reasonable assurance about whether effective internal control over financial reporting was maintained in all 
material respects. 

Our audit included obtaining an understanding of internal control over financial reporting, assessing the risk that a material 
weakness exists, testing and evaluating the design and operating effectiveness of internal control based on the assessed risk, and 
performing such other procedures as we considered necessary in the circumstances. We believe that our audit provides a 
reasonable basis for our opinion.

Definition and Limitations of Internal Control over Financial Reporting

A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the 
reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally 
accepted accounting principles. A company’s internal control over financial reporting includes those policies and procedures 
that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and 
dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit 
preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and 
expenditures of the company are being made only in accordance with authorizations of management and directors of the 
company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or 
disposition of the company’s assets that could have a material effect on the financial statements.

74

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, 
projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate 
because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

/s/ Ernst & Young LLP

Tulsa, Oklahoma

March 1, 2019 

75

Report of Independent Registered Public Accounting Firm

To the Shareholders and the Board of Directors of BOK Financial Corporation

Opinion on the Financial Statements

We have audited the accompanying consolidated balance sheets of BOK Financial Corporation (the Company) as of 
December 31, 2018 and 2017, and the related consolidated statements of earnings, comprehensive income, changes in equity, 
and cash flows for each of the three years in the period ended December 31, 2018, and the related notes (collectively referred to 
as the "consolidated financial statements"). In our opinion, the consolidated financial statements present fairly, in all material 
respects, the financial position of the Company at December 31, 2018 and 2017, and the results of its operations and its cash 
flows for each of the three years in the period ended December 31, 2018, in conformity with U.S. generally accepted 
accounting principles.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) 
(PCAOB), the Company's internal control over financial reporting as of December 31, 2018, based on the criteria established in 
Internal Control-Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission 
(2013 framework), and our report dated March 1, 2019 expressed an unqualified opinion thereon.

Basis for Opinion

These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on 
the Company's financial statements based on our audits. We are a public accounting firm registered with the PCAOB and are 
required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable 
rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the 
audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to 
error or fraud. Our audits included performing procedures to assess the risks of material misstatement of the financial 
statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included 
examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also included 
evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall 
presentation of the financial statements. We believe that our audits provide a reasonable basis for our opinion.

/s/ Ernst & Young LLP

We have served as the Company's auditor since 1990.

Tulsa, Oklahoma

March 1, 2019 

76

77

Consolidated Statements of Earnings

(In thousands, except share and per share data)

Interest and dividend revenue
Loans
Residential mortgage loans held for sale
Trading securities
Investment securities
Available for sale securities
Fair value option securities
Restricted equity securities
Interest-bearing cash and cash equivalents

Total interest and dividend revenue

Interest expense
Deposits
Borrowed funds
Subordinated debentures
Total interest expense

Net interest and dividend revenue
Provision for credit losses
Net interest and dividend revenue after provision for credit losses
Other operating revenue
Brokerage and trading revenue
Transaction card revenue
Fiduciary and asset management revenue
Deposit service charges and fees
Mortgage banking revenue
Other revenue
Total fees and commissions
Other gains (losses), net
Gain (loss) on derivatives, net
Loss on fair value option securities, net
Change in fair value of mortgage servicing rights
Gain (loss) on available for sale securities, net
Total other operating revenue
Other operating expense
Personnel
Business promotion
Charitable contributions to BOKF Foundation
Professional fees and services
Net occupancy and equipment
Insurance
Data processing and communications
Printing, postage and supplies
Net losses and operating expenses of repossessed assets
Amortization of intangible assets
Mortgage banking costs
Other expense
Total other operating expense
Net income before taxes
Federal and state income taxes
Net income
Net income (loss) attributable to non-controlling interests
Net income attributable to BOK Financial Corporation shareholders
Earnings per share:

Basic
Diluted

Average shares used in computation:

Basic
Diluted

Dividends declared per share

See accompanying notes to Consolidated Financial Statements.

78

Year Ended December 31,
2017

2016

2018

$

$

891,587
8,123
57,531
14,775
197,317
15,205
21,555
22,333
1,228,426

95,517
138,215
9,827
243,559
984,867
8,000
976,867

108,323
84,025
184,703
112,153
97,787
56,651
643,642
(2,731)
(422)
(25,572)
4,668
(2,801)
616,784

696,479
8,706
17,002
16,121
177,070
16,755
18,490
22,128
972,751

53,803
69,124
8,123
131,050
841,701
(7,000)
848,701

131,601
119,988
162,889
112,079
104,719
49,959
681,235
11,213
779
(2,733)
172
4,428
695,094

583,131
30,523
2,846
59,099
97,981
23,318
114,796
17,169
17,052
9,620
46,298
26,333
1,028,166
565,485
119,061
446,424
778
445,646

6.63
6.63

66,628,640
66,662,273
1.90

573,408
28,877
2,000
51,067
86,477
19,653
146,970
15,689
9,687
6,779
52,856
32,054
1,025,517
518,278
182,593
335,685
1,041
334,644

5.11
5.11

64,745,364
64,806,284
1.77

$

$
$

$

$

$
$

$

$

$

$
$

$

581,030
12,658
8,527
16,894
175,321
6,723
17,238
10,726
829,117

40,494
35,099
6,296
81,889
747,228
65,000
682,228

138,377
116,452
135,387
111,589
133,914
50,112
685,831
4,947
(15,685)
(10,555)
(2,193)
11,675
674,020

553,119
26,582
2,000
56,783
80,024
32,489
131,841
15,584
3,359
6,862
61,387
47,560
1,017,590
338,658
106,377
232,281
(387)
232,668

3.53
3.53

65,085,627
65,143,898
1.73

Consolidated Statements of Comprehensive Income

(In thousands)

Net income

Other comprehensive loss before income taxes:

Net change in unrealized gain (loss)

Reclassification adjustments included in earnings:

Interest revenue, Investment securities, Taxable securities

Loss (gain) on available for sale securities, net

Other comprehensive loss, before income taxes

Federal and state income taxes

Other comprehensive loss, net of income taxes

Comprehensive income

Comprehensive income (loss) attributable to non-controlling interests

Year Ended December 31,

2018

2017

2016

$

446,424

$

335,685

$

232,281

(48,010)

(26,152)

(41,521)

—

2,801

(45,209)

(11,507)

(33,702)

—

(4,428)

(30,580)

(11,923)

(18,657)

(112)

(11,675)

(53,308)

(20,754)

(32,554)

412,722

317,028

199,727

778

1,041

(387)

Comprehensive income attributable to BOK Financial Corp. shareholders

$

411,944

$

315,987

$

200,114

See accompanying notes to Consolidated Financial Statements.

79

Consolidated Balance Sheets

(In thousands, except share data)

Assets
Cash and due from banks
Interest-bearing cash and cash equivalents
Trading securities
Investment securities (fair value:  2018 – $367,298; 2017 – $480,035)
Available for sale securities
Fair value option securities
Restricted equity securities
Residential mortgage loans held for sale
Loans
Allowance for loan losses
Loans, net of allowance
Premises and equipment, net
Receivables
Goodwill
Intangible assets, net
Mortgage servicing rights
Real estate and other repossessed assets, net of allowance (2018 – $13,665; 2017 – $12,648)
Derivative contracts
Cash surrender value of bank-owned life insurance
Receivable on unsettled securities sales
Other assets

Total assets

Liabilities and Equity
Liabilities:
Noninterest-bearing demand deposits
Interest-bearing deposits:

Transaction
Savings
Time
Total deposits

Funds purchased and repurchase agreements
Other borrowings
Subordinated debentures
Accrued interest, taxes and expense
Derivative contracts
Due on unsettled securities purchases
Other liabilities

Total liabilities
Shareholders' equity:
Common stock ($.00006 par value; 2,500,000,000 shares authorized; shares issued and outstanding: 2018 – 

75,711,492; 2017 – 75,147,686)

Capital surplus
Retained earnings
Treasury stock (shares at cost:  2018 – 3,588,560; 2017 – 9,752,749)
Accumulated other comprehensive loss
Total shareholders’ equity

Non-controlling interests
Total equity
Total liabilities and equity

See accompanying notes to Consolidated Financial Statements.

80

December 31,

2018

2017

741,749
401,675
1,956,923
355,187
8,857,120
283,235
344,447
149,221
21,656,730
(207,457)
21,449,273
330,033
204,960
1,049,263
134,849
259,254
17,487
320,929
381,608
336,400
446,891
38,020,504

$

$

602,510
1,714,544
462,676
461,793
8,321,578
755,054
320,189
221,378
17,153,424
(230,682)
16,922,742
317,335
178,800
447,430
28,658
252,867
28,437
220,502
316,498
340,077
359,092
32,272,160

$

$

$

10,414,592

$

9,243,338

12,206,576
529,215
2,113,380
25,263,763
1,018,411
6,124,390
275,913
192,826
362,306
156,370
183,480
33,577,459

10,250,393
469,158
2,098,416
22,061,305
574,963
5,134,897
144,677
164,895
171,963
338,745
162,381
28,753,826

5

1,334,030
3,369,654
(198,995)
(72,585)
4,432,109
10,936
4,443,045
38,020,504

$

4

1,035,895
3,048,487
(552,845)
(36,174)
3,495,367
22,967
3,518,334
32,272,160

$

Consolidated Statements of Changes in Equity

(In thousands)

Common Stock

Shares

Amount

Capital
Surplus

Retained
Earnings

Treasury Stock

Shares

Amount

Accumulated
Other
Comprehensive
Income (Loss)

Total
Shareholders’
Equity

Non-
Controlling
Interests

Total
Equity

4

—

—

—

—

—

—

—

—

4

—

—

—

—

—

—

—

—

—

$ 982,009

$2,704,121

8,636

$ (477,165) $

21,587

$

3,230,556

$

37,083

$3,267,639

—

—

232,668

—

—

—

—

—

—

(32,554)

1,005

(66,792)

12,465

1,590

—

10,471

—

—

—

—

—

—

(113,455)

—

—

—

15

—

—

—

—

—

(95)

—

—

—

—

—

—

—

—

—

—

232,668

(32,554)

(66,792)

12,465

1,590

(95)

10,471

(113,455)

(387)

232,281

—

—

—

—

—

—

—

(32,554)

(66,792)

12,465

1,590

(95)

10,471

(113,455)

—

(5,193)

(5,193)

1,006,535

2,823,334

9,656

(544,052)

(10,967)

3,274,854

31,503

3,306,357

—

—

—

5,758

—

—

23,602

334,644

—

—

—

—

—

—

—

—

(116,041)

—

—

—

80

—

—

17

—

—

—

—

—

(7,403)

—

—

(1,390)

—

—

—

—

(18,657)

—

—

—

—

—

—

—

334,644

(18,657)

(7,403)

5,758

—

(1,390)

23,602

(116,041)

1,041

335,685

—

—

—

—

—

—

—

(18,657)

(7,403)

5,758

—

(1,390)

23,602

(116,041)

—

(9,577)

(9,577)

Balance, December 31,

2015

Net income

Other comprehensive loss

Repurchase of common

stock

Share-based

compensation plans:

Stock options exercised

Non-vested shares
awarded, net

Vesting of non-vested

shares

Share-based

compensation

Cash dividends on
common stock

Capital calls and

distributions, net

74,530

$

—

—

214

249

—

—

—

—

Balance, December 31,

2016

Net income

Other comprehensive loss

Repurchase of common

stock

Share-based

compensation plans:

74,993

—

—

—

Stock options exercised

100

55

—

—

—

—

Non-vested shares
awarded, net

Vesting of non-vested

shares

Share-based

compensation

Cash dividends on
common stock

Capital calls and

distributions, net

Reclassification of

stranded accumulated
other comprehensive
loss related to tax
reform

Balance, December 31,

2017

75,148

$

4

$1,035,895

$3,048,487

9,753

$ (552,845) $

(36,174) $

3,495,367

$

22,967

$3,518,334

6,550

(6,550)

—

—

—

81

Consolidated Statements of Changes in Equity

(In thousands)

Common Stock

Shares

Amount

Capital
Surplus

Retained
Earnings

Treasury Stock

Shares

Amount

Accumulated
Other
Comprehensive
Income (Loss)

Total
Shareholders’
Equity

Non-
Controlling
Interests

Total
Equity

75,148

$

4

$1,035,895

$3,048,487

9,753

$ (552,845) $

(36,174) $

3,495,367

$

22,967

$3,518,334

Balance, December 31,

2017

Transition adjustment of

net unrealized gains on
equity securities

Balance, December 31,
2017, Adjusted

Net income

Other comprehensive loss

Repurchase of common

stock

Share-based

compensation plans:

Stock options exercised

Non-vested shares
awarded, net

Vesting of non-vested

shares

Share-based

compensation

Cash dividends on
common stock

Issuance of shares for
CoBiz acquisition

Capital calls and

distributions, net

Balance, December 31,

2018

—

75,148

—

—

—

54

109

—

—

—

400

—

—

4

—

—

—

—

—

—

—

—

1

—

—

2,709

—

—

(2,709)

—

—

—

1,035,895

3,051,196

9,753

(552,845)

(38,883)

3,495,367

22,967

3,518,334

—

—

—

—

—

(33,702)

445,646

(33,702)

778

—

446,424

(33,702)

—

—

—

2,781

—

—

4,229

445,646

—

—

—

—

—

—

—

(127,188)

616

(53,465)

—

—

31

—

—

—

—

(2,870)

—

—

291,125

— (6,811)

410,185

—

—

—

—

—

—

—

—

—

—

—

—

(53,465)

—

(53,465)

2,781

—

(2,870)

4,229

(127,188)

701,311

—

—

—

—

—

2,781

—

(2,870)

4,229

(127,188)

701,311

—

(12,809)

(12,809)

75,711

$

5

$1,334,030

$3,369,654

3,589

$ (198,995) $

(72,585) $

4,432,109

$

10,936

$4,443,045

See accompanying notes to Consolidated Financial Statements.

82

Consolidated Statements of Cash Flows
(In thousands)

Cash Flows From Operating Activities:
Net income
Adjustments to reconcile net income to net cash provided by (used in) operating activities:

Provision for credit losses
Change in fair value of mortgage servicing rights due to market changes
Change in fair value of mortgage servicing rights due to principal payments
Net unrealized losses from derivative contracts
Share-based compensation
Depreciation and amortization
Net amortization of securities discounts and premiums
Net losses (gains) on financial instruments and other losses(gains), net
Net gain on mortgage loans held for sale
Mortgage loans originated for sale
Proceeds from sale of mortgage loans held for sale
Capitalized mortgage servicing rights
Change in trading and fair value option securities
Change in receivables
Change in other assets
Change in accrued interest, taxes and expense
Change in other liabilities

Net cash provided by (used in) operating activities

Cash Flows From Investing Activities:

Proceeds from maturities or redemptions of investment securities
Proceeds from maturities or redemptions of available for sale securities
Purchases of investment securities
Purchases of available for sale securities
Proceeds from sales of available for sale securities
Change in amount receivable on unsettled available for sale securities transactions
Loans originated, net of principal collected
Net payments on derivative asset contracts
Acquisitions, net of cash acquired
Proceeds from disposition of assets
Purchases of assets

Net cash provided by (used in) investing activities

Cash Flows From Financing Activities:

Net change in demand deposits, transaction deposits and savings accounts
Net change in time deposits
Net change in other borrowed funds
Repayment of subordinated debentures
Issuance of subordinated debentures, net of issuance costs
Change in amount due on unsettled security purchases
Issuance of common and treasury stock, net
Net change in derivative margin accounts
Net payments or proceeds on derivative liability contracts
Repurchase of common stock
Dividends paid

Net cash provided by (used in) financing activities
Net increase (decrease) in cash and cash equivalents
Cash and cash equivalents at beginning of period
Cash and cash equivalents at end of period

Supplemental Cash Flow Information:
Cash paid for interest
Cash paid for taxes
Net loans and bank premises transferred to repossessed real estate and other assets
Increase in U.S. government guaranteed loans eligible for repurchase
Increase in receivables from conveyance of GNMA OREO
See accompanying notes to Consolidated Financial Statements.

83

2018

Year Ended
2017

2016

$

446,424

$

335,685

$

232,281

8,000
(4,668)
33,528
4,686
4,229
60,843
30,945
9,585
(35,705)
(2,587,297)
2,691,144
(35,247)
(1,023,097)
(38,346)
27,507
(5,191)
(139,346)
(552,006)

124,864
1,122,680
(4,468)
(1,955,172)
745,643
38,347
(1,553,033)
(114,417)
(175,755)
308,762
(345,082)
(1,807,631)

(13,870)
(73,089)
1,295,484
—
—
(41,319)
(88)
85,466
114,076
(53,465)
(127,188)
1,186,007
(1,173,630)
2,317,054
1,143,424

243,121
92,291
9,880
100,238
38,216

$

$
$
$
$
$

(7,000)
(172)
33,527
3,704
23,602
54,466
28,693
(2,828)
(47,159)
(3,286,873)
3,405,890
(39,149)
(804,204)
321,880
(5,506)
18,191
182,184
214,931

112,022
1,841,217
(32,972)
(2,845,557)
1,309,215
(68,792)
(78,232)
479,409
—
274,029
(250,783)
739,556

(563,406)
(123,384)
(10,909)
—
—
144,690
4,368
(17,726)
(485,119)
(7,403)
(116,041)
(1,174,930)
(220,443)
2,537,497
2,317,054

127,513
121,697
7,367
148,107
40,528

$

$
$
$
$
$

65,000
2,193
40,744
11,234
10,471
47,016
41,643
(13,011)
(63,636)
(6,117,417)
6,193,587
(71,405)
149,921
(603,861)
(49,565)
44,269
(11,413)
(91,949)

86,847
1,740,226
(41,590)
(2,333,740)
899,381
33,005
(621,605)
(103,668)
56,017
198,922
(199,802)
(286,007)

1,277,285
(216,084)
(606,476)
(226,550)
144,615
(10,389)
12,455
(28,806)
106,051
(66,792)
(113,455)
271,854
(106,102)
2,643,599
2,537,497

82,876
79,883
36,391
120,406
68,873

$

$
$
$
$
$

Notes to Consolidated Financial Statements

(1) Significant Accounting Policies 

Basis of Presentation

The Consolidated Financial Statements of BOK Financial Corporation (“BOK Financial” or “the Company”) have been 
prepared in conformity with accounting principles generally accepted in the United States ("U.S. GAAP"), including 
interpretations of U.S. GAAP issued by federal banking regulators and general practices of the banking industry. The 
Consolidated Financial Statements include the accounts of BOK Financial and its subsidiaries, principally BOKF, NA, CoBiz 
Bank, BOK Financial Securities, Inc., The Milestone Group, Inc. and Cavanal Hill Distributors, Inc. All significant 
intercompany transactions are eliminated in consolidation. 

The Consolidated Financial Statements include the assets, liabilities, non-controlling interests and results of operations of 
variable interest entities (“VIEs”) when BOK Financial is determined to be the primary beneficiary. Variable interest entities 
are generally defined as entities that either do not have sufficient equity to finance their activities without support from other 
parties or whose equity investors lack a controlling financial interest. Determination that the Company is the primary 
beneficiary considers the power to direct the activities that most significantly impact the variable interest's economic 
performance and the obligation to absorb losses of the variable interest or the right to receive benefits of the variable interest 
that could be significant to the variable interest.

Certain prior year amounts have been reclassified to conform to current year presentation. 

Nature of Operations

BOK Financial, through its subsidiaries, provides a wide range of financial services to commercial and industrial customers, 
other financial institutions, municipalities, and consumers. These services include depository and cash management; lending 
and lease financing; mortgage banking; securities brokerage, trading and underwriting; and personal and corporate trust.

BOKF, NA operates as Bank of Oklahoma primarily in the Tulsa and Oklahoma City metropolitan areas of the state of 
Oklahoma and Bank of Texas primarily in the Dallas, Fort Worth and Houston metropolitan areas of the state of Texas. In 
addition, BOKF, NA does business as Bank of Albuquerque in Albuquerque, New Mexico; Colorado State Bank and Trust in 
Denver, Colorado; Bank of Arizona in Phoenix, Arizona; Mobank in Kansas City, Missouri/Kansas and Bank of Arkansas in 
Northwest Arkansas. BOKF, NA also operates the TransFund electronic funds network, Cavanal Hill Investment Management, 
and BOK Financial Asset Management, Inc.

On October 1, 2018, BOK Financial acquired CoBiz Financial, Inc. and CoBiz Bank, its wholly owned subsidiary. CoBiz 
Financial has been merged into BOK Financial. CoBiz Bank will be merged into BOKF, NA in the first quarter of 2019.

Use of Estimates

Preparation of BOK Financial's Consolidated Financial Statements requires management to make estimates of future economic 
activities, including loan collectability, prepayments and cash flows from customer accounts. These estimates are based upon 
current conditions and information available to management. Actual results may differ significantly from these estimates.

Acquisitions

Assets and liabilities acquired, including identifiable intangible assets, are recorded at fair value on the acquisition date. The 
purchase price includes consideration paid at closing and the estimated fair value of contingent consideration that will be paid 
in the future, subject to achieving defined performance criteria. Premiums and discounts assigned to interest-earning assets and 
interest-bearing liabilities are amortized over the lives of the acquired assets and liabilities on either an individual instrument or 
pool basis. Provision for credit losses is recognized for changes in credit quality after the acquisition date. Goodwill is 
recognized as the excess of the purchase price over the net fair value of assets acquired and liabilities assumed. The 
Consolidated Statements of Earnings include the results of operations from the acquisition date.

84

Goodwill and Intangible Assets

Goodwill and intangible assets generally result from business combinations and are evaluated for each of BOK Financial's 
reporting units for impairment annually or more frequently if conditions indicate impairment. The evaluation of possible 
impairment of goodwill and intangible assets involves significant judgment based upon short-term and long-term projections of 
future performance.

Reporting units are defined by the Company as significant lines of business within each operating segment. This definition is 
consistent with the manner in which the chief operating decision maker assesses the performance of the Company and makes 
decisions concerning the allocation of resources. The Company qualitatively assesses whether it is more likely than not that the 
fair value of the reporting units are less than their carrying value, including goodwill. Reporting unit carrying value includes 
sufficient capital to exceed regulatory requirements. This assessment includes consideration of relevant events and 
circumstances including but not limited to macroeconomic conditions, industry and market conditions, the financial and stock 
performance of the Company and other relevant factors.

If the Company concludes based on the qualitative assessment that goodwill may be impaired, a quantitative one-step 
impairment test will be applied to goodwill at all reporting units. The quantitative analysis compares the fair value of the 
reporting unit with its carrying value, including goodwill. The fair value of each reporting unit is estimated by the discounted 
future earnings method. Goodwill is considered impaired if the fair value of the reporting unit is less than the carrying value of 
the reporting unit, including goodwill.

Intangible assets are generally composed of customer relationships, naming rights, non-compete agreements and core deposit 
premiums. They are amortized using accelerated or straight-line methods, as appropriate, over the estimated benefit periods. 
These periods range from 3 years to 20 years. The net book values of identifiable intangible assets are evaluated for impairment 
when economic conditions indicate impairment may exist.

Cash Equivalents

Due from banks, funds sold (generally federal funds sold for one day), resell agreements (which generally mature within one 
day to 30 days) and investments in money market funds are considered cash equivalents.

Securities

Securities are identified as trading, investment (held to maturity) or available for sale at the time of purchase based upon the 
intent of management, liquidity and capital requirements, regulatory limitations and other relevant factors. Trading securities, 
which are acquired for profit through resale, are carried at fair value with unrealized gains and losses included in current period 
earnings. Investment securities are carried at amortized cost. Amortization is computed by methods that approximate level yield 
and is adjusted for changes in prepayment estimates. Securities identified as available for sale are carried at fair value. 
Unrealized gains and losses are recorded, net of deferred income taxes, as accumulated other comprehensive income in 
shareholders' equity. Available for sale securities are separately identified as pledged to creditors if the creditor has the right to 
sell or re-pledge the collateral.

The purchase or sale of securities is recognized on a trade date basis. Realized gains and losses on sales of securities are based 
upon specific identification of the security sold. A receivable or payable is recognized for subsequent transaction 
settlement. Securities meeting certain criteria may also be transferred from the available for sale classification to the investment 
securities portfolio at fair value on the date of transfer. The unrealized gain or loss at the date of transfer is retained in 
accumulated other comprehensive income and in the carrying value of the investment securities portfolio. Such amounts are 
amortized over the estimated remaining life of the security as an adjustment to yield, offsetting the related amortization of the 
premium or accretion of the discount on the transferred securities.

On a quarterly basis, the Company performs separate evaluations of impaired debt investment and available for sale securities  
to determine if the decline in fair value below the amortized cost is other-than-temporary.

85

Management determines whether it intends to sell or if it is more likely than not that it will be required to sell impaired 
securities. This determination considers current and forecasted liquidity requirements and securities portfolio management. If 
the Company intends to sell or it is more likely than not that it will be required to sell the impaired debt security, a charge is 
recognized against earnings for the entire unrealized loss. For all impaired debt securities for which there is no intent or 
expected requirement to sell, the evaluation considers all available evidence to assess whether it is more likely than not that all 
amounts due would not be collected according to the security's contractual terms. Impairment of debt securities rated 
investment grade by nationally-recognized rating agencies is considered temporary unless specific contrary information is 
identified. Impairment of debt securities rated below investment grade by at least one of the nationally recognized rating 
agencies is evaluated based on projections of estimated cash flows. Any expected credit loss due to the inability to collect all 
amounts due according to the security's contractual terms is recognized as a charge against earnings. Any remaining unrealized 
loss related to other factors would be recognized in other comprehensive income, net of taxes.

BOK Financial may elect to carry certain securities at fair value with changes in fair value recognized in current period 
income. These securities are held with the intent that gains or losses will offset changes in the fair value of mortgage servicing 
rights or certain derivative instruments.

Restricted equity securities represent equity interests the Company is required to hold in the Federal Reserve Banks and Federal 
Home Loan Banks. Restricted equity securities are carried at cost as these securities do not have a readily determined fair value 
because ownership of these shares is restricted and they lack a market.

The fair value of our securities portfolio is generally based on a single price for each financial instrument provided to us by a 
third-party pricing service determined by one or more of the following:

•
•
•

•

Quoted prices for similar, but not identical, assets or liabilities in active markets;
Quoted prices for identical or similar assets or liabilities in inactive markets;
Inputs other than quoted prices that are observable, such as interest rate and yield curves, volatilities, prepayment
speeds, loss severities, credit risks and default rates; and
Other inputs derived from or corroborated by observable market inputs.

The underlying methods used by the third-party pricing services are considered in determining the primary inputs used to 
determine fair values. We evaluate the methodologies employed by the third-party pricing services by comparing the price 
provided by the pricing service with other sources, including brokers' quotes, sales or purchases of similar instruments and 
discounted cash flows to establish a basis for reliance on the pricing service values. Significant differences between the pricing 
service provided value and other sources are discussed with the pricing service to understand the basis for their values. Based 
on all observable inputs, management may adjust prices obtained from third-party pricing services to more appropriately reflect 
the prices that would be received to sell assets or paid to transfer liabilities in orderly transactions in the current market. 

Derivative Instruments

Derivative instruments may be used by the Company as part of its internal risk management programs or may be offered to 
customers. All derivative instruments are carried at fair value and changes in fair value are generally reported in income as they 
occur. The determination of fair value of derivative instruments considers changes in interest rates, commodity prices and 
foreign exchange rates. Fair values for exchange-traded contracts are based on quoted prices in an active market for identical 
instruments. Fair values for over-the-counter contracts are generated internally using third-party valuation models. Inputs used 
in third-party valuation models to determine fair values are considered significant other observable inputs. Credit risk is also 
considered in determining fair value. Deterioration in the credit rating of customers or other counterparties reduces the fair 
value of asset contracts. Deterioration of our credit rating could decrease the fair value of our derivative liabilities. 

When bilateral netting agreements or similar agreements exist between the Company and its counterparties that create a single 
legal claim or obligation to pay or receive the net amount in settlement of the individual derivative contracts, the Company 
reports derivative assets and liabilities on a net by derivative contract by counterparty basis.

Derivative contracts may also require the Company to provide or receive cash margin as collateral for derivative assets and 
liabilities. Derivative assets and liabilities are reported net of cash margin when certain conditions are met. In addition, 
derivative contracts executed with customers under Customer Risk Management Programs may be secured by non-cash 
collateral in conjunction with a credit agreement with that customer. Access to collateral in the event of default is reasonably 
assured.

86

Derivative instruments may be designated as cash flow hedges of variable rate assets or liabilities, or of anticipated 
transactions. Changes in the fair value of derivative instruments designated as cash flow hedges are recorded in accumulated 
other comprehensive income to the extent they are effective. The amount recorded in other comprehensive income is 
reclassified to earnings in the same periods as the hedged cash flows impact earnings. The ineffective portion of changes in fair 
value is reported in current earnings.

BOK Financial may use derivative instruments in managing its interest rate sensitivity, as part of its economic hedge of the 
changes in the fair value of mortgage servicing rights and to mitigate the market risk of holding trading securities. Changes in 
the fair value of derivative instruments used in managing interest rate sensitivity and as part of its economic hedge of changes 
in the fair value of mortgage servicing rights are included in Other Operating Revenue - Gain (loss) on derivatives, net in the 
Consolidated Statements of Earnings. Changes in the fair value of derivative instruments used to mitigate the market risk of 
holding trading securities are included in Operating Revenue - Brokerage and trading revenue.

BOK Financial also enters into mortgage loan commitments that are considered derivative contracts. Forward sales contracts 
that have not been designated as hedging instruments are used to economically hedge these mortgage loan commitments as 
well as mortgage loans held for sale. Mortgage loan commitments are carried at fair value based upon quoted prices. Changes 
in the fair value of mortgage loan commitments, mortgage loans held for sale and forward sales contracts are reported in Other 
Operating Revenue - Mortgage banking revenue.

BOK Financial offers programs that permit its customers to manage various risks, including fluctuations in energy, cattle and 
other agricultural products, interest rates and foreign exchange rates with derivative contracts. Customers may also manage 
interest rate risk through interest rate swaps used by the borrower to modify interest rate terms of their loans or to-be-
announced securities used by our mortgage banking customers to hedge their loan production. Derivative contracts are 
executed between the customers and BOK Financial. Offsetting contracts are executed between BOK Financial and other 
selected counterparties to minimize market risk from changes in commodity prices, interest rates or foreign exchange rates. The 
counterparty contracts are identical to customer contracts, except for a fixed pricing spread or fee paid to BOK Financial as 
profit and compensation for administrative costs and credit risk which is recognized over the life of the contracts and included 
in other Operating Revenue - Brokerage and trading revenue in the Consolidated Statements of Earnings.

Loans

Loans are either secured or unsecured based on the type of loan and the financial condition of the borrower. Repayment is 
generally expected from cash flow or proceeds from the sale of selected assets of the borrower. BOK Financial is exposed to 
risk of loss on loans due to the borrower's financial difficulties, which may arise from any number of factors, including 
problems within the respective industry or local economic conditions. Access to collateral, in the event of borrower default, is 
reasonably assured through adherence to applicable lending laws and through sound lending standards and credit review 
procedures. Accounting policies for all loans, excluding residential loans guaranteed by U.S. government agencies, are as 
follows.

Interest is accrued at the applicable interest rate on the outstanding principal amount. Loans are placed on nonaccruing status 
when, in the opinion of management, full collection of principal or interest is uncertain. Internally risk graded loans are 
individually evaluated for nonaccruing status quarterly. Non-risk graded loans are generally placed on nonaccruing status when 
90 days or more past due or within 60 days of being notified of the borrower's bankruptcy filing. Interest previously accrued 
but not collected is charged against interest income when the loan is placed on nonaccruing status. Payments received on 
nonaccruing loans are applied to principal or recognized as interest income, according to management's judgment as to the 
collectability of principal. Loans may be returned to accruing status when, in the opinion of management, full collection of 
principal and interest, including principal previously charged off, is probable based on improvements in the borrower's financial 
condition or a sustained period of performance. 

For loans acquired with no evidence of credit deterioration, discounts are accreted on either an individual basis for loans with 
unique characteristics or on a pool basis for groups of homogeneous loans.  Accretion is discontinued when a loan with an 
individually attributed discount is placed on nonaccruing status.

Loans to borrowers experiencing financial difficulties may be modified in troubled debt restructurings ("TDRs"). All TDRs are 
generally classified as nonaccruing, excluding loans guaranteed by U.S. government agencies. Modifications generally consist 
of extension of payment terms or interest rate concessions and may result either voluntarily through negotiations with the 
borrower or involuntarily through court order. Generally, principal and accrued but unpaid interest is not voluntarily forgiven. 

87

Performing loans may be renewed under the current collateral, debt service ratio and other underwriting standards. 
Nonaccruing loans may also be renewed and will remain classified as nonaccruing.

Occasionally, loans, other than residential mortgage loans, may be held for sale in order to manage credit concentration. These 
loans are carried at the lower of cost or fair value with gains or losses recognized in gain (loss) on assets.  

All loans are charged-off when the loan balance or a portion of the loan balance is no longer supported by the paying capacity 
of the borrower or when the required cash flow is reduced in a TDR. The charge-off amount is determined through an 
evaluation of available cash resources and collateral value. Internally risk graded loans are evaluated quarterly and charge-offs 
are taken in the quarter in which the loss is identified. Non-risk graded loans that are past due between 60 days and 180 days, 
based on the loan product type, are charged off. Loans to borrowers whose personal obligation has been discharged through 
Chapter 7 bankruptcy proceedings are charged off within 60 days of notice of the bankruptcy filing, regardless of payment 
status.

Loan origination and commitment fees and direct loan acquisition and origination costs are deferred and amortized as an 
adjustment to yield over the life of the loan or over the commitment period, as applicable. Amortization does not anticipate loan 
prepayments. Net unamortized fees are recognized in full at time of payoff.

Qualifying residential mortgage loans guaranteed by U.S. government agencies have been sold into GNMA pools. Under 
certain performance conditions specified in government programs, the Company has the right, but not the obligation to 
repurchase loans from GNMA pools. These loans no longer qualify for sale accounting and are recognized in the Consolidated 
Balance Sheets. Guaranteed loans are considered to be impaired because we do not expect to receive all principal and interest 
based on the loan's contractual terms. The principal balance continues to be guaranteed, however, interest accrues at a curtailed 
rate as specified in the programs. The carrying value of these loans is reduced based on an estimate of expected cash flows 
discounted at the original note rate plus a liquidity spread. Guaranteed loans may be modified in TDRs in accordance with U.S. 
government agency guidelines. Interest continues to accrue at the modified rate. Guaranteed loans may either be resold into 
GNMA pools after a performance period specified by the programs or foreclosed and conveyed to the guarantors.

Loans are disaggregated into portfolio segments and further disaggregated into classes. The portfolio segment is the level at 
which the Company develops and documents a systematic method for determining its Allowance for Credit Losses. Classes are 
based on the risk characteristics of the loans and the Company's method for monitoring and assessing credit risk.

Allowance for Loan Losses and Accrual for Off-Balance Sheet Credit Risk

The appropriateness of the allowance for loan losses and accrual for off-balance sheet credit risk (collectively "Allowance for 
Credit Losses") is assessed by management based on an ongoing quarterly evaluation of the probable estimated losses inherent 
in the portfolio, including probable losses on both outstanding loans and unused commitments to provide financing. A 
consistent well-documented methodology has been developed and is applied by an independent Credit Administration 
department to assure consistency across the Company.

The allowance for loan losses consists of specific allowances attributed to impaired loans that have not yet been charged down 
to amounts we expect to recover, general allowances based on estimated loss rates by loan class and nonspecific allowances 
based on factors that affect more than one portfolio segment. There were no changes to the methodology for estimating general 
allowances during 2018 or 2017. 

Loans are considered to be impaired when it becomes probable that BOK Financial will be unable to collect all amounts due 
according to the contractual terms of the loan agreements. Internally risk graded loans are evaluated individually for 
impairment. Substantially all commercial and commercial real estate loans and certain residential mortgage and personal loans 
are risk graded based on a quarterly evaluation of the borrowers' ability to repay. Certain commercial loans and most residential 
mortgage and personal loans are small balance, homogeneous pools of loans that are not risk graded. Non-risk graded loans are 
identified as impaired based on performance status. Generally, non-risk graded loans 90 days or more past due, modified in a 
troubled debt restructuring or in bankruptcy are considered to be impaired.

88

Specific allowances for impaired loans are measured by an evaluation of estimated future cash flows discounted at the loan's 
initial effective interest rate or the fair value of collateral for certain collateral dependent loans. The fair value of real property 
held as collateral is generally based on third party appraisals that conform to Uniform Standards of Professional Appraisal 
Practice, less estimated selling costs. Appraised values are on an “as-is” basis and generally are not adjusted by the 
Company. Updated appraisals are obtained at least annually or more frequently if market conditions indicate collateral values 
may have declined. Collateral value of mineral rights is generally determined by our internal staff of engineers based on 
projected cash flows from proven oil and gas reserves under existing economic and operating conditions. The value of other 
collateral is generally determined by our special assets staff based on projected liquidation cash flows under current market 
conditions. Collateral values and available cash resources that support impaired loans are evaluated quarterly. Historical 
statistics may be used as a practical way to estimate impairment in limited situations, such as when a collateral dependent loan 
is identified as impaired at the end of a reporting period until an appraisal of collateral value is received or a full assessment of 
future cash flows is completed. Estimates of future cash flows and collateral values require significant judgments and may be 
volatile.

General allowances for unimpaired loans are based on an estimated loss rate by loan class. The appropriate historical gross loss 
rate for each loan class is determined by the greater of the current loss rate based on the most recent twelve months or a ten-
year average gross loss rate. Recoveries are not directly considered in the estimation of historical loss rates. Recoveries 
generally do not follow predictable patterns and are not received until well-after the charge-off date as a result of protracted 
legal actions. For risk graded loans, historical gross loss rates are adjusted for changes in risk grading. For each loan class, the 
current weighted average risk grade is compared to the long-term weighted average risk grade. This comparison determines 
whether credit risk in each loan class is increasing or decreasing. Historical loss rates are adjusted upward or downward in 
proportion to changes in average risk grading. General allowances for unimpaired loans also consider inherent risks identified 
for each loan class. Inherent risks consider loss rates that most appropriately represent the current credit cycle and other factors 
attributable to a specific loan class which have not yet been represented in the historical gross loss rates or risk grading. These 
factors include changes in commodity prices or engineering imprecision which may affect the value of reserves that secure our 
energy loan portfolio, construction risk that may affect commercial real estate loans, changes in regulations and public policy 
that may disproportionately impact health care loans and changes in loan products.

Nonspecific allowances are maintained for risks beyond factors specific to a particular portfolio segment or loan class. These 
factors include trends in the economy in our primary lending areas, concentration in large-balance loans and other relevant 
factors. 

An accrual for off-balance sheet credit risk is included in Other liabilities in the Consolidated Balance Sheets. The 
appropriateness of the accrual is determined in the same manner as the allowance for loan losses. 

A provision for credit losses is charged against or credited to earnings in amounts necessary to maintain an appropriate 
Allowance for Credit Losses. Recoveries of loans previously charged off are added to the allowance when received.

Real Estate and Other Repossessed Assets

Real estate and other repossessed assets are acquired in partial or total forgiveness of loans. These assets are initially 
recognized at cost, which is determined by fair value at date of foreclosure less estimated disposal costs. They are subsequently 
carried at the lower of cost or current fair value less estimated disposal costs. Decreases in fair value below cost are recognized 
as asset-specific valuation allowances which may be reversed when supported by future increases in fair value. Subsequent 
increases in fair value may be used to reduce the allowance but not below zero.

Fair values of real estate are based on “as is” appraisals which are updated at least annually or more frequently for certain asset 
types or assets located in certain distressed markets. Fair values based on appraisals are generally considered to be based on 
significant other observable inputs. The Company also considers decreases in listing price and other relevant information in 
quarterly evaluations and reduces the carrying value of real estate and other repossessed assets when necessary. Fair values 
based on list prices and other relevant information are generally considered to be based on significant unobservable inputs. 
Additional costs incurred to complete real estate and other repossessed assets may increase the carrying value, up to current fair 
value based on “as completed” appraisals. The fair value of mineral rights included in repossessed assets are generally 
determined by our internal staff of engineers based on projected cash flows from proven oil and gas reserves under existing 
economic and operating conditions. The value of other repossessed assets is generally determined by our special assets staff 
based on projected liquidation cash flows under current market conditions.

89

Income generated by these assets is recognized as received. Operating expenses are recognized as incurred. Gains or losses on 
sales of real estate and other repossessed assets are based on the cash proceeds received less the cost basis of the asset, net of 
any valuation allowances. The estimated disposal costs of real estate and other repossessed assets are evaluated by the 
Company on an annual basis based on actual results.

Transfers of Financial Assets

BOK Financial regularly transfers financial assets as part of its mortgage banking activities and periodically may transfer other 
financial assets. Transfers are recorded as sales when the criteria for surrender of control are met.  

The Company has elected to carry certain residential mortgage loans held for sale at fair value under the fair value option. 
Changes in fair value are recognized in net income as they occur. These loans are reported separately in the Consolidated 
Balance Sheets and changes in fair value are recorded in Other Operating Revenue - Mortgage banking revenue in the 
Consolidated Statements of Earnings.  

Fair value of conforming residential mortgage loans that will be sold to U.S. government agencies is based on sales 
commitments or market quotes considered Level 2 inputs. Fair value of mortgage loans that are unable to be sold to U.S. 
government agencies is based on Level 3 inputs using quoted prices of loans that are sold in securitization transactions with a 
liquidity discount applied. The fair value is corroborated with an independent third party on at least an annual basis.  
BOK Financial retains a repurchase obligation under underwriting representations and warranties related to residential 
mortgage loans transferred and generally retains the right to service the loans. The Company may incur a recourse obligation in 
limited circumstances. Separate accruals are recognized in Other liabilities in the Consolidated Balance Sheets for repurchase 
and recourse obligations. These reserves reflect the estimated amount of probable loss the Company will incur as a result of 
repurchasing a loan, indemnifications, and other settlement resolutions.  

Repurchases of loans with an origination defect that are also credit impaired are considered collateral dependent and are 
initially recognized at net realizable value (appraised value less the cost to sell). The difference between unpaid principal 
balance and net realizable value is not accreted. Repurchases of loans with an origination defect that are not credit impaired are 
carried at fair value as of the repurchase date. Interest income continues to accrue on these loans and the discount is accreted 
over the estimated life of the loan.

The Company may also choose to purchase GNMA loans once certain mandated delinquency criteria are met. The loans that 
are eligible and are chosen to be repurchased are initially recognized at fair value based on expected cash flow discounted using 
the average agency guaranteed debenture rates, average actual principal loss rates and liquidity premium.

Mortgage Servicing Rights

Mortgage servicing rights may be purchased or may be recognized when mortgage loans are originated and sold with servicing 
rights retained. All mortgage servicing rights are carried at fair value. Changes in the fair value are recognized in earnings as 
they occur.

Mortgage servicing rights are not traded in active markets. A cash flow model is used to determine fair value. Key assumptions 
and estimates, including projected prepayment speeds and assumed servicing costs, earnings on escrow deposits, ancillary 
income and discount rates, used by this model are based on current market sources. Assumptions used to value mortgage 
servicing rights are considered significant unobservable inputs. A separate third-party model is used to estimate prepayment 
speeds based on interest rates, housing turnover rates, estimated loan curtailment, anticipated defaults and other relevant 
factors. The prepayment model is updated daily for changes in market conditions and adjusted to better correlate with actual 
performance of BOK Financial's servicing portfolio. Fair value estimates from outside sources are received at least annually to 
corroborate the results of the valuation model.

90

Premises and Equipment

Premises and equipment are carried at cost, including capitalized interest when appropriate, less accumulated depreciation and 
amortization. Depreciation and amortization are computed on a straight-line basis over the estimated useful lives of the assets 
or, for leasehold improvements, over the shorter of the estimated useful lives or remaining lease terms. Useful lives range from 
5 years to 40 years for buildings and improvements, 3 years to 10 years for software and related implementation costs, and 3 
years to 10 years for furniture and equipment. Construction in progress represents facilities construction and data processing 
systems projects underway that have not yet been placed into service. Depreciation and amortization begin once the assets are 
placed into service. 

Repair and maintenance costs, including software maintenance and enhancement costs, are charged to expense as incurred. 
Software licensing costs are generally charged to expense as incurred. Software licensing costs are capitalized if the contractual 
right to take possession of the software exists and it is feasible to take possession without significant penalty. Capitalized costs 
are amortized over the shorter of the estimated useful life of the software or remaining contractual life of the license.

Premises no longer used by the Company are transferred to real estate and other repossessed assets. The transferred amount is 
the lower of cost less accumulated depreciation or fair value less estimated disposal costs as of the transfer date.

Rent expense for leased premises is recognized as incurred over the lease term. The effects of rent holidays, significant rent 
escalations and other adjustments to rent payments are recognized on a straight-line basis over the lease term.

Ongoing technology projects of significant size or length are reviewed at least annually for impairment. Accumulated costs are 
reviewed for projects or components of projects that do not support the value of the asset being developed. Findings of 
obsolescence, duplicate effort or other conditions that do not support the recorded value are impaired, with the cost of the 
impaired components being charged to current-year earnings.

Federal and State Income Taxes

BOK Financial and its subsidiaries file consolidated tax returns. The subsidiaries provide for income taxes on a separate return 
basis and remit to BOK Financial amounts determined to be currently payable. BOK Financial is agent for its subsidiaries 
under the Company's tax sharing agreements and has no ownership rights to any refunds received for the benefit of its 
subsidiaries. 

Current income tax expense or benefit is based on an evaluation that considers estimated taxable income, tax credits, and 
statutory federal and state income tax rates. The amount of current income tax expense or benefit recognized in any period may 
differ from amounts reported to taxing authorities. Annually, tax returns are filed with each jurisdiction where the Company 
conducts business and recognized current income tax expense or benefit is adjusted to the filed tax returns.

Deferred tax assets and liabilities are based upon the temporary differences between the values of assets and liabilities as 
recognized in the financial statements and their related tax basis using enacted tax rates in effect for the year in which the 
differences are expected to be recovered or settled. The effect of changes in statutory tax rates on the measurement of deferred 
tax assets and liabilities is recognized through income tax expense in the period the change is enacted. A valuation allowance is 
provided when it is more likely than not that some portion of the entire deferred tax asset may not be realized.  

BOK Financial has unrecognized tax benefits, which are included in accrued current income taxes payable, for the uncertain 
portion of recorded tax benefits and related interest. These uncertainties result from the application of complex tax laws, rules, 
regulations and interpretations, primarily in state taxing jurisdictions. Unrecognized tax benefits are assessed quarterly and may 
be adjusted through current income tax expense in future periods based on changing facts and circumstances, completion of 
examinations by taxing authorities or expiration of a statute of limitations. Estimated penalties and interest on uncertain tax 
positions are recognized in income tax expense.

91

Employee Benefit Plans

BOK Financial sponsors a defined contribution plan (“Thrift Plan”) and a defined benefit cash balance pension plan (“Pension 
Plan”). Employer contributions to the Thrift Plan, which matches employee contributions subject to percentage and years of 
service limits, are expensed when incurred. Pension Plan costs, which are based upon actuarial computations of current costs, 
are expensed annually.  Pension Plan benefits were curtailed as of April 1, 2006. No participants may be added to the Pension 
Plan and no additional service benefits will be accrued. BOK Financial recognizes the funded status of its employee benefit 
plans.  Adjustments required to recognize the Pension Plan's net funded status are made through accumulated other 
comprehensive income, net of deferred income taxes.

Share-Based Compensation Plans

BOK Financial awards stock options and non-vested common shares as compensation to certain officers. Compensation cost is 
generally fixed based on the grant date fair value of the award. The grant date fair value of stock options is based on the Black-
Scholes option pricing model. Stock options generally have graded vesting over 7 years. Each tranche is considered a separate 
award for valuation and compensation cost recognition. Grant date fair value of non-vested shares is based on the then-current 
market value of BOK Financial common stock. Non-vested shares generally cliff vest in 3 years and are subject to a holding 
period after vesting of 2 years. Compensation cost of non-vested shares granted under the Executive Incentive Plan varies 
based on changes in the fair value of BOKF common shares.   

Compensation cost is recognized as expense over the service period, which is generally the vesting period. Expense is reduced 
for estimated forfeitures over the vesting period and adjusted for actual forfeitures as they occur. Stock-based compensation 
awarded to certain officers has performance conditions that affect the number of awards granted. Compensation cost is adjusted 
based on the probable outcome of the performance conditions. 

Tax effects of share-based payments are recognized through tax expense. Dividends on non-vested shares that are not subject to 
forfeiture are charged to retained earnings. 

Other Operating Revenue

Fees and commissions revenue is generated through the sales of products, consisting primarily of financial instruments, and the 
performance of services for customers under contractual obligations. Revenue from providing services for customers is 
recognized at the time services are provided in an amount that reflects the consideration we expect to be entitled to for those 
services. Revenue is recognized based on the application of five steps:
•
•
•
•
•

Identify the contract with a customer
Identify the performance obligations in the contract
Determine the transaction price
Allocate the transaction price to the performance obligations in the contract
Recognize revenue when (or as) the Company satisfies a performance obligation

For contracts with multiple performance obligations, individual performance obligations are accounted for separately if the 
customer can benefit from the good or service on its own or with other resources readily available to the customer and the 
promise to transfer goods and services to the customer is separately identifiable in the contract. The transaction price is 
allocated to the performance obligations based on relative standalone selling prices.  

Revenue is recognized on a gross basis whenever we have primary responsibility and risk in providing the services or products 
to our customers and have discretion in establishing the price for the services or products. Revenue is recognized on a net basis 
whenever we act as an agent for products or services of others.

92

Brokerage and trading revenue includes revenues from trading, customer hedging, retail brokerage and investment banking. 
Trading revenue includes net realized and unrealized gains primarily related to sales of securities to institutional customers and 
related derivative contracts. Customer hedging revenue includes realized and unrealized changes in the fair value of derivative 
contracts held for customer risk management programs including credit valuation adjustments, as necessary. We offer 
commodity, interest rate, foreign exchange and equity derivatives to our customers. These customer contracts are offset with 
contracts with selected counterparties and exchanges to minimize changes in market risk from changes in commodity prices, 
interest rates or foreign exchange rates. Retail brokerage revenue represents fees and commissions earned on sales of fixed 
income securities, annuities, mutual funds and other financial instruments to retail customers. Investment banking revenue 
includes fees earned upon completion of underwriting and financial advisory services. Investment banking revenue also 
includes fees earned in conjunction with loan syndications. 

Transaction card revenue includes merchant discount fees and electronic funds transfer network fees, net of interchange fees 
paid to card issuers and assessments paid to card networks. Merchant discount fees represent fees paid by customers for 
account management and electronic processing of card transactions. Merchant discount fees are recognized at the time the 
customer’s transactions are processed or other services are performed. The Company also maintains the TransFund electronic 
funds transfer network for the benefit of its members, which includes the BOKF, NA. Electronic funds transfer fees are 
recognized as electronic transactions processed on behalf of its members. 

Fiduciary and asset management revenue includes fees from asset management, custody, recordkeeping, investment advisory 
and administration services. Revenue is recognized on an accrual basis at the time the services are performed and may be based 
on either the fair value of the account or the service provided.

Deposit service charges and fees include commercial account service charges, overdraft fees, check card fee revenue and 
automated service charge and other deposit service fees. Fees are recognized at least quarterly in accordance with published 
deposit account agreements and disclosure statements for retail accounts or contractual agreements for commercial 
accounts. Item charges for overdraft or non-sufficient funds items are recognized as items are presented for payment. Account 
balance charges and activity fees are accrued monthly and collected in arrears. Commercial account activity fees may be offset 
by an earnings credit based on account balances. Check card fees represent interchange fees paid by a merchant bank for 
transactions processed from cards issued by the Company. Check card fees are recognized when transactions are processed.   

Mortgage banking revenue includes revenues recognized in conjunction with the origination, marketing and servicing of 
conventional and government-sponsored residential mortgage loans. Mortgage production revenue includes net realized gains 
(losses) on sales of residential mortgage loans in the secondary market and the net change in unrealized gains (losses) on 
residential mortgage loans held for sale. Mortgage production revenue also includes changes in the fair value of derivative 
contracts not designated as hedging instruments related to residential mortgage loan commitments and forward sales contracts. 
Mortgage servicing revenue includes servicing fee income and late charges on loans serviced for others.  

Newly Adopted and Pending Accounting Pronouncements

The following is a summary of newly adopted and pending accounting pronouncements that may have a more than 
insignificant effect on the Company's financial statements. 

Financial Accounting Standards Board ("FASB")

FASB Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers ("ASU 2014-09")

On May 28, 2014, the FASB issued ASU 2014-09 to clarify the principles for recognizing revenue by providing a more robust 
framework that will give greater consistency and comparability in revenue recognition practices. In the new framework, an 
entity recognizes revenue in an amount that reflects the consideration to which the entity expects to be entitled in exchange for 
goods or services. The new model requires the identification of performance obligations included in contracts with customers, a 
determination of the transaction price and an allocation of the price to those performance obligations. The entity recognizes 
revenue when performance obligations are satisfied. Revenue from financial assets and liabilities is explicitly excluded from 
the scope of ASU 2014-09. Management adopted the standard in the first quarter of 2018 using the modified retrospective 
transition method. There were no significant cumulative effect adjustments as a result of implementation as of January 1, 2018 
as our current revenue recognition policies generally conformed with the principals in ASU 2014-09.

93

FASB Accounting Standards Update No. 2016-08, Revenue from Contracts with Customers (Topic 606): Principal versus Agent 
Considerations (Reporting Revenue Gross versus Net) ("ASU 2016-08")

On March 17, 2016, the FASB Issued ASU 2016-08 to amend the principal versus agent implementation guidance in ASU 
2014-09. The ASU clarifies that an entity should evaluate whether it is the principal or the agent for each specified good or 
service promised in a contract with a customer. Management adopted the standard in the first quarter of 2018. Interchange fees 
paid to issuing banks for card transactions processed related to its merchant processing services previously included in data 
processing and communication expense are now netted against the amounts charged to the merchant in transaction card 
processing revenue. 

FASB Accounting Standards Update No. 2016-01, Financial Instruments - Overall (Subtopic 825-10): Recognition and 
Measurement of Financial Assets and Financial Liabilities ("ASU 2016-01")

On January 5, 2016, the FASB issued ASU 2016-01 over the recognition and measurement of financial assets and liabilities. 
The update requires equity investments, in general, to be measured at fair value with changes in fair value recognized in 
earnings. It also eliminates the requirement to disclose the methods and significant assumptions used to estimate the fair value 
for financial instruments measured at amortized cost, requires entities to use the exit price notion when measuring fair value, 
requires an entity to present separately in other comprehensive income the portion of the total change in fair value of a liability 
resulting from a change in the instrument-specific credit risk when the fair value option has been elected, requires separate 
presentation of financial assets and liabilities by measurement category and form on the balance sheet or accompanying notes, 
clarifies that an entity should evaluate the need for a valuation allowance on a deferred tax asset related to available-for-sale 
securities in combination with the entity's other deferred tax assets, and simplifies the impairment assessment of equity 
investments without readily determinable fair values. Management adopted the standard in the first quarter of 2018. Upon 
adoption, net unrealized gains of $2.7 million from equity securities were reclassified from other comprehensive income to 
retained earnings. 

FASB Accounting Standards Update No. 2016-02, Leases (Topic 842) ("ASU 2016-02")

On February 25, 2016, the FASB issued ASU 2016-02 to increase transparency and comparability by recognizing lease assets 
and liabilities on the balance sheet and disclosing key information about leasing arrangements. Lessees will be required to 
recognize an obligation for future lease payments measured on a discounted basis and a right-of-use asset. The ASU is effective 
for the Company for interim and annual periods beginning after December 15, 2018.  As originally issued, ASU 2016-02 
required implementation through the modified transition method applied as of the earliest period presented in the financial 
statements.  In 2018 an additional and optional transition method that allows entities to apply the standard as of the adoption 
date was approved.  BOKF elected this optional transition method.  BOKF elected all practical expedients other than the 
lessee's practical expedient to combine lease and non-lease components which would further gross up the lease liability and 
related right of use asset. The implementation of ASU 2016-02 increased the reported right of use assets and liabilities by 
approximately $137 million. The effect on retained earnings was immaterial. 

FASB Accounting Standards Update No. 2016-13, Financial Instruments - Credit Losses (Topic 326): Assets Measured at 
Amortized Cost ("ASU 2016-13")

On June 16, 2016, the FASB issued ASU 2016-13 in order to provide more timely recording of credit losses on loans and other 
financial instruments. The ASU adds an impairment model (known as the current expected credit loss ("CECL") model) that is 
based on expected credit losses rather than incurred credit losses. It requires measurement of all expected credit losses for 
financial assets carried at amortized cost, including loans and related off-balance sheet credit exposure and investment 
securities, based on historical experience, current conditions, and reasonable and supportable forecasts. ASU 2016-13 also 
changes the recognition of other-than-temporary impairment of available for sale securities to an allowance methodology from 
a direct write-down methodology. ASU 2016-13 will be effective for the Company for annual reporting periods beginning after 
December 15, 2019, including interim periods within those fiscal years. Early adoption is permitted for annual reporting 
periods beginning after December 15, 2018. ASU 2016-13 will be applied through a cumulative-effect adjustment to retained 
earnings as of the beginning of the first reporting period in which the guidance is effective. 

94

The Company has established a CECL implementation team in order to evaluate the impact the adoption of ASU 2016-13 will 
have on the Company's financial statements.  The CECL implementation team, overseen by the Chief Credit Officer, Chief 
Financial Officer, and Chief Risk Officer, has developed a project plan that incorporates input from various departments within 
the bank including Credit, Financial Reporting, Risk, and Information Technology among others.  Key implementation 
activities for 2018 included portfolio segmentation, credit risk driver identification, model development, as well as process and 
information systems enhancements. Key implementation initiatives for 2019 include model validation and development of 
governance and control and disclosure frameworks. The Company will adopt the standard on January 1, 2020.

FASB Accounting Standards Update No. 2016-15, Statement of Cash Flows (Topic 230): Classification of Certain Cash 
Receipts and Cash Payments ("ASU 2016-15")

On August 26, 2016, the FASB issued ASU 2016-15, which amends guidance in ASC 230 on the classification of certain cash 
receipts and payments in the statement of cash flows. The amendments address eight cash flow issues. Management adopted 
the standard in first quarter of 2018. Adoption of ASU 2016-15 did not have a material impact on the Company's financial 
statements.

FASB Accounting Standards Update No. 2017-12, Derivatives and Hedging (Topic 815): Targeted Improvements to Accounting 
for Hedging Activities ("ASU 2017-12")

On August 28, 2017, the FASB issued ASU 2017-12, which amends the hedge accounting recognition and presentation 
requirements in ASC 815 in order to improve transparency and understandability of information and reduce the complexity. 
The update expands the types of transactions eligible for hedge accounting, eliminates the requirement to separately measure 
and present hedge ineffectiveness, simplifies hedge effectiveness assessments and updates documentation and presentation 
requirements. The update allows the reclassification of certain debt securities from held to maturity to available for sale if the 
debt security is eligible to be hedged under the last-of-layer method. ASU 2017-12 is effective for the Company for fiscal years 
beginning after December 15, 2018, and interim periods therein; however, early adoption was permitted. Adoption of ASU 
2017-12 had no material impact on the Company's financial statements.  

FASB Accounting Standards Update No. 2018-05, Income Taxes (Topic 740): Amendments to SEC Paragraphs Pursuant to 
SEC Staff Accounting Bulletin No. 118 (SAB 118).

On March 13, 2018, the FASB issued ASU 2018-05, which adds SEC guidance related to SAB 118 - Income Tax Accounting 
Implications of the Tax Cuts and Jobs Act. ASU 2018-05 was effective upon issuance. The adoption of ASU 2018-05 has not 
had a significant impact in 2018. 

FASB Accounting Standards Update No. 2018-15, Intangibles - Goodwill and Other Internal-Use Software (Subtopic 350-40): 
Customer's Accounting for Implementation Costs Incurred in a Cloud Computing Arrangement that is a Service Contract 
("ASU 2018-15")

On August 29, 2018, the FASB issued ASU 2018-15, which requires a customer in a cloud hosting arrangement that is a service 
contract to follow the internal use software requirements in ASC 350-40 to determine which implementation costs to capitalize 
or expense as incurred. Internal use software guidance requires the capitalization of costs incurred during the development 
phase. Capitalized costs will be amortized over the term of the hosting arrangement beginning when the arrangement is ready 
for its intended use. ASU 2018-15 is effective for the Company for fiscal years beginning after December 15, 2019; however, 
early adoption is permitted. The Company elected to early adopt the update prospectively in third quarter of 2018. The adoption 
of ASU 2018-15 has not had a significant impact in 2018.

95

(2) Securities 

Trading Securities

The fair value and net unrealized gain (loss) included in trading securities is as follows (in thousands):

December 31, 2018

December 31, 2017

Fair Value

Net
Unrealized
Gain (Loss)

Fair Value

Net
Unrealized
Gain (Loss)

U.S. government agency debentures

$

63,765

$

254

$

21,196

$

U.S. government agency residential mortgage-backed securities

1,791,584

9,966

392,673

34,507

42,656

24,411

(1)

685

65

13,559

23,885

11,363

$

1,956,923

$

10,969

$

462,676

$

(448)

8

(517)

83

(26)

4

Municipal and other tax-exempt securities

Asset-backed securities

Other trading securities

Total trading securities

Investment Securities

The amortized cost and fair values of investment securities are as follows (in thousands):

December 31, 2018

Amortized

Cost

Fair

Value

Gross Unrealized

Gain

Loss

Municipal and other tax-exempt securities

$

137,296

$

138,562

$

1,858

$

U.S. government agency residential mortgage-backed securities

Other debt securities

Total investment securities

12,612

205,279

12,770

215,966

293

12,257

$

355,187

$

367,298

$

14,408

$

(592)

(135)

(1,570)

(2,297)

Municipal and other tax-exempt securities

$

228,186

$

230,349

$

2,967

$

U.S. government agency residential mortgage-backed securities

Other debt securities

Total investment securities

15,891

217,716

16,242

233,444

446

17,095

$

461,793

$

480,035

$

20,508

$

(804)

(95)

(1,367)

(2,266)

December 31, 2017

Amortized

Cost

Fair

Value

Gross Unrealized

Gain

Loss

96

The amortized cost and fair values of investment securities at December 31, 2018, by contractual maturity, are as shown in the 
following table (dollars in thousands):

Municipal and other tax-exempt securities:

Carrying value

Fair value

Nominal yield¹

Other debt securities:

Carrying value

Fair value

Nominal yield

Total fixed maturity securities:

Carrying value

Fair value

Nominal yield

Residential mortgage-backed securities:

Carrying value

Fair value
Nominal yield4

Total investment securities:

Carrying value

Fair value

Nominal yield

Less than
One Year

One to
Five Years

Six to
Ten Years

Over
Ten Years

Total

Weighted
Average
Maturity²

$

$

$

$

$

41,475

41,371

2.25%

16,282

16,327

$

46,363

46,123

$

35,077

36,471

14,381

14,597

$

137,296

138,562

3.94%

6.00%

4.32%

4.00%

61,830

63,923

$

115,606

$

125,050

11,561

10,666

$

205,279

215,966

3.88%

4.69%

5.76%

4.33%

5.21%

57,757

57,698

$

108,193

$

150,683

$

110,046

161,521

25,942

25,263

$

342,575

354,528

2.71%

4.37%

5.82%

4.32%

4.73%

4.73

5.50

5.19

$

³

12,612

12,770

2.77%

$

355,187

367,298

4.65%

1  Calculated on a taxable equivalent basis using a 25 percent effective tax rate.
2  Expected maturities may differ from contractual maturities because borrowers may have the right to call or prepay obligations with or without 

penalty.

3  The average expected lives of residential mortgage-backed securities were 4.7 years based upon current prepayment assumptions.
4  The nominal yield on residential mortgage-backed securities is based upon prepayment assumptions at the purchase date. Actual yields earned may 
differ significantly based upon actual prepayments. See Quarterly Financial Summary - Unaudited for current yields on the investment securities 
portfolio.

97

Available for Sale Securities 

The amortized cost and fair value of available for sale securities are as follows (in thousands):

U.S. Treasury securities

Municipal and other tax-exempt securities

Residential mortgage-backed securities:

U.S. government agencies:

FNMA

FHLMC

GNMA

Total U.S. government agencies

Private issue

Total residential mortgage-backed securities

Commercial mortgage-backed securities guaranteed by U.S.

government agencies

Other debt securities

Amortized

Cost

Fair

Value

December 31, 2018

Gross Unrealized

Gain

Loss

OTTI

$

496

$

493

$

2,782

2,864

— $

82

(3) $

—

3,414,573

1,723,399

748,351

3,367,124

1,699,779

737,805

5,886,323

5,804,708

40,948

59,736

5,927,271

5,864,444

2,986,297

2,953,889

35,545

35,430

10,559

5,189

401

16,149

18,788

34,937

7,955

12

(58,008)

(28,809)

(10,947)

(97,764)

—

(97,764)

(40,363)

(127)

Total available for sale securities

$ 8,952,391

$

8,857,120

$

42,986

$

(138,257) $

U.S. Treasury securities

Municipal and other tax-exempt securities

Residential mortgage-backed securities:

U.S. government agencies:

FNMA

FHLMC

GNMA

Total U.S. government agencies

Private issue

Total residential mortgage-backed securities

Commercial mortgage-backed securities guaranteed by U.S.

government agencies

Other debt securities

Perpetual preferred stock

Equity securities and mutual funds

Total available for sale securities

Amortized

Cost

Fair

Value

December 31, 2017

Gross Unrealized

Gain

Loss

OTTI

$

1,000

$

1,000

$

27,182

27,080

— $

181

— $

(283)

3,021,551

1,545,971

787,626

2,997,563

1,531,009

780,580

5,355,148

5,309,152

74,311

93,221

5,429,459

5,402,373

2,858,885

2,834,961

25,500

12,562

14,487

25,481

15,767

14,916

11,549

3,148

1,607

16,304

19,301

35,605

1,963

50

3,205

515

(35,537)

(18,110)

(8,653)

(62,300)

—

(62,300)

(25,887)

(69)

—

(86)

$

8,369,075

$

8,321,578

$

41,519

$

(88,625) $

(391)

98

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

(391)

(391)

—

—

—

—

The amortized cost and fair values of available for sale securities at December 31, 2018, by contractual maturity, are as shown in the 
following table (dollars in thousands): 

Less than
One Year

One to
Five Years

Six to
Ten Years

Over
Ten Years

Total

Weighted
Average
Maturity4

$

$

$

$

$

U.S. Treasury securities:

Amortized cost

Fair value

Nominal yield

Municipal and other tax-exempt securities:

Amortized cost

Fair value

Nominal yield¹

Commercial mortgage-backed securities:

Amortized cost

Fair value

Nominal yield

Other debt securities:

Amortized cost

Fair value

Nominal yield

Total fixed maturity securities:

Amortized cost

Fair value

Nominal yield

Residential mortgage-backed securities:

Amortized cost

Fair value
Nominal yield3

Total available-for-sale securities:

Amortized cost

Fair value

Nominal yield

— $

—

—%

496

493

1.99%

$

1,057

1,063

1,725

1,801

6.69%

6.45%

$

$

— $

—

—%

— $

—

—%

$

—

—

—%

—

—

—%

496

493

1.99%

2,782

2,864

6.54%

77,558

76,902

$ 1,107,567

$ 1,497,468

$

303,704

1,088,991

1,486,939

301,057

2,986,297

2,953,889

1.66%

2.06%

2.44%

2.54%

2.29%

— $

— $

— $

—

—%

—

—%

—

—%

35,545

35,430

1.94% 5

35,545

35,430

1.94%

1.08

1.67

6.90

13.61

78,615

77,965

$ 1,109,788

$ 1,497,468

$

339,249

$

3,025,120

6.98

1,091,285

1,486,939

336,487

2,992,676

1.73%

2.07%

2.44%

2.48%

2.29%

$

5,927,271

2

5,864,444

2.41%

$

8,952,391

8,857,120

2.37%

1  Calculated on a taxable equivalent basis using a 25 percent effective tax rate.
2  The average expected lives of mortgage-backed securities were 4.1 years based upon current prepayment assumptions.
3  The nominal yield on mortgage-backed securities is based upon prepayment assumptions at the purchase date. Actual yields earned may differ 
significantly based upon actual prepayments. See Quarterly Financial Summary –– Unaudited following for current yields on available for sale 
securities portfolio.

4  Expected maturities may differ from contractual maturities, because borrowers may have the right to call or prepay obligations with or without 

penalty.

5  Nominal yield on other debt securities with contractual maturity dates over ten years are based on variable rates which generally are reset within 

35 days. 

Sales of available for sale securities resulted in gains and losses as follows (in thousands):

Proceeds

Gross realized gains

Gross realized losses

Related federal and state income tax expense

99

Year Ended December 31,

2018

2017

2016

$

745,643

$

1,309,215

$

899,381

7,117

(9,918)

(713)

10,223

(5,795)

1,722

11,696

(21)

4,542

The fair value of debt securities pledged as collateral for repurchase agreements, public trust funds on deposit and for other purposes, 
as required by law was $9.1 billion at December 31, 2018 and $7.3 billion at December 31, 2017. 

The secured parties do not have the right to sell or re-pledge these securities. 

Temporarily Impaired Securities as of December 31, 2018 
(In thousands)

Number
of
Securities

Less Than 12 Months

12 Months or Longer

Total

Fair
Value

Unrealized
Loss

Fair
Value

Unrealized
Loss

Fair
Value

Unrealized
Loss

72

$

18,255

$

69

$

66,141

$

523

$

84,396

$

592

2

72

—

13,372

—

64

5,633

23,028

135

1,506

5,633

36,400

146

$

31,627

$

133

$

94,802

$

2,164

$

126,429

$

135

1,570

2,297

Number
of
Securities

Less Than 12 Months

12 Months or Longer

Total

Fair
Value

Unrealized
Loss

Fair
Value

Unrealized
Loss

Fair
Value

Unrealized
Loss

1

$

— $

— $

493

$

3

$

493

$

—

—

—

—

—

—

161,089

71,205

278,530

510,824

—

542

328

288

2,135,377

1,129,730

376,263

1,158

3,641,370

—

—

57,466

28,481

10,659

96,606

—

2,296,466

1,200,935

654,793

4,152,194

—

510,824

1,158

3,641,370

96,606

4,152,194

97,764

Investment:

Municipal and other tax-exempt

securities

U.S. government agency residential

mortgage-backed securities – Other

Other debt securities

Total investment securities

Available for sale:

U.S. Treasury securities

Municipal and other tax-exempt

securities

Residential mortgage-backed

securities:

U.S. government agencies:

FNMA

FHLMC

GNMA

Total U.S. agencies
Private issue1

Total residential mortgage-backed

securities

Commercial mortgage-backed securities

guaranteed by U.S. government
agencies

Other debt securities

162

85

42

289

—

289

197

3

179,258

9,982

394

63

1,969,504

39,969

2,148,762

20,436

64

30,418

Total available for sale securities
1  Includes securities for which an unrealized loss remains in AOCI after an other-than-temporary credit loss has been recognized in income.

$ 5,631,803

$ 6,331,867

700,064

136,642

1,615

490

$

$

$

$

100

3

—

58,008

28,809

10,947

97,764

—

40,363

127

138,257

Temporarily Impaired Securities as of December 31, 2017 
(In thousands)

Number
of
Securities

Less Than 12 Months

12 Months or Longer

Total

Fair
Value

Unrealized
Loss

Fair
Value

Unrealized
Loss

Fair
Value

Unrealized
Loss

Investment:

Municipal and other tax- exempt

securities

U.S. government agency residential

mortgage-backed securities – Other

Other debt securities

Total investment securities

100

$

145,960

$

643

$

5,833

$

161

$

151,793

$

804

1

49

—

20,091

—

1,238

3,356

3,076

150

$

166,051

$

1,881

$

12,265

$

95

129

385

3,356

23,167

$

178,316

$

95

1,367

2,266

Number
of
Securities

Less Than 12 Months

12 Months or Longer

Total

Fair
Value

Unrealized
Loss

Fair
Value

Unrealized
Loss

Fair
Value

Unrealized
Loss

— $

— $

— $

— $

— $

— $

19

12,765

18

4,802

265

17,567

113

69

27

209

8

1,203,041

863,778

201,887

9,618

7,297

1,452

824,029

385,816

248,742

2,268,706

18,367

1,458,587

5,898

391

—

25,919

10,813

7,201

43,933

—

2,027,070

1,249,594

450,629

3,727,293

5,898

—

283

35,537

18,110

8,653

62,300

391

217

2,274,604

18,758

1,458,587

43,933

3,733,191

62,691

Available for sale:

U.S. Treasury securities

Municipal and other tax-exempt

securities

Residential mortgage-backed

securities:

U. S. government agencies:

FNMA

FHLMC

GNMA

Total U.S. agencies
Private issue1

Total residential mortgage-backed

securities

Commercial mortgage-backed

securities guaranteed by U.S.
government agencies

Other debt securities

Perpetual preferred stock

Equity securities and mutual funds

185

2

—

111

1,465,703

19,959

—

911

11,824

652,296

14,063

2,117,999

25,887

41

—

7

472

—

2,203

28

—

79

20,431

—

3,114

69

—

86

89,016

Total available for sale securities
1  Includes securities for which an unrealized loss remains in AOCI after an other-than-temporary credit loss has been recognized in income.

$ 5,892,302

$ 2,118,360

$ 3,773,942

30,648

58,368

534

$

$

$

Based on evaluations of impaired securities as of December 31, 2018, the Company does not intend to sell any impaired available for 
sale securities before fair value recovers to the current amortized cost and it is more-likely-than-not that the Company will not be 
required to sell impaired securities before fair value recovers, which may be maturity. 

No other-than-temporary impairment losses were recorded in earnings during 2018 and none were recorded in 2017. Cumulative 
other-than-temporary impairment on available for sale securities was $45 million at December 31, 2018 and $55 million at 
December 31, 2017. The decrease compared to the prior year was due to sales during 2018.

101

Fair Value Option Securities

Fair value option securities represent securities which the Company has elected to carry at fair value and are separately identified on 
the Consolidated Balance Sheets with changes in the fair value recognized in earnings as they occur. Certain residential mortgage-
backed securities issued by U.S. government agencies and derivative contracts are held as an economic hedge of the mortgage 
servicing rights. 

The fair value and net unrealized gain (loss) included in Fair value option securities is as follows (in thousands):

U.S. government agency residential mortgage-backed securities

$

283,235

$

2,766

$

755,054

$

(1,877)

December 31, 2018

December 31, 2017

Fair Value

Net
Unrealized
Gain (Loss)

Fair Value

Net
Unrealized
Gain (Loss)

102

(3) Derivatives 

The following table summarizes the fair values of derivative contracts recorded as “derivative contracts” assets and liabilities in 
the balance sheet at December 31, 2018 (in thousands):

Assets

Notional1

Gross
Fair
Value

Netting
Adjustments

Net Fair
Value
Before
Cash
Collateral

Cash
Collateral

Fair Value
Net of Cash
Collateral

Customer risk management programs:

Interest rate contracts

To-be-announced residential mortgage-

backed securities

Interest rate swaps

Energy contracts

Agricultural contracts

Foreign exchange contracts

Equity option contracts

$ 10,671,151

$ 92,231

$

(26,787) $

65,444

$

— $

1,924,131

36,112

(6,688)

29,424

(7,934)

1,472,209

206,418

(60,983)

145,435

(106,752)

21,210

842

184,990

183,759

89,085

2,021

(201)

—

—

641

183,759

2,021

—

—

(648)

(94,659)

(40,871)

426,724

(115,334)

9,539

—

65,444

21,490

38,683

641

183,759

1,373

311,390

9,539

Total customer risk management programs

14,362,776

521,383

Internal risk management programs

15,909,988

50,410

Total derivative contracts

$ 30,272,764

$ 571,793

$

(135,530) $ 436,263

$ (115,334) $

320,929

Customer risk management programs:

Interest rate contracts

To-be-announced residential mortgage-

backed securities

Interest rate swaps

Energy contracts

Agricultural contracts

Foreign exchange contracts

Equity option contracts

Liabilities

Notional¹

Gross
Fair
Value

Netting
Adjustments

Net Fair
Value
Before
Cash
Collateral

Cash
Collateral

Fair Value
Net of Cash
Collateral

$ 10,558,151

$ 90,388

$

(26,787) $

63,601

$ (63,596) $

5

1,924,131

36,288

(6,688)

29,600

1,434,247

202,494

(60,983)

141,511

21,214

812

177,423

175,922

89,085

2,021

(201)

—

—

(94,659)

(40,871)

611

175,922

2,021

413,266

25,551

(4,110)

(1,490)

—

—

—

(69,196)

(7,315)

25,490

140,021

611

175,922

2,021

344,070

18,236

Total customer risk management programs

14,204,251

507,925

Internal risk management programs

19,634,642

66,422

Total derivative contracts
1  Notional amounts for commodity contracts are converted into dollar-equivalent amounts based on dollar prices at the inception of the 

(135,530) $ 438,817

$ (76,511) $

$ 33,838,893

$ 574,347

$

362,306

contract.

103

The following table summarizes the fair values of derivative contracts recorded as “derivative contracts” assets and liabilities in 
the balance sheet at December 31, 2017 (in thousands):

Assets

Notional1

Gross
Fair
Value

Netting
Adjustments

Net Fair
Value
Before
Cash
Collateral

Cash
Collateral

Fair Value
Net of Cash
Collateral

Customer risk management programs:

Interest rate contracts

To-be-announced residential mortgage-

backed securities

Interest rate swaps

Energy contracts

Agricultural contracts

Foreign exchange contracts

Equity option contracts

$ 12,347,542

$ 23,606

$

(18,096) $

5,510

$

— $

1,478,944

28,278

1,190,067

103,044

53,238

1,576

132,397

129,551

99,633

5,503

—

(47,873)

(960)

—

—

28,278

55,171

616

129,551

5,503

(4,964)

(196)

—

(448)

(920)

Total customer risk management programs

15,301,821

291,558

(66,929)

224,629

(6,528)

Internal risk management programs

4,736,701

9,494

(7,093)

2,401

—

5,510

23,314

54,975

616

129,103

4,583

218,101

2,401

Total derivative contracts

$ 20,038,522

$ 301,052

$

(74,022) $ 227,030

$

(6,528) $

220,502

Liabilities

Notional¹

Gross
Fair
Value

Netting
Adjustments

Net Fair
Value
Before
Cash
Collateral

Cash
Collateral

Fair Value
Net of Cash
Collateral

Customer risk management programs:

Interest rate contracts

To-be-announced residential mortgage-

backed securities

Interest rate swaps

Energy contracts

Agricultural contracts

Foreign exchange contracts

Equity option contracts

$ 11,537,742

$ 20,367

$

(18,096) $

2,271

$

(704) $

1,478,944

28,298

1,166,924

101,603

48,552

1,551

126,251

123,321

99,633

5,503

—

(47,873)

(960)

—

—

28,298

53,730

591

123,321

5,503

(12,896)

(42,767)

—

(53)

—

Total customer risk management programs

14,458,046

280,643

(66,929)

213,714

(56,420)

Internal risk management programs

5,728,421

21,762

(7,093)

14,669

—

1,567

15,402

10,963

591

123,268

5,503

157,294

14,669

Total derivative contracts
1  Notional amounts for commodity contracts are converted into dollar-equivalent amounts based on dollar prices at the inception of the 

(74,022) $ 228,383

$ (56,420) $

$ 20,186,467

$ 302,405

$

171,963

contract.

104

The following summarizes the pre-tax net gains (losses) on derivative instruments and where they are recorded in the Consolidated 
Statements of Earnings (in thousands):

Year Ended December 31,

2018

2017

2016

Brokerage
and 
Trading 
Revenue

Gain (Loss)
on 
Derivatives, 
Net

Brokerage
and 
Trading
Revenue

Gain (Loss)
on 
Derivatives,
Net

Brokerage
and 
Trading
Revenue

Gain (Loss)
on 
Derivatives,
Net

Customer risk management programs:

Interest rate contracts

To-be-announced residential mortgage-

backed securities

Interest rate swaps

Energy contracts

Agricultural contracts

Foreign exchange contracts

Equity option contracts

Total customer risk management programs

Internal risk management programs

$

27,190

$

— $

34,532

$

— $

38,523

$

2,614

8,443

53

535

—

38,835

(13,643)

—

—

—

—

—

—

(422)

2,647

5,536

79

1,352

—

44,146

4,615

—

—

—

—

—

—

779

779

2,589

5,027

111

945

—

47,195

(4,592)

$

42,603

$

—

—

—

—

—

—

—

(15,685)

(15,685)

Total derivative contracts

$

25,192

$

(422) $

48,761

$

As discussed in Note 7, certain derivative contracts not designated as hedging instruments related to mortgage loan 
commitments and forward sales contracts are included in Residential mortgage loans held for sale on the Consolidated Balance 
Sheets. See Note 7 for additional discussion of notional, fair value and impact on earnings of these contracts.

No derivative contracts have been designated as hedging instruments for financial reporting purposes.

(4) Loans and Allowances for Credit Losses 

The portfolio segments of the loan portfolio are as follows (in thousands):

December 31, 2018

Fixed
Rate

Variable
Rate

Non-
accrual

Total

Fixed
Rate

December 31, 2017

Variable
Rate

Non-
accrual

Total

Commercial

$ 2,251,188

$ 11,285,049

$

99,841

$ 13,636,078

$ 2,217,432

$ 8,379,240

$ 137,303

$ 10,733,975

Commercial real

estate

Residential mortgage

Personal

Total

Accruing loans past 
due (90 days)1
Foregone interest on
nonaccrual loans

1,477,274

1,830,224

190,687

3,265,918

358,254

834,889

21,621

41,555

4,764,813

548,692

2,928,440

2,230,033

1,608,655

230

1,025,806

154,517

317,584

810,990

2,855

47,447

269

3,479,987

1,973,686

965,776

$ 5,749,373

$ 15,744,110

$ 163,247

$ 21,656,730

$ 4,529,296

$ 12,436,254

$ 187,874

$ 17,153,424

$

$

1,338

15,502

$

$

633

16,496

1  Excludes residential mortgage loans guaranteed by agencies of the U.S. government.

105

At December 31, 2018, loans to businesses and individuals with collateral primarily located in Texas totaled $6.4 billion or 
30% of the total loan portfolio. Loans to businesses and individuals with collateral primarily located in Oklahoma totaled $3.5 
billion or 16% of our total loan portfolio. Loans to businesses and individuals with collateral primarily located in Colorado 
totaled $3.3 billion or 15% of our total loan portfolio. Loans for which the collateral location is not relevant, such as unsecured 
loans and reserve-based energy loans, are distributed by the borrower’s primary operating location. These geographic 
concentrations subject the loan portfolio to the general economic conditions within these areas. At December 31, 2017, loans to 
businesses and individuals with collateral primarily located in Texas totaled $5.8 billion or 34% of the loan portfolio and loans 
to businesses and individuals with collateral primarily located in Oklahoma totaled $3.3 billion or 19% of the loan portfolio.

Commercial

Commercial loans represent loans for working capital, facilities acquisition or expansion, purchases of equipment and other 
needs of commercial customers primarily located within our geographical footprint. Commercial loans are underwritten 
individually and represent on-going relationships based on a thorough knowledge of the customer, the customer’s industry and 
market. While commercial loans are generally secured by the customer’s assets including real property, inventory, accounts 
receivable, operating equipment, interest in mineral rights and other property and may also include personal guarantees of the 
owners and related parties, the primary source of repayment of the loans is the on-going cash flow from operations of the 
customer’s business. Inherent lending risk is centrally monitored on a continuous basis from underwriting throughout the life of 
the loan for compliance with commercial lending policies.

At December 31, 2018, commercial loans with collateral primarily located in Texas totaled $4.1 billion or 30% of the 
commercial loan portfolio segment. Commercial loans with collateral primarily located in Oklahoma totaled $2.2 billion or 
16% of the commercial loan portfolio segment. Commercial loans with collateral primarily located in Colorado totaled $2.0 
billion or 15% of the commercial loan portfolio segment. The commercial loan portfolio segment is further divided into loan 
classes. The services loan class totaled $3.3 billion or 15% of total loans. Approximately $2.3 billion of loans in the services 
class consisted of loans with individual balances of less than $10 million. Businesses included in the services class include 
commercial services, Native American tribal governments, financial services, entertainment and recreation and education. The 
energy loan class totaled $3.6 billion or 17% of total loans, including $2.9 billion of outstanding loans to energy producers. 
Approximately 57% of committed production loans were secured by properties primarily producing oil and 43% are secured by 
properties producing natural gas. The healthcare loan class totaled $2.7 billion or 13% of total loans. The healthcare loan class 
consists primarily of loans for the development and operation of senior housing and care facilities, including independent 
living, assisted living and skilled nursing. Healthcare also includes loans to hospitals and other medical service providers. 

At December 31, 2017, commercial loans with collateral primarily located in Texas totaled $3.6 billion or 34% of the 
commercial loan portfolio segment and commercial loans with collateral primarily located in Oklahoma totaled $2.0 billion or 
18% of the commercial loan portfolio segment. The energy loan class totaled $2.9 billion or 17% of total loans, including $2.5 
billion of outstanding loans to energy producers. At December 31, 2017, approximately 57% of committed production loans 
were secured by properties primarily producing oil and 43% were secured by properties producing natural gas. The services 
loan class totaled $2.5 billion or 15% of total loans. Approximately $1.5 billion of loans in the services category consisted of 
loans with individual balances of less than $10 million. The healthcare loan class totaled $2.2 billion or 13% of total loans.

Commercial Real Estate

Commercial real estate loans are for the construction of buildings or other improvements to real estate and property held by 
borrowers for investment purposes primarily within our geographical footprint. We require collateral values in excess of the 
loan amounts, demonstrated cash flows in excess of expected debt service requirements, equity investment in the project and a 
portion of the project already sold, leased or permanent financing already secured. The expected cash flows from all significant 
new or renewed income producing property commitments are stress tested to reflect the risks in varying interest rates, vacancy 
rates and rental rates. As with commercial loans, inherent lending risks are centrally monitored on a continuous basis from 
underwriting throughout the life of the loan for compliance with applicable lending policies.

At December 31, 2018, 26% of commercial real estate loans are secured by properties primarily located in the Dallas and 
Houston areas of Texas. An additional 16% of commercial real estate loans are secured by properties located primarily in the 
Denver, Colorado metropolitan area. At December 31, 2017, 35% of commercial real estate loans were secured by properties in 
Texas, 12% of commercial real estate loans were secured by properties in Oklahoma.

106

Residential Mortgage and Personal

Residential mortgage loans provide funds for our customers to purchase or refinance their primary residence or to borrow 
against the equity in their home. Residential mortgage loans are secured by a first or second mortgage on the customer’s 
primary residence. Personal loans consist primarily of loans secured by the cash surrender value of insurance policies and 
marketable securities. It also includes direct loans secured by and for the purchase of automobiles, recreational and marine 
equipment as well as other unsecured loans. Residential mortgage and personal loans are made in accordance with underwriting 
policies. Credit scoring is assessed based on significant credit characteristics including credit history, residential and 
employment stability. Residential mortgage loans retained in the Company’s portfolio are primarily composed of various 
mortgage programs to support customer relationships including jumbo mortgage loans, non-builder construction loans and 
special loan programs for high net worth individuals and certain professionals. Jumbo loans may be fixed or variable rate and 
are fully amortizing. Jumbo loans generally conform to government sponsored entity standards, except that the loan size 
exceeds maximums required under these standards. These loans generally require a minimum FICO score of 720 and a 
maximum debt-to-income ratio (“DTI”) of 38%. Loan-to-value (“LTV”) ratios are tiered from 60% to 100%, depending on the 
market. Special mortgage programs include fixed and variable fully amortizing loans tailored to the needs of certain healthcare 
professionals. Variable rate loans are fully indexed at origination and may have fixed rates for 3 years to 10 years, then adjust 
annually thereafter. 

At December 31, 2018 and 2017, residential mortgage loans included $191 million and $198 million, respectively, of loans 
guaranteed by U.S. government agencies previously sold into GNMA mortgage pools. These loans either have been 
repurchased or are eligible to be repurchased by the Company when certain defined delinquency criteria are met. Although 
payments on these loans generally are past due more than 90 days, interest continues to accrue based on the government 
guarantee.

Home equity loans totaled $719 million at December 31, 2018 and $733 million at December 31, 2017. At December 31, 2018, 
59% of the home equity loan portfolio was comprised of first lien loans and 41% of the home equity portfolio was comprised 
of junior lien loans. Junior lien loans were distributed 40% to amortizing term loans and 60% to revolving lines of credit. At 
December 31, 2017, 64% of the home equity portfolio was comprised of first lien loans and 36% of the home equity loan 
portfolio was comprised of junior lien loans. Junior lien loans were distributed 46% to amortizing term loans and 54% to 
revolving lines of credit. Home equity loans generally require a minimum FICO score of 700 and a maximum DTI of 40%. The 
maximum loan amount available for our home equity loan products is generally $400 thousand. Revolving loans have a 5 year 
revolving period followed by 15 year term of amortizing repayments. Interest-only home equity loans may not be extended for 
any additional revolving time. All other home equity loans may be extended at management's discretion for an additional 5 year 
revolving term subject to an update of certain credit information.

At December 31, 2018, 26% of residential mortgage loans are secured by properties located in Oklahoma, 28% of residential 
mortgage loans are secured by properties located in Texas and 19% of residential mortgage are secured by properties located in 
Colorado. At December 31, 2017, 31% of residential mortgage loans were secured by properties in Oklahoma, 30% of 
residential mortgage were secured by properties in Texas, 11% of residential mortgage loans are secured by properties in 
Colorado and 9% of residential mortgage loans are secured by properties in New Mexico.

Purchase Credit Impaired Loans

In conjunction with the acquisition of CoBiz Financial on October, 1, 2018, the Company acquired certain loans for which 
there was evidence of deterioration of credit quality since origination and for which it was probable that all contractually 
required payments would not be collected ("PCI loans"). At December 31, 2018, the carrying amount of PCI loans was $31 
million and the unpaid balance was $47 million. The accretable yield related to these PCI loans was $843 thousand. 

Credit Commitments

Commitments to extend credit are agreements to lend to a customer as long as there is no violation of conditions established in 
the contract. Commitments generally have fixed expiration dates or other termination clauses and may require payment of a 
fee. At December 31, 2018, outstanding commitments totaled $12 billion. Because some commitments are expected to expire 
before being drawn upon, the total commitment amounts do not necessarily represent future cash requirements. BOK Financial 
uses the same credit policies in making commitments as it does loans.

The amount of collateral obtained, if deemed necessary, is based upon management’s credit evaluation of the borrower.

107

Standby letters of credit are conditional commitments issued to guarantee the performance of a customer to a third party. 
Because the credit risk involved in issuing standby letters of credit is essentially the same as that involved in extending loan 
commitments, BOK Financial uses the same credit policies in evaluating the creditworthiness of the customer. Additionally, 
BOK Financial uses the same evaluation process in obtaining collateral on standby letters of credit as it does for loan 
commitments. The term of these standby letters of credit is defined in each commitment and typically corresponds with the 
underlying loan commitment. At December 31, 2018, outstanding standby letters of credit totaled $582 million. Commercial 
letters of credit are used to facilitate customer trade transactions with the drafts being drawn when the underlying transaction is 
consummated. At December 31, 2018, outstanding commercial letters of credit totaled $1.9 million.

Allowances for Credit Losses

BOK Financial maintains an allowance for loan losses and an accrual for off-balance sheet credit risk. The accrual for off-
balance sheet credit risk is maintained at a level that is appropriate to cover estimated losses associated with credit instruments 
that are not currently recognized as assets such as loan commitments, standby letters of credit or guarantees. As discussed in 
greater detail in Note 7, the Company also has separate accruals related to off-balance sheet credit risk related to residential 
mortgage loans previously sold with full or partial recourse and for residential mortgage loans sold to government sponsored 
agencies under standard representations and warranties.

The allowance for loan losses consists of specific allowances attributed to impaired loans that have not yet been charged down 
to amounts we expect to recover, general allowances for unimpaired loans based on estimated loss rates by loan class and 
nonspecific allowances based on general economic conditions, concentration in loans with large balances and other relevant 
factors.

The activity in the allowance for loan losses and the accrual for off-balance sheet credit risk related to loan commitments and 
standby letters of credit for the year ended December 31, 2018 is summarized as follows (in thousands):

Allowance for loan losses:

Beginning balance

Provision for loan losses

Loans charged off

Recoveries

Ending balance

Commercial

Commercial
Real Estate

Residential
Mortgage

Personal

Nonspecific
Allowance

Total

$

124,269

$

56,621

$

18,451

$

9,124

$

22,217

$

230,682

12,521

(37,880)

3,316

(147)

—

3,552

(1,156)

(378)

1,047

3,175

(5,325)

2,499

(4,449)

—

—

9,944

(43,583)

10,414

$

102,226

$

60,026

$

17,964

$

9,473

$

17,768

$

207,457

Accrual for off-balance sheet

credit risk:

Beginning balance

Provision for off-balance sheet credit

risk

Ending balance

Total provision for credit losses

$

$

$

3,644

(1,989)

1,655

10,532

$

$

$

45

$

43

$

2

$

— $

3,734

7

52

$

9

52

$

29

31

(140) $

(1,147) $

3,204

—

— $

(1,944)

1,790

(4,449) $

8,000

$

$

108

The activity in the allowance for loan losses and the accrual for off-balance sheet credit risk related to loan commitments and 
standby letters of credit for the year ended December 31, 2017 is summarized as follows (in thousands):

Allowance for loan losses:

Beginning balance

Provision for loan losses

Loans charged off

Recoveries

Ending balance

Commercial

Commercial
Real Estate

Residential
Mortgage

Personal

Nonspecific
Allowance

Total

$

140,213

$

50,749

$

18,224

$

8,773

$

28,200

$

246,159

(595)

(19,810)

4,461

4,008

(76)

1,940

116

(649)

760

2,964

(5,064)

2,451

(5,983)

—

—

510

(25,599)

9,612

$

124,269

$

56,621

$

18,451

$

9,124

$

22,217

$

230,682

Accrual for off-balance sheet credit

risk:

Beginning balance

Provision for off-balance sheet credit

risk

Ending balance

Total provision for credit losses

$

$

$

11,063

$

123

$

50

$

8

$

— $

11,244

(7,419)

3,644

$

(78)

45

(8,014) $

3,930

(7)

43

109

$

$

(6)

2

2,958

$

$

$

$

—

— $

(7,510)

3,734

(5,983) $

(7,000)

The activity in the allowance for loan losses and the accrual for off-balance sheet credit risk related to loan commitments and 
standby letters of credit for the year ended December 31, 2016 is summarized as follows (in thousands):

Allowance for loan losses:

Beginning balance

Provision for loan losses

Loans charged off

Recoveries

Ending balance

Commercial

Commercial
Real Estate

Residential
Mortgage

Personal

Nonspecific
Allowance

Total

$

130,334

$

41,391

$

19,509

$

4,164

$

30,126

$

225,524

43,980

(35,828)

1,727

8,075

—

1,283

(1,972)

(1,312)

1,999

7,310

(5,448)

2,747

(1,926)

—

—

55,467

(42,588)

7,756

$

140,213

$

50,749

$

18,224

$

8,773

$

28,200

$

246,159

Accrual for off-balance sheet credit

risk:

Beginning balance

Provision for off-balance sheet credit

risk

Ending balance

Total provision for credit losses

$

$

$

1,506

$

153

$

30

$

22

$

— $

1,711

9,557

11,063

53,537

$

$

(30)

123

8,045

$

$

20

50

$

(14)

8

(1,952) $

7,296

—

— $

9,533

11,244

(1,926) $

65,000

$

$

109

The allowance for loan losses and recorded investment of the related loans by portfolio segment for each impairment 
measurement method at December 31, 2018 is as follows (in thousands):

Commercial

Commercial real estate

Residential mortgage

Personal

Total

Collectively Measured
for Impairment

Individually Measured
for Impairment

Total

Recorded
Investment

Related
Allowance

Recorded
Investment

Related
Allowance

Recorded
Investment

Related
Allowance

$ 13,536,237

$

93,494

$

99,841

$

8,732

$ 13,636,078

$

102,226

4,743,192

2,188,478

1,025,576

60,026

17,964

9,473

21,621

41,555

230

—

—

—

4,764,813

2,230,033

1,025,806

60,026

17,964

9,473

21,493,483

180,957

163,247

8,732

21,656,730

189,689

Nonspecific allowance

—

—

—

—

—

17,768

Total

$ 21,493,483

$

180,957

$

163,247

$

8,732

$ 21,656,730

$

207,457

The allowance for loan losses and recorded investment of the related loans by portfolio segment for each impairment 
measurement method at December 31, 2017 is as follows (in thousands):

Commercial

Commercial real estate

Residential mortgage

Personal

Total

Collectively Measured
for Impairment

Individually Measured
for Impairment

Total

Recorded
Investment

Related
Allowance

Recorded
Investment

Related
Allowance

Recorded
Investment

Related
Allowance

$ 10,596,672

$

115,438

$

137,303

$

8,831

$ 10,733,975

$

124,269

3,477,132

1,926,239

965,507

56,621

18,451

9,124

2,855

47,447

269

—

—

—

3,479,987

1,973,686

965,776

56,621

18,451

9,124

16,965,550

199,634

187,874

8,831

17,153,424

208,465

Nonspecific allowance

—

—

—

—

—

22,217

Total

$ 16,965,550

$

199,634

$

187,874

$

8,831

$ 17,153,424

$

230,682

110

Credit Quality Indicators

The Company utilizes loan class and risk grading as primary credit quality indicators. Substantially all commercial and 
commercial real estate loans and certain residential mortgage and personal loans are risk graded based on a quarterly evaluation 
of the borrowers’ ability to repay the loans. Certain commercial loans and most residential mortgage and personal loans are 
small, homogeneous pools that are not risk graded. 

The allowance for loan losses and recorded investment of the related loans by portfolio segment for risk graded and non-risk 
graded loans at December 31, 2018 is as follows (in thousands):

Commercial

Commercial real estate

Residential mortgage

Personal

Total

Internally Risk Graded

Non-Graded

Total

Recorded
Investment

Related
Allowance

Recorded
Investment

Related
Allowance

Recorded
Investment

Related
Allowance

$ 13,586,654

$

101,303

$

49,424

$

923

$ 13,636,078

$

102,226

4,764,813

505,046

948,890

60,026

3,310

6,633

—

1,724,987

76,916

19,805,403

171,272

1,851,327

—

14,654

2,840

18,417

4,764,813

2,230,033

1,025,806

60,026

17,964

9,473

21,656,730

189,689

Nonspecific allowance

—

—

—

—

—

17,768

Total

$ 19,805,403

$

171,272

$

1,851,327

$

18,417

$ 21,656,730

$

207,457

The allowance for loan losses and recorded investment of the related loans by portfolio segment for risk graded and non-risk 
graded loans at December 31, 2017 is as follows (in thousands):

Commercial

Commercial real estate

Residential mortgage

Personal

Total

Internally Risk Graded

Non-Graded

Total

Recorded
Investment

Related
Allowance

Recorded
Investment

Related
Allowance

Recorded
Investment

Related
Allowance

$ 10,706,035

$

123,383

$

27,940

$

886

$ 10,733,975

$

124,269

3,479,987

234,477

877,390

56,621

2,947

6,461

—

1,739,209

88,386

15,297,889

189,412

1,855,535

—

15,504

2,663

19,053

3,479,987

1,973,686

965,776

56,621

18,451

9,124

17,153,424

208,465

Nonspecific allowance

—

—

—

—

—

22,217

Total

$ 15,297,889

$

189,412

$

1,855,535

$

19,053

$ 17,153,424

$

230,682

Loans are considered to be performing if they are in compliance with the original terms of the agreement which is consistent 
with the regulatory guideline of “pass.” Performing also includes loans considered to be “other loans especially mentioned” by 
regulatory guidelines and all residential mortgage loans guaranteed by agencies of the U.S. government that continue to accrue 
interest based on criteria of the guarantor's programs. Other loans especially mentioned are currently performing in compliance 
with the original terms of the agreement but may have a potential weakness that deserves management's close attention, 
consistent with regulatory guidelines.

The risk grading process identified certain loans that have a well-defined weakness (e.g. inadequate debt service coverage or 
liquidity or marginal capitalization; repayment may depend on collateral or other risk mitigation) that may jeopardize 
liquidation of the debt and represent a greater risk due to deterioration in the financial condition of the borrower. This is 
consistent with the regulatory guideline for “substandard.” Because the borrowers are still performing in accordance with the 
original terms of the loan agreements, these loans were not placed in nonaccruing status. 

111

Nonaccruing loans represent loans for which full collection of principal and interest in accordance with the original terms of the 
loan agreements is uncertain. This is substantially the same criteria used to determine whether a loan is impaired and includes 
certain loans considered “substandard” and all loans considered “doubtful” by regulatory guidelines.

The following table summarizes the Company’s loan portfolio at December 31, 2018 by the risk grade categories (in 
thousands): 

Internally Risk Graded

Non-Graded

Performing

Other
Loans
Especially
Mentioned

Pass

Accruing

Substandard Nonaccrual

Performing Nonaccrual

Total

$ 3,414,039

$

42,176

$

86,624

$

47,494

$

— $

— $ 3,590,333

3,161,157

1,593,902

668,438

2,664,381

876,336

49,761

18,809

30,934

14,920

—

148,234

885,588

1,059,334

1,287,471

776,898

—

11,926

10,532

281

—

555,301

1,188

32,661

7,131

22,230

37,698

—

7,588

193,932

—

1,289

3,054

12

1,208

876

8,567

1,316

8,919

16,538

—

16,954

99,788

350

20,279

—

301

—

691

4,712,826

23,927

6,439

21,621

—

—

—

—

—

49,371

49,371

—

—

—

—

—

—

—

—

—

—

—

—

53

53

—

—

—

—

—

—

—

3,252,146

1,621,158

730,521

2,733,537

876,336

832,047

13,636,078

148,584

919,082

1,072,920

1,288,065

778,106

558,056

4,764,813

Commercial:

Energy

Services

Wholesale/retail

Manufacturing

Healthcare

Public finance

Commercial real estate:

Residential construction
and land development

Retail

Office

Multifamily

Industrial

Other commercial real

estate

Total commercial real
estate

Other commercial and

industrial

Total commercial

756,815

13,135,068

1,266

157,866

Residential mortgage:

Permanent mortgage

467,233

Permanent mortgages
guaranteed by U.S.
government agencies

Home equity

Total residential
mortgage

—

25,743

492,976

52

—

—

52

9,730

1,991

819,199

21,960

1,320,165

—

296

—

—

183,734

682,491

7,132

10,472

190,866

719,002

10,026

1,991

1,685,424

39,564

2,230,033

Personal

Total

944,256

115

4,443

76

76,762

154

1,025,806

$ 19,285,126

$

181,960

$

214,840

$

123,476

$ 1,811,557

$

39,771

$ 21,656,730

112

The following table summarizes the Company’s loan portfolio at December 31, 2017 by the risk grade categories (in thousands): 

Internally Risk Graded

Non-Graded

Performing
Other
Loans
Especially
Mentioned

Pass

Accruing

Substandard Nonaccrual

Performing Nonaccrual

Total

$ 2,632,986

$

60,288

$

144,598

92,284

$

— $

— $

2,930,156

Commercial:

Energy

Services

Wholesale/retail

Manufacturing

Healthcare

Public finance

Other commercial and

industrial

2,478,945

1,443,917

472,869

2,182,231

541,775

473,366

13,927

19,263

6,653

3,186

—

7

26,533

5,502

11,290

43,305

—

2,620

2,574

5,962

14,765

—

—

—

—

—

—

8,161

239,389

19,028

137,233

27,870

27,870

—

—

—

—

—

70

70

—

—

—

—

—

—

—

2,522,025

1,471,256

496,774

2,243,487

541,775

528,502

10,733,975

117,245

691,532

831,770

980,017

573,014

286,409

3,479,987

1,832

276

275

—

—

472

2,855

—

—

—

—

—

—

—

1,163

784,928

24,030

1,043,435

—

—

188,327

719,670

9,179

13,075

197,506

732,745

1,163

1,692,925

46,284

1,973,686

83

88,200

186

965,776

Total commercial

10,226,089

103,324

Commercial real estate:

Residential construction
and land development

Retail

Office

Multifamily

Industrial

Other commercial real

estate

Total commercial real

estate

113,190

686,915

824,408

979,969

573,014

285,506

1,828

4,243

7,087

—

—

145

3,463,002

13,303

Residential mortgage:

Permanent mortgage

232,492

Permanent mortgages
guaranteed by U.S.
government agencies

Home equity

Total residential
mortgage

—

—

232,492

—

—

—

—

875,696

1,548

Personal

Total

395

98

—

48

—

286

827

822

—

—

822

63

$ 14,797,279

$

118,175

$

241,101

141,334

$ 1,808,995

$

46,540

$ 17,153,424

113

Impaired Loans

Loans are considered to be impaired when it is probable that the Company will not be able to collect all amounts due according 
to the contractual terms of the loan agreement. This includes all nonaccruing loans, all loans modified in a troubled debt 
restructuring and all loans repurchased from GNMA pools.

A summary of impaired loans follows (in thousands):

As of December 31, 2018
Recorded Investment

Total

With No
Allowance

With
Allowance

Related
Allowance

Year Ended
December 31, 2018

Average 
Recorded
Investment

Interest
Income
Recognized

Commercial:

Energy
Services
Wholesale/retail
Manufacturing
Healthcare

Public finance

Other commercial and

industrial
Total commercial

Unpaid
Principal
Balance

$

$

79,675
13,437
1,722
10,055
24,319

—

26,955
156,163

Commercial real estate:

Residential construction and

land development

Retail
Office
Multifamily

Industrial

Other commercial real estate

1,306
27,680
—
301

—

851

$

47,494
8,567
1,316
8,919
16,538

—

17,007
99,841

350
20,279
—
301

—

691

18,639
8,489
1,015
8,673
10,563

—

17,007
64,386

350
20,279
—
301

—

691

Total commercial real estate

30,138

21,621

21,621

Residential mortgage:
Permanent mortgage

Permanent mortgage 
guaranteed by U.S. 
government agencies1

Home equity

Total residential mortgage

28,716

23,951

23,951

196,296
12,196
237,208

190,866
10,472
225,289

190,866
10,472
225,289

Personal

278

230

230

—
—
—
—
—

—

—
—

—
—
—
—

—

—

—

$

$

28,855
78
301
246
5,975

—

—
35,455

$

5,362
74
101
246
2,949

—

—
8,732

$

69,645
4,509
1,784
7,249
14,297

—

17,976
115,460

—
—
—
—

—

—

—

—

—
—
—

—

—
—
—
—

—

—

—

—

—
—
—

—

1,091
10,278
137
151

—

581

12,238

24,572

1,233

180,813
11,774
217,159

7,172
—
8,405

250

—

Total
1  All permanent mortgage loans guaranteed by U.S. government agencies are considered impaired as we do not expect full collection of 

346,981

423,787

345,107

311,526

35,455

8,732

$

$

$

$

$

$

$

8,405

contractual principal and interest. At December 31, 2018, $7.1 million of these loans are nonaccruing and $184 million are accruing based 
on the guarantee by U.S. government agencies.

Generally, no interest income is recognized on impaired loans until all principal balances, including amounts charged-off, have 
been recovered. 

114

Commercial:

Energy

Services

Wholesale/retail

Manufacturing

Healthcare

Public finance

Other commercial and

industrial

Total commercial

Commercial real estate:

Residential construction and

land development

Retail

Office

Multifamily

Industrial

Other commercial real estate

Total commercial real

estate

Residential mortgage:

Permanent mortgage

Permanent mortgage 
guaranteed by U.S. 
government agencies1

Home equity

Total residential mortgage

As of December 31, 2017

Recorded Investment

Unpaid
Principal
Balance

Total

With No
Allowance

With
Allowance

Related
Allowance

Year Ended

December 31, 2017

Average 
Recorded
Investment

Interest
Income
Recognized

$

111,011

$

92,284

$

40,968

$

51,316

$

8,814

$

112,392

$

5,324

9,099

6,073

25,140

—

2,620

2,574

5,962

14,765

—

27,957

184,604

19,098

137,303

2,620

2,574

5,962

14,765

—

19,080

85,969

—

—

—

—

—

18

—

—

—

—

—

17

51,334

8,831

3,285

1,832

1,832

509

287

—

—

670

276

275

—

—

472

276

275

—

—

472

4,751

2,855

2,855

30,435

25,193

25,193

203,814

14,548

248,797

197,506

13,075

235,774

197,506

13,075

235,774

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

5,396

6,990

5,446

7,795

—

20,108

158,127

2,633

301

351

19

38

847

4,189

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

24,024

1,229

199,244

12,297

235,565

7,632

—

8,861

280

—

Personal

307

269

269

Total
1  All permanent mortgage loans guaranteed by U.S. government agencies are considered impaired as we do not expect full collection of 

398,161

376,201

438,459

324,867

51,334

8,831

$

$

$

$

$

$

$

8,861

contractual principal and interest. At December 31, 2017, $9.2 million of these loans are nonaccruing and $188 million are accruing based 
on the guarantee by U.S. government agencies.

115

Troubled Debt Restructurings

At December 31, 2018 the Company has $166 million in troubled debt restructurings (TDRs), of which $86 million are 
accruing residential mortgage loans guaranteed by U.S. government agencies. Approximately $71 million of TDRs are 
performing in accordance with the modified terms. The loans designated as TDRs had $16.1 million in charge offs during the 
year ended December 31, 2018.

At December 31, 2017, TDRs totaled $126 million, of which $74 million were accruing residential mortgage loans guaranteed 
by U.S. government agencies. Approximately $48 million of TDRs were performing. The loans designated as TDRs had $117 
thousand in charge offs during the year ended December 31, 2017.

TDRs generally consist of interest rate concessions, payment stream concessions or a combination of concessions to distressed 
borrowers. During the year ended December 31, 2018, $75 million of loans were restructured. During the year ended 
December 31, 2017, $57 million of loans were restructured. 

116

Nonaccrual & Past Due Loans

Past due status for all loan classes is based on the actual number of days since the last payment was due according to the 
contractual terms of the loans.

A summary of loans currently performing, loans past due and accruing and nonaccrual loans as of December 31, 2018 is as follows 
(in thousands):

Current

30 to 59
Days

Past Due

60 to 89
Days

90 Days
or More

Nonaccrual

Total

— $

— $

47,494

$ 3,590,333

Commercial:

Energy

Services

Wholesale/retail

Manufacturing

Healthcare

Public finance

Other commercial and industrial

$ 3,542,839

$

3,231,532

1,619,290

721,204

2,716,204

876,336

814,489

—

6,009

515

392

241

—

518

6,038

37

6

—

—

25

Total commercial

13,521,894

7,675

6,106

—

—

—

554

—

8

562

—

—

—

—

—

714

714

8,567

1,316

8,919

3,252,146

1,621,158

730,521

16,538

2,733,537

—

17,007

99,841

876,336

832,047

13,636,078

350

20,279

—

301

—

691

148,584

919,082

1,072,920

1,288,065

778,106

558,056

21,621

4,764,813

147,705

884,424

1,072,920

1,287,483

776,898

556,239

4,725,669

249

14,379

—

281

1,208

412

16,529

280

—

—

—

—

—

280

1,292,652

3,196

366

—

23,951

1,320,165

37,459

707,017

2,037,128

24,369

1,102

28,667

16,345

352

17,063

105,561

59

105,620

7,132

10,472

41,555

190,866

719,002

2,230,033

1,024,298

479

796

3

230

1,025,806

$ 21,308,989

$

53,350

24,245

$

106,899

$

163,247

$ 21,656,730

117

Commercial real estate:

Residential construction and land

development

Retail

Office

Multifamily

Industrial

Other commercial real estate

Total commercial real estate

Residential mortgage:

Permanent mortgage

Permanent mortgages guaranteed by

U.S. government agencies

Home equity

Total residential mortgage

Personal

Total

A summary of loans currently performing, loans past due and accruing and nonaccrual loans as of December 31, 2017 is as 
follows (in thousands):

Current

30 to 59
Days

Past Due

60 to 89
Days

90 Days
or More

Nonaccrual

Total

4,204

$

— $

92,284

$ 2,930,156

Commercial:

Energy

Services

Wholesale/retail

Manufacturing

Healthcare

Public finance

Other commercial and industrial

$ 2,833,668

$

2,518,298

1,468,284

490,739

2,213,504

541,775

509,116

—

514

398

—

15,218

—

85

486

—

73

—

—

78

Total commercial

10,575,384

16,215

4,841

Commercial real estate:

Residential construction and land

development

Retail

Office

Multifamily

Industrial

Other commercial real estate

115,213

691,256

831,118

979,625

573,014

285,937

Total commercial real estate

3,476,163

200

—

254

22

—

—

476

—

—

—

370

—

—

370

107

—

—

—

—

125

232

—

—

123

—

—

—

123

2,620

2,574

5,962

2,522,025

1,471,256

496,774

14,765

2,243,487

—

19,098

541,775

528,502

137,303

10,733,975

1,832

276

275

—

—

472

2,855

117,245

691,532

831,770

980,017

573,014

286,409

3,479,987

Residential mortgage:

Permanent mortgage

Permanent mortgages guaranteed by

U.S. government agencies

Home equity

Total residential mortgage

Personal

Total

1,014,588

3,435

219

—

25,193

1,043,435

22,692

717,007

1,754,287

18,978

2,206

24,619

13,468

440

14,127

133,189

17

133,206

9,179

13,075

47,447

197,506

732,745

1,973,686

964,374

681

191

261

269

965,776

$ 16,770,208

$

41,991

19,529

$

133,822

$

187,874

$ 17,153,424

118

(5) Premises and Equipment 

Premises and equipment at December 31 are summarized as follows (in thousands):

Land

Buildings and improvements

Software

Furniture and equipment

Construction in progress

Premises and equipment

Less accumulated depreciation
Premises and equipment, net of accumulated depreciation

December 31,

2018

2017

$

70,575

$

266,733

150,207

129,988

27,514

645,017

314,984
330,033

$

$

71,348

249,139

188,826

223,163

23,348

755,824

438,489
317,335

Depreciation expense of premises and equipment was $51 million, $48 million and $40 million for the years ended 
December 31, 2018, 2017 and 2016, respectively.

119

(6) Goodwill and Intangible Assets 

On October 1, 2018, the Company acquired CoBiz Financial, Inc. ("CoBiz"), parent company of CoBiz Bank. CoBiz is 
headquartered in Denver, Colorado serving the Colorado and Arizona markets. The Company paid total consideration of $944 
million, which included $243 million in cash along with the issuance of 7.2 million shares of BOK Financial common stock 
valued at $701 million in exchange for all the outstanding shares of CoBiz. Goodwill acquired is attributed to synergies 
expected to be gained through consolidation of administrative functions resulting in cost savings. 

A summary of the preliminary purchase price allocation and resulting goodwill at October 1, 2018 follows (in thousands):

Cash and due from banks

Investment securities

Available for sale securities

Restricted equity securities

Loans (Unpaid principal balance - $3,066,521)

Premises and equipment

Receivables

Intangible assets

Real estate and other repossessed assets

Derivative contracts asset, net

Cash surrender value of bank-owned life insurance

Other assets

Total assets acquired

Deposits

Funds purchased and repurchase agreements

Subordinated debentures

Accrued interest, taxes and expense

Derivative contracts liability, net

Other liabilities

Total liabilities assumed

Net assets acquired

Less: Purchase price

Goodwill

$

80,827

17,287

546,776

5,261

2,937,499

5,515

24,893

106,733

5,155

8,197

55,740

56,642

3,850,525

3,289,071

37,218

131,197

33,122

12,303

5,254

3,508,165

342,360

944,193

$

601,833

The preliminary purchase price allocation represents acquired assets and liabilities at estimated fair value. Fair value for loans 
and intangibles assets was determined by applying discounted cash flow measurement techniques using significant 
unobservable (Level 3) inputs. These inputs include estimates of loss rates and prepayment speeds, customer attrition rates, 
operating costs, alternative funding costs and discount rates. The fair value of other acquired assets and liabilities was 
determined primarily through the use of significant other observable (Level 2) inputs. 

On May 1, 2018, the Company acquired a majority voting interest in Switchgrass Holdings, LLC, a restaurant franchise owner 
and operator, pursuant to merchant banking regulations and restrictions. The purchase price for the acquisition was $14 million 
and included $6.7 million of intangible assets.

On December 1, 2016, the Company acquired MBT Bancshares (“MBT”), parent company of Missouri Bank and Trust of 
Kansas City (“Mobank”) following regulatory approval of the transaction. Mobank operated four banking branches in the 
Kansas City, Mo. area. BOK Financial paid $103 million in an all-cash deal for all outstanding shares of MBT stock. The 
purchase price allocation resulted in $15 million of identifiable intangibles and $66 million of goodwill.

120

The pro-forma impact of all acquisition transactions on earnings for periods prior to the acquisition dates were not material to 
the Company's financial statements.

The following table presents the original cost and accumulated amortization of intangible assets (in thousands):

Core deposit premiums

Less accumulated amortization

Net core deposit premiums

Other identifiable intangible assets

Less accumulated amortization

Net other identifiable intangible assets

Dec. 31,

2018

2017

$

103,200

$

5,032

98,168

63,497

26,816

36,681

6,510

808

5,702

44,468

21,512

22,956

Total intangible assets, net

$

134,849

$

28,658

Expected amortization expense for intangible assets that will continue to be amortized (in thousands):

2019

2020

2021

2022

2023

Thereafter

Core
Deposit
Premiums

Other
Identifiable
Intangible 
Assets

$

14,332

$

6,149

$

12,892

11,893

10,981

10,145

37,925

6,304

5,606

4,238

3,199

11,185

Total

20,481

19,196

17,499

15,219

13,344

49,110

$

98,168

$

36,681

$

134,849

The changes in the carrying value of goodwill by operating segment are as follows (in thousands):

Balance, December 31, 2016

Goodwill recognized during 2017

Sales of consolidated merchant banking investments

during 2017

Adjustment1
Balance, December 31, 2017
Goodwill recognized during 20182
Balance, December 31, 2018

Commercial
Banking

Consumer
Banking

Wealth
Management

Funds
Management
and Other

272,196

4,301

(5,219)

41,992

313,270

—

39,023

71,520

66,160

—

—

4,435

43,458

—

—

(25)

19,207

90,702

—

—

—

(66,160)

—

601,833

Total

448,899

4,301

(5,244)

(526)

447,430

601,833

$ 1,049,263
313,270
1  Goodwill from Mobank acquisition was not yet allocated to the segments as of December 31, 2016. Adjustment was made in 2017 for final 

601,833

90,702

43,458

$

$

$

$

purchase price adjustments and to allocate to the segments.

2  Goodwill related to the CoBiz acquisition was not yet allocated to the operating segments as of December 31, 2018 and is included in 

Funds Management and Other above. 

The annual goodwill evaluations for 2018 and 2017 did not indicate impairment for any reporting unit. Economic conditions 
did not indicate that impairment existed for any identifiable intangible assets and therefore no impairment evaluation was 
performed.

121

(7) Mortgage Banking Activities 

Residential Mortgage Loan Production

The Company originates, markets and services conventional and government-sponsored residential mortgage loans. Generally, 
conforming fixed rate residential mortgage loans are held for sale in the secondary market and non-conforming and adjustable-
rate residential mortgage loans are held for investment. The volume of mortgage loans originated for sale and secondary market 
prices are the primary drivers of originating and marketing revenue.

Residential mortgage loan commitments are generally outstanding for 60 to 90 days, which represents the typical period from 
commitment to originate a residential mortgage loan to when the closed loan is sold to an investor. Residential mortgage loan 
commitments are subject to both credit and interest rate risk. Credit risk is managed through underwriting policies and 
procedures, including collateral requirements, which are generally accepted by the secondary loan markets. Exposure to interest 
rate fluctuations is partially managed through forward sales of residential mortgage-backed securities and forward sales 
contracts. These latter contracts set the price for loans that will be delivered in the next 60 to 90 days.

The unpaid principal balance of residential mortgage loans held for sale, notional amounts of derivative contracts related to 
residential mortgage loan commitments and forward contract sales and their related fair values included in Mortgage loans held 
for sale on the Consolidated Balance Sheets were (in thousands):

Residential mortgage loans held for sale

Residential mortgage loan commitments

Forward sales contracts

December 31, 2018

December 31, 2017

Unpaid 
Principal 
Balance/
Notional

Fair Value

Unpaid 
Principal 
Balance/
Notional

Fair Value

$

145,057

$

146,971

$

212,525

$

215,113

160,848

274,000

5,378

(3,128)

222,919

380,159

6,523

(258)

$

149,221

$

221,378

No residential mortgage loans held for sale were 90 days or more past due or considered impaired as of December 31, 2018 or 
December 31, 2017. No credit losses were recognized on residential mortgage loans held for sale for the years ended 
December 31, 2018, 2017 and 2016.

Mortgage banking revenue was as follows (in thousands):

Year Ended

2018

2017

2016

Production revenue:

Net realized gains on sales of mortgage loans

$

36,379

$

45,128

$

Net change in unrealized gain on mortgage loans held for sale

Net change in the fair value of mortgage loan commitments

Net change in the fair value of forward sales contracts

Total mortgage production revenue

Servicing revenue

Total mortgage banking revenue

(674)

(1,145)

(2,870)

31,690

66,097

2,031

(3,210)

(5,451)

38,498

66,221

68,947

(5,311)

1,599

4,393

69,628

64,286

$

97,787

$

104,719

$

133,914

Mortgage production revenue includes gain (loss) on residential mortgage loans held for sale and changes in the fair value of 
derivative contracts not designated as hedging instruments related to residential mortgage loan commitments and forward sales 
contracts. Servicing revenue includes servicing fee income and late charges on loans serviced for others.

122

Residential Mortgage Servicing

The Company generally retains the right to service residential mortgage loans sold and may purchase mortgage servicing 
rights. The unpaid principal balance of loans serviced for others is the primary driver of servicing revenue.

The following represents a summary of mortgage servicing rights (Dollars in thousands):

December 31,

2018

2017

2016

Number of residential mortgage loans serviced for others

132,463,000

136,528,000

139,340,000

Outstanding principal balance of residential mortgage loans serviced for others

$

21,658,335

$

22,046,632

$

21,997,568

Weighted average interest rate

Remaining contractual term (in months)

3.99%

293

3.94%

297

3.97%

301

Activity in capitalized mortgage servicing rights during the three years ended December 31, 2018 is as follows (in thousands):

Balance, December 31, 2015

Additions, net

Change in fair value due to loan runoff

Change in fair value due to market changes

Balance, December 31, 2016

Additions, net

Change in fair value due to loan runoff

Change in fair value due to market changes

Balance, December 31, 2017

Additions, net

Change in fair value due to loan runoff

Change in fair value due to market changes

Balance, December 31, 2018

$

218,605

71,405

(40,744)

(2,193)

247,073

39,149

(33,527)

172

252,867

35,247

(33,528)

4,668

$

259,254

Changes in the fair value of mortgage servicing rights due to market changes are included in Other operating revenue in the 
Consolidated Statements of Earnings. Changes in fair value due to loan runoff are included in Mortgage banking costs. 

Mortgage servicing rights are not traded in active markets. Fair value is determined by discounting the projected net cash flows. 
Significant assumptions used to determine fair value considered to be significant unobservable inputs were as follows:

Discount rate – risk-free rate plus a market premium

December 31,

2018

9.90%

2017

9.84%

Prepayment rate - based upon loan interest rate, original term and loan type

8.05% - 15.74%

8.72%-15.16%

Loan servicing costs – annually per loan based upon loan type:

Performing loans

Delinquent loans

Loans in foreclosure

Primary/secondary mortgage rate spread

Escrow earnings rate – indexed to rates paid on deposit accounts with comparable average

life

$67 - $93

$150 - $500

$65 - $88

$150 - $500

$1,000 - $4,000

$1,000 - $4,000

105 bps

2.57%

105 bps

2.24%

Changes in primary residential mortgage interest rates directly affect the prepayment speeds used in valuing our mortgage 
servicing rights. A separate third party model is used to estimate prepayment speeds based on interest rates, housing turnover 
rates, estimated loan curtailment, anticipated defaults and other relevant factors. The prepayment model is updated periodically 
for changes in market conditions and adjusted to better correlate with actual performance of BOK Financial’s servicing 
portfolio.

123

The aging status of our mortgage loans serviced for others by investor at December 31, 2018 follows (in thousands):

Current

30 to 59
Days

Past Due

60 to 89
Days

90 Days or
More

Total

$ 7,798,790

$

58,271

$

11,139

$

25,239

$

7,893,439

6,458,561

6,568,459

362,268

63,321

200,747

4,297

12,413

56,024

81

20,858

15,996

1,871

6,555,153

6,841,226

368,517

$ 21,188,078

$

326,636

$

79,657

$

63,964

$ 21,658,335

FHLMC

FNMA

GNMA

Other

Total

(8) Deposits 

Interest expense on deposits is summarized as follows (in thousands):

Transaction deposits

Savings

Time:

Certificates of deposits under $100,000

Certificates of deposits $100,000 and over

Other time deposits

Total time

Total

Year Ended December 31,

2018

2017

2016

$

65,859

$

28,627

$

13,906

439

359

386

5,751

19,739

3,729

29,219

7,702

12,393

4,722

24,817

8,776

10,123

7,303

26,202

$

95,517

$

53,803

$

40,494

The aggregate amounts of time deposits in denominations of $250,000 or more at December 31, 2018 and 2017 were $756 
million and $797 million, respectively.

Time deposit maturities are as follows:  2019 – $1.3 billion, 2020 – $262 million, 2021 – $98 million, 2022 – $115 million, 
2023 – $130 million and $211 million thereafter. 

The aggregate amount of overdrawn customer transaction deposits that have been reclassified as loan balances was $27 million 
at December 31, 2018 and $5.9 million at December 31, 2017.

124

(9) Other Borrowings 

Information relating to other borrowings is summarized as follows (dollars in thousands):

As of

Year Ended

December 31, 2018

December 31, 2018

Balance

Rate

Average
Balance

Rate

Maximum
Outstanding
At Any
Month End

Parent company and other non-bank subsidiaries:

Other borrowings

Subordinated debentures

Total parent company and other non-bank subsidiaries

$

5,207

1.57% $

2,660

1.35% $

275,913

281,120

5.34%

177,884

180,544

5.52%

5.46%

Subsidiary banks:

Funds purchased

Repurchase agreements

Other borrowings:

Federal Home Loan Bank advances

GNMA repurchase liability

Other

Total other borrowings

Subordinated debentures

Total Subsidiary banks

402,450

615,961

2.34%

0.36%

419,322

464,582

1.89%

0.28%

6,100,000

2.65% 6,207,142

15,552

3,631

4.43%

4.80%

6,119,183

14,783

11,856

6,233,781

—

—%

—

2.06%

4.47%

4.45%

2.07%

—%

7,137,594

7,117,685

1.94%

Total other borrowed funds

$

7,418,714

$ 7,298,229

2.03%

5,335

275,913

949,531

615,961

6,500,000

16,529

15,096

—

As of

Year Ended

December 31, 2017

December 31, 2017

Balance

Rate

Average
Balance

Rate

Maximum
Outstanding
At Any
Month End

Parent company and other non-bank subsidiaries:

Other borrowings

Subordinated debentures

Total parent company and other non-bank subsidiaries

$

—

—% $

935

11.11% $

144,677

144,677

5.60%

147,954

148,889

5.57%

5.65%

Subsidiary banks:

Funds purchased

Repurchase agreements

Other borrowings:

Federal Home Loan Bank advances

GNMA repurchase liability

Other

Total other borrowings

Subordinated debentures

Total Subsidiary banks

58,628

516,335

1.00%

0.17%

58,064

433,791

0.73%

0.10%

5,100,000

1.47% 5,882,466

19,947

14,950

4.22%

2.61%

5,134,897

20,509

15,382

5,918,357

—

—%

—

1.13%

4.59%

2.38%

1.14%

—%

5,709,860

6,410,212

1.07%

Total other borrowed funds

$

5,854,537

$ 6,559,101

1.18%

125

3,104

151,875

80,967

536,094

6,200,000

24,139

15,506

—

As of

Year Ended

December 31, 2016

December 31, 2016

Balance

Rate

Average
Balance

Rate

Maximum
Outstanding
At Any
Month End

Parent company and other non-bank subsidiaries:

Other borrowings

Subordinated debentures

Total parent company and other non-bank subsidiaries

$

1,092

8.27% $

2,073

16.11% $

151,857

152,949

5.49%

75,039

77,112

5.57%

5.86%

Subsidiary banks:

Funds purchased

Repurchase agreements

Other borrowings:

Federal Home Loan Bank advances

GNMA repurchase liability

Other

Total other borrowings

Subordinated debentures

Total Subsidiary banks

57,929

668,661

0.38%

0.02%

78,222

589,145

0.24%

0.04%

4,800,000

0.72% 5,985,656

22,471

15,292

4.26%

2.66%

4,837,763

15,637

15,670

6,016,963

—

—%

140,414

5,564,353

6,824,744

0.55%

4.74%

2.41%

0.57%

1.35%

0.54%

Total other borrowed funds

$

5,717,302

$ 6,901,856

0.60%

Aggregate annual principal repayments at December 31, 2018 are as follows (in thousands):

3,157

151,857

567,103

668,661

6,500,000

22,471

15,797

226,434

2019

2020

2021

2022

2023

Thereafter

Total

Parent
Company 
and Other 
Non-bank 
Subsidiaries

Subsidiary
Banks

$

— $

7,134,538

—

—

—

—

281,120

575

575

575

625

706

$

281,120

$

7,137,594

Funds purchased are unsecured and generally mature within one day to ninety days from the transaction date. Securities 
repurchase agreements are recorded as secured borrowings that generally mature within ninety days and are secured by certain 
available for sale securities. 

126

Additional information relating to securities sold under agreements to repurchase and related liabilities at December 31, 2018 
and 2017 is as follows (dollars in thousands):

Security Sold/Maturity

U.S. government agency mortgage-backed securities:

Overnight1
Long-term

Total Agency Securities

Security Sold/Maturity

U.S. government agency mortgage-backed securities:

Overnight1
Long-term

Total Agency Securities

December 31, 2018

Amortized

Cost

Fair

Value

Repurchase
Liability1

Average

Rate

636,864

—

636,864

$

$

628,229

—

628,229

$

$

615,961

—

615,961

0.36%

—%

0.36%

December 31, 2017

Amortized

Cost

Fair

Value

Repurchase
Liability1

Average

Rate

525,452

—

525,452

$

$

523,914

—

523,914

$

$

516,335

—

516,335

0.17 %

— %

0.17 %

$

$

$

$

1  BOK Financial maintains control over the securities underlying overnight repurchase agreements and generally transfers control over securities underlying 

longer-term dealer repurchase agreements to the respective counterparty.

Borrowings from the Federal Home Loan Banks are used for funding purposes. In accordance with policies of the Federal 
Home Loan Banks, BOK Financial has granted a blanket pledge of eligible assets (generally unencumbered U.S. Treasury and 
residential mortgage-backed securities, 1-4 family loans and multifamily loans) as collateral for these advances. The Federal 
Home Loan Banks have issued letters of credit totaling $266 million to secure BOK Financial’s obligations to depositors of 
public funds. The unused credit available to BOK Financial at December 31, 2018 pursuant to the Federal Home Loan Bank’s 
collateral policies is $1.9 billion.

In 2016, BOK Financial issued $150 million of subordinated debt that will mature on June 30, 2056. Interest on this debt bears 
an interest rate of 5.375%, payable quarterly. On June 30, 2021, BOK Financial will have the option to redeem the debt at the 
principal amount plus accrued interest, subject to regulatory approval. 

As a result of the acquisition of CoBiz Financial, we obtained $60 million of subordinated debt issued in June 2015 that will 
mature on June 25, 2030. This debt bears interest at the rate of 5.625% through June 2025 and thereafter, the notes will bear 
interest at an annual floating rate equal to three-month LIBOR plus 3.17%. The debt contains a call option that allows for 
repayment prior to contractual maturity. The call option is available on June 25, 2025 and quarterly thereafter at 100% of the 
principal amount.  

Also through CoBiz Financial, we acquired junior subordinated debentures split across three issuance tranches. Junior 
subordinated debentures of $21 million will mature September 17, 2033 and bear an interest rate of three-month LIBOR plus 
2.95% that resets quarterly. Junior subordinated debentures of $31 million will mature on July 23, 2034 and bear an interest rate 
of three-month LIBOR plus 2.60% that resets quarterly. Junior subordinated debentures of $20 million will mature on 
September 30, 2035 and bear an interest rate of three-month LIBOR plus 1.45% that resets quarterly. The junior subordinated 
debentures are subject to early redemption prior to maturity. 

In conjunction with the acquisition of MBT, BOK Financial assumed $7.2 million of variable rate subordinated trust preferred 
debt. Interest was payable quarterly at three-month LIBOR plus 2.95% on $3.1 million and three-month LIBOR plus 1.82% on 
$4.1 million. This trust preferred debt was redeemed during 2017. 

BOK Financial Securities, Inc. may borrow funds from Pershing, LLC ("Pershing"), a clearing broker/dealer and a wholly 
owned subsidiary of Bank of New York Mellon, for the purposes of financing securities purchases or to facilitate funding of 
investment banking activities, on terms to be negotiated at the time of the borrowing. BOK Financial Securities, Inc. had no 
borrowings from Pershing outstanding at December 31, 2018 or December 31, 2017.

127

In 2007, BOKF, NA issued $250 million of subordinated debt due May 15, 2017. Interest on this debt was based upon a fixed 
rate of 5.75% through May 14, 2012 and is based on a floating rate of three-month LIBOR plus 0.69% thereafter. The 
outstanding balance was called during 2016.

The Company has a liability related to the repurchase of certain delinquent residential mortgage loans previously sold into 
GNMA mortgage pools. Interest is payable at rates contractually due to investors.

128

(10) Federal and State Income Taxes 

The Tax Cuts and Jobs Act (the "Tax Reform Act"), which was enacted on December 22, 2017, reduced the federal corporate 
tax rate from 35% to 21% for periods beginning January 1, 2018. We completed our accounting during 2018 for uncertainties 
that resulted from the Tax Reform Act. 

Deferred income taxes reflect the net tax effects of temporary differences between the carrying amounts of assets and liabilities 
for financial reporting purposes and the amounts used for income tax purposes. Significant components of deferred tax assets 
and liabilities are as follows (in thousands):

December 31,

2018

2017

Deferred tax assets:

Available for sale securities mark to market

$

24,441

$

Share-based compensation

Credit loss allowances

Valuation adjustments

Deferred compensation

Unearned fees

Purchased loan discount

Other

Total deferred tax assets

Deferred tax liabilities:

Depreciation

Mortgage servicing rights

Lease financing

Acquired identifiable intangible

Other

Total deferred tax liabilities

Net deferred tax assets

4,434

49,804

9,619

25,608

9,814

27,283

31,812

182,815

13,901

61,844

10,040

28,620

32,954

147,359

$

35,456

$

12,083

7,598

58,666

8,102

12,215

9,265

—

30,859

138,788

15,817

63,112

9,973

—

34,880

123,782

15,006

No valuation allowance was necessary on deferred tax assets as of December 31, 2018 and 2017.

The significant components of the provision for income taxes attributable to continuing operations for BOK Financial are 
shown below (in thousands):

Current income tax expense:

Federal

State

Total current income tax expense

Deferred income tax expense:

Federal

State

Total deferred income tax expense

Total income tax expense

Year Ended December 31,

2018

2017

2016

$

103,748

$

141,607

$

107,379

15,253

119,001

14,592

156,199

11,028

118,407

(190)

250

60

25,525

869

26,394

(11,340)

(690)

(12,030)

$

119,061

$

182,593

$

106,377

129

The reconciliations of income attributable to continuing operations at the U.S. federal statutory tax rate to income tax expense 
are as follows (in thousands):

Amount:

Federal statutory tax

Tax exempt revenue

Effect of state income taxes, net of federal benefit

Utilization of tax credits, net of proportional amortization of low-income housing limited

partnership investments

Share-based compensation

Implementation of Tax Reform Act

Deposit insurance

Other, net

Total income tax expense

Percent of pretax income:

Federal statutory tax

Tax exempt revenue

Effect of state income taxes, net of federal benefit

Utilization of tax credits, net of proportional amortization of low-income housing limited

partnership investments

Share-based compensation

Implementation of Tax Reform Act

Deposit insurance

Other, net

Total

Year Ended December 31,

2018

2017

2016

$

118,752

$

181,397

$

118,530

(8,311)

12,430

(4,559)

(2,105)

(1,728)

3,099

1,483

(12,402)

10,701

(6,811)

(2,817)

11,672

—

853

(10,544)

6,478

(6,256)

—

—

—

(1,831)

$

119,061

$

182,593

$

106,377

Year Ended December 31,

2018

2017

2016

21.0%

35.0%

35.0%

(1.5)

2.2

(0.8)

(0.4)

(0.3)

0.5

0.4

(2.4)

2.0

(1.3)

(0.5)

2.3

—

0.1

21.1%

35.2%

(3.1)

1.9

(1.8)

—

—

—

(0.6)

31.4%

A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows (in thousands):

Balance as of January 1

Additions for tax for current year positions

Settlements during the period

Lapses of applicable statute of limitations

Balance as of December 31

2018

2017

2016

$

18,110

$

15,841

$

2,649

—

(1,890)

4,645

—

(2,376)

$

18,869

$

18,110

$

13,232

5,640

—

(3,031)

15,841

Of the above unrecognized tax benefits, $12.9 million, if recognized, would have affected the effective tax rate.

BOK Financial recognizes interest and penalties accrued related to unrecognized tax benefits in income tax expense. The 
Company recognized $1.7 million for 2018, $1.2 million for 2017 and $1.0 million for 2016 in interest and penalties. The 
Company had approximately $5.0 million and $4.0 million accrued for the payment of interest and penalties at December 31, 
2018 and 2017, respectively. Federal statutes remain open for federal tax returns filed in the previous three reporting periods. 
Various state income tax statutes remain open for the previous three to six reporting periods. 

130

(11) Employee Benefits 

BOK Financial sponsors a defined benefit cash balance Pension Plan for all employees who satisfy certain age and service 
requirements. Pension Plan benefits were curtailed as of April 1, 2006. No participants may be added to the plan and no 
additional service benefits will be accrued. During 2018 and 2017, interest accrued on employees' account balances at a 
variable rate tied to the five-year trailing average of five-year U.S. Treasury securities plus 1.5%. The rate has a floor of 3.0% 
and a ceiling of 5.0%. The 2018 quarterly variable rates ranged from 3.00% to 3.24%.

The following table presents information regarding this plan (in thousands):

Change in projected benefit obligation:

Projected benefit obligation at beginning of year

Interest cost

Actuarial loss (gain)

Benefits paid

Projected benefit obligation at end of year1,2
Change in plan assets:

Plan assets at fair value at beginning of year

Actual return on plan assets

Benefits paid

Plan assets at fair value at end of year

Funded status of the plan

Components of net periodic benefit:

Interest cost

Expected return on plan assets

Other

Net periodic benefit cost (credit)
1  Projected benefit obligation equals accumulated benefit obligation.
2  Projected benefit obligation is based on January 1 measurement date.

Weighted-average assumptions as of December 31:

Discount rate

Expected return on plan assets

December 31,

2018

2017

$

30,897

$

34,964

973

(1,417)

(6,033)

24,547

40,419

(804)

(6,033)

33,582

9,035

973

(2,065)

509

$

$

$

$

$

(583) $

1,153

223

(5,443)

30,897

41,769

4,093

(5,443)

40,419

9,522

1,153

(2,041)

184

(704)

$

$

$

$

$

$

2018

2017

4.10%

5.50%

3.30%

5.50%

As of December 31, 2018, expected future benefit payments related to the Pension Plan were as follows (in thousands):

2019

2020

2021

2022

2023

Thereafter

Total estimated future benefit payments

$

$

3,562

2,257

2,194

2,299

2,495

19,175

31,982

131

Assets of the Pension Plan consist primarily of shares in the Cavanal Hill Active Core Fund. The stated objective of this fund is 
to provide an attractive total return with a well-balanced mix of equities and bonds. The typical portfolio mix is approximately 
60% equities and 40% bonds. The net asset value of shares in the Cavanal Hill Funds is reported daily based on market 
quotations for the Fund’s securities. Management considers the Fund's recent and long-term performance as indicators when 
setting the expected return on plan assets. The maximum tax deductible Pension Plan contribution for 2018 was $6.6 million. 
No minimum contribution was required for 2018, 2017 or 2016. 

Employee contributions to the Thrift Plan are eligible for Company matching equal to 6% of base compensation, as defined in 
the plan. The Company-provided matching contribution rates range from 50% for employees with less than 4 years of service 
to 200% for employees with 15 or more years of service. Additionally, a maximum Company-provided, non-elective annual 
contribution of up to $750 per participant is provided for employees whose annual base compensation is less than $40,000. 
Participants may direct investments in their accounts to a variety of options, including a BOK Financial common stock fund 
and Cavanal Hill funds. Employer contributions, which are invested in accordance with the participant’s investment options, 
vest over five years. Thrift Plan expenses were $25.1 million for 2018, $22.8 million for 2017 and $22.4 million for 2016.

132

(12) Share-Based Compensation Plans 

The shareholders and Board of Directors of BOK Financial have approved various share-based compensation plans. An 
independent compensation committee of the Board of Directors determines the number of awards granted to the Chief 
Executive Officer and other senior executives. Share-based compensation is granted to other officers and employees as 
determined by the Chief Executive Officer.

The following table presents stock options outstanding under these plans (in thousands, except for per share data):

Options outstanding at:

December 31, 2016

December 31, 2017

December 31, 2018

Options vested at:

December 31, 2016

December 31, 2017

December 31, 2018

Weighted-
Average
Exercise
Price

Aggregate
Intrinsic
Value

Number

218,524

117,551

63,058

93,117

51,286

33,573

$

$

51.95

53.26

54.89

46.22

48.62

53.09

$

$

6,793

4,592

1,163

3,429

2,241

679

No options have been awarded since 2013. At December 31, 2018, the weighted average remaining contractual life of options 
outstanding was 2.12 years and the weighted average remaining contractual life of vested options was 1.04 years. The 
aggregate intrinsic value of options exercised was $2.3 million for 2018, $3.5 million for 2017 and $6.2 million for 2016.

The Company also awards non-vested shares to certain officers and employees. Vesting of all non-vested shares is subject to 
service requirements. Additionally, vesting of certain non-vested shares is subject to performance criteria based on changes in 
the Company's earnings per share relative to defined peers. The following represents a summary of the non-vested stock awards 
for the three years ended December 31, 2018 (in thousands):

Non-vested at January 1, 2016

   Granted

   Vested

   Forfeited

Non-vested at December 31, 2016

   Granted

   Vested

   Forfeited

Non-vested at December 31, 2017

   Granted

   Vested

   Forfeited

Non-vested at December 31, 2018

Weighted
Average
Grant Date
Fair Value

$55.35

$55.87

$57.86

$86.95

$63.07

$78.70

$85.58

$74.85

$75.68

Shares

791,109

256,670

(213,941)

(47,132)

786,706

177,807

(194,419)

(102,991)

667,103

150,419

(242,215)

(47,700)

527,607

Compensation expense recognized on non-vested shares totaled $3.6 million for 2018, $23.2 million for 2017 and $10.2 million 
for 2016. Unrecognized compensation cost of non-vested shares totaled $14.2 million at December 31, 2018. We expect to 
recognize compensation expense of $9.7 million in 2019, $4.3 million in 2020, and $138 thousand in 2021. 

Compensation cost for 189,179 non-vested shares is variable based on the current fair value of BOK Financial common shares. 
Vesting of 188,827 non-vested shares may be increased or decreased based on performance criteria defined in the plan 
documents. 

133

(13) Related Parties 

In compliance with applicable banking regulations, the Company may extend credit to certain executive officers, directors, 
principal shareholders and their affiliates (collectively referred to as “related parties”) in the ordinary course of business. The 
Company’s loans to related parties do not involve more than the normal credit risk. 

Activity in loans to related parties is summarized as follows (in thousands):

Beginning balance

Advances

Payments
Adjustments1
Ending balance
1  Adjustments generally consist of changes in status as a related party. 

Year Ended December 31,

2018

2017

$

110,246

$

136,945

1,479,735

1,559,291

(1,514,841)

(1,585,865)

125

(125)

$

75,265

$

110,246

As defined by banking regulations, loan commitments and equity investments from the subsidiary banks to a single affiliate 
may not exceed 10% of unimpaired capital and surplus while loan commitments and equity investments to all affiliates may not 
exceed 20% of unimpaired capital and surplus. All loans to affiliates must be fully secured by eligible collateral. At 
December 31, 2018, loan commitments and equity investments were limited to $310 million to a single affiliate and $621 
million to all affiliates. The largest loan commitment and equity investment to a single affiliate was $253 million and the 
aggregate loan commitments and equity investments to all affiliates were $313 million. The largest outstanding amount to a 
single affiliate at December 31, 2018 was $883 thousand and the total outstanding amounts to all affiliates were $883 
thousand. At December 31, 2017, total loan commitments and equity investments to all affiliates were $323 million and the 
total outstanding amounts to all affiliates were $16 million.

We have $4.7 million of impaired loans from a related party with no allowance as the fair value of the collateral exceeds the 
outstanding principal balance at December 31, 2018. There were no nonaccruing or impaired related party loans outstanding at 
December 31, 2017.

Certain related parties are customers of the Company for services other than loans, including consumer banking, corporate 
banking, risk management, wealth management, brokerage and trading, or fiduciary/trust services. The Company engages in 
transactions with related parties in the ordinary course of business in compliance with applicable regulations.

The Company rents office space in facilities owned by affiliates of Mr. Kaiser, its Chairman and principal shareholder. Lease 
payments totaled $683 thousand for 2018, $1.0 million for 2017 and $1.1 million for 2016. The Company also invested $3.1 
million and $580 thousand during the years ended 2018 and 2017, respectively, in QRC Valve Distributors, which is indirectly 
owned by Mr. Kaiser.

QuikTrip Corporation has entered into a fee sharing agreement with TransFund, BOKF’s electronic funds transfer network 
(“TransFund”), respecting transactions completed at TransFund automated teller machines placed in QuikTrip locations. In 
2018, BOKF paid QuikTrip approximately $9.2 million pursuant to this agreement. A BOK Financial director, is Chief 
Executive Officer, Chairman, and a significant shareholder of QuikTrip Corporation.

Cavanal Hill Investment Management, Inc., a wholly-owned subsidiary of BOKF, NA, is the administrator to and investment 
advisor for the Cavanal Hill Funds (the "Funds"), a diversified, open-ended investment company established as a business trust 
under the Investment Company Act of 1940 (the "1940 Act"). BOKF, NA is custodian and Cavanal Hill Distributors, Inc. is 
distributor for the Funds. The Funds’ products are offered to customers, employee benefit plans, trusts and the general public in 
the ordinary course of business. Approximately 89% of the Funds’ assets of $3.4 billion are held for the Company's clients. A 
Company executive officer serves on the Funds' board of trustees and officers of BOKF, NA serve as president and secretary of 
the Funds. A majority of the members of the Funds’ board of trustees are, however, independent of the Company and the Funds 
are managed by its board of trustees.

134

(14)  Commitments and Contingent Liabilities 

Litigation Contingencies

As a member of Visa, BOK Financial is obligated for a proportionate share of certain covered litigation losses incurred by Visa 
under a retrospective responsibility plan. A contingent liability was recognized for the Company’s share of Visa’s covered 
litigation liabilities. Visa funded an escrow account to cover litigation claims, including covered litigation losses under the 
retrospective responsibility plan, with proceeds from its initial public offering in 2008 and from available cash.   

BOK Financial currently owns 252,233 Visa Class B shares which are convertible into 411,089 shares of Visa Class A shares 
after the final settlement of all covered litigation. Class B shares may be diluted in the future if the escrow fund is not adequate 
to cover future covered litigation costs. Therefore, no value has been currently assigned to the Class B shares and no value may 
be assigned until the Class B shares are converted into a known number of Class A shares.

On June 24, 2015, BOKF, NA received a complaint alleging that an employee had colluded with a bond issuer and an 
individual in misusing revenues pledged to municipal bonds for which BOKF, NA served as trustee under the bond indenture. 
The Company conducted an investigation and concluded that employees in one of its Corporate Trust offices had, with respect 
to a single group of affiliated bond issuances, violated Company policies and procedures by waiving financial covenants, 
granting forbearances and accepting without disclosure to the bondholders, debt service payments from sources other than 
pledged revenues. The relationship manager was terminated. The Company reported the circumstances to, and cooperated with 
an investigation by, the Securities and Exchange Commission ("SEC").

 On December 28, 2015, in an action brought by the SEC, the United States District Court for the District of New Jersey 
entered a judgment against the principals involved in issuing the bonds, precluding the principals from denying the alleged 
violations of the federal securities laws and requiring the principals to pay all outstanding principal, accrued interest, and other 
amounts required under the bond documents (now estimated to be approximately $40 million, less the value of the facilities 
securing repayment of the bonds), subject to oversight by a court appointed monitor. The obligation of the principal to pay all 
principal and interest on the bonds is non-dischargeable in bankruptcy. 

On September 7, 2016, BOKF, NA agreed, and the SEC entered, a consent order finding that the BOKF, NA had violated 
Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act and requiring the BOKF, NA to 
disgorge $1,067,721 of fees and pay a civil penalty of $600,000. The BOKF, NA has disgorged the fees and paid the penalty.  

On August 26, 2016, the BOKF, NA was sued in the United States District Court for New Jersey by two bondholders in a 
putative class action on behalf of all holders of the bonds alleging the BOKF, NA participated in the fraudulent sale of 
securities by the principals. On September 14, 2016, the BOKF, NA was sued in the District Court of Tulsa County, Oklahoma 
by 19 bondholders alleging the BOKF, NA participated in the fraudulent sale of securities by the principals. Two separate small 
groups of bondholders have filed arbitration complaints with the Financial Institutions Regulatory Association respecting the 
bonds and other bonds for which the BOKF, NA served as indenture trustee. Management has been advised by counsel that the 
BOKF, NA has valid defenses to the claims. 

The time by which the principal must perform the Court ordered payment plan currently expires on March 31, 2019. BOKF, 
NA expects the Court ordered payment plan to be continued from time to time until the principals complete the payment of the 
bonds, though there is no assurance that it will be. Accordingly, no loss is probable at this time and no provision for loss has 
been made. If the payment plan does not result in payment of the bonds, a loss could become probable. A reasonable estimate 
cannot be made at this time though the amount could be material to the Company.  

On March 5, 2018, BOKF, NA was sued in the Fulton, Georgia County District Court by the administratrix of a deceased 
resident who had sued for and obtained a judgment for wrongful death against one of the operators of a nursing home financed 
by one of the bonds which are the subject of the litigation discussed above. The judgment is alleged to total approximately $8 
million in principal and interest at this time. Plaintiff alleges that BOKF, in its capacity as indenture trustee for the bonds, 
colluded with the borrower and others to defraud creditors of the nursing home by misleading the public about the solvency of 
the nursing home. Plaintiff alleges that this conduct has prevented her from collecting on her judgment. BOKF, NA is advised 
by counsel that the BOKF, NA has valid defenses to the plaintiffs’ claims and no loss is probable.

135

On March 14, 2017, BOKF, NA was sued in the United States District Court for the Northern District of Oklahoma by 
bondholders in a second putative class action representing a different set of municipal securities. The bondholders in this 
second action allege two individuals purchased facilities from the principals who are the subject of the SEC New Jersey 
proceedings by means of the fraudulent sale of $60 million of municipal securities for which BOKF, NA also served as 
indenture trustee. The bondholders allege BOKF, NA failed to disclose that the seller of the purchased facilities had engaged in 
the conduct complained of in the New Jersey action. BOKF, NA properly performed all duties as indenture trustee of this 
second set of municipal securities, timely commenced proceedings against the issuer of the securities when default occurred, is 
cooperating with the SEC in actions against the two principals, is not a target of the SEC proceedings, and has been advised by 
counsel that BOKF, NA has valid defenses to the claims of these bondholders. Management is advised by counsel that a loss is 
not probable and that the loss, if any, cannot be reasonably estimated.

On March 7, 2017, a plaintiff filed a putative class action in the United States District Court for the Northern District of Texas 
alleging an extended overdraft fee charged by BOKF, NA is interest and exceeds permitted rates. This action makes the same 
allegations as a putative class action that was dismissed by the United States District Court for the Northern District of 
Oklahoma on October 19, 2015. On August 22, 2018, a plaintiff filed a second putative class action in the United States District 
Court for New Mexico making the same allegations as the Texas action. On September 18, 2018, the District Court dismissed 
the Texas action. Management is advised by counsel that a loss is not probable in the New Mexico action or the Texas action 
and that the loss, if any, cannot be reasonably estimated.

On July 6, 2018, a plaintiff served a petition in a putative class action in the Oklahoma District Court for Tulsa County 
Oklahoma alleging BOKF NA breached its Demand Deposit Agreements by charging overdraft and not sufficient funds fees to 
deposit accounts on the day of the transaction triggering the fee and by the bank's debit hold process causing overdraft fees.  
Management is advised by counsel that a loss is not probable and that the loss, if any, cannot be reasonably estimated.

In the ordinary course of business, BOK Financial and its subsidiaries are subject to legal actions and complaints. Management 
believes, based upon the opinion of counsel, that the actions and liability or loss, if any, resulting from the final outcomes of the 
proceedings, will not have a material effect on the Company’s financial condition, results of operations or cash flows.

Alternative Investment Commitments

The Company sponsors two private equity funds and invests in several tax credit entities and other funds as permitted by 
banking regulations. Consolidation of these investments is based on the variable interest model. 

BOKF Equity, LLC, an indirect wholly-owned subsidiary, is the general partner of two consolidated private equity funds (“the 
Funds”). The Funds provide alternative investment opportunities to certain customers, some of which are related parties, 
through unaffiliated limited partnerships. Substantially all committed capital invested by these Funds has been returned to the 
partners. 

Consolidated tax credit entities represented the Company's interest in entities earning federal new market tax credits related to 
qualifying loans. These entities were liquidated in 2018.

The Company also has interests in various alternative investments generally consisting of unconsolidated limited partnership 
interests in entities for which investment return is in the form of low income housing tax credits or other investments in 
merchant banking activities. The Company is prohibited by banking regulations from controlling or actively managing the 
activities of these investments and the Company's maximum exposure to loss is restricted to its investment balance. The 
Company's obligation to fund alternative investments is included in Other liabilities in the Consolidated Balance Sheets. 

136

A summary of consolidated and unconsolidated alternative investments as of December 31, 2018 and December 31, 2017 is as 
follows (in thousands):

Consolidated:

Private equity funds

Tax credit entities

Other

Total consolidated

Unconsolidated:

Tax credit entities

Other

Total unconsolidated

Consolidated:

Private equity funds

Tax credit entities

Other

Total consolidated

Unconsolidated:

Tax credit entities

Other

Total unconsolidated

December 31, 2018

Loans

Other
Assets

Other
Liabilities

Other
Borrowings

Non-
controlling
Interests

— $

9,516

$

— $

— $

—

—

—

17,602

—

1,448

—

5,207

— $

27,118

$

1,448

$

5,207

$

8,644

—

2,292

10,936

58,981

$ 165,567

—

62,406

58,981

$ 227,973

$

$

53,198

20,687

73,885

$

$

— $

—

— $

—

—

—

$

$

$

$

December 31, 2017

Loans

Other
Assets

Other
Liabilities

Other
Borrowings

Non-
controlling
Interests

$

— $

14,783

$

— $

— $

10,000

—

10,964

1,040

—

—

10,964

—

$

10,000

$

26,787

$

— $

10,964

$

11,927

10,000

1,040

22,967

$

$

52,852

$ 153,506

—

38,397

52,852

$ 191,903

$

$

47,859

22,968

70,827

$

$

— $

—

— $

—

—

—

Other Commitments and Contingencies

Cavanal Hill Funds’ assets include U.S. Treasury and government securities money market funds. Assets of these funds consist 
of highly-rated, short-term obligations of the U.S. Treasury and Agencies. The net asset value of units in these funds was $1.00 
at December 31, 2018. An investment in these funds is not insured by the Federal Deposit Insurance Corporation or guaranteed 
by BOK Financial or any of its subsidiaries. BOK Financial may, but is not obligated to purchase assets from these funds to 
maintain the net asset value at $1.00. No assets were purchased from the funds in 2018 or 2017.

Total rent expense for BOK Financial was $28.5 million in 2018, $27.5 million in 2017 and $25.8 million in 2016. At 
December 31, 2018, future minimum lease payments for premises under operating leases were as follows: $25.8 million in 
2019, $24.8 million in 2020, $21.3 million in 2021, $15.2 million in 2022, $13.0 million in 2023 and $78.6 million thereafter. 
BOKF, NA is obligated under a long-term lease for its bank premises in downtown Tulsa. The lease term, which began 
November 1, 1976, is for fifty-seven years with an option to terminate in 2024 with a two-year prior written notice. Premises 
leases may include options to renew at then current market rates and may include escalation provisions based upon changes in 
consumer price index or similar benchmarks.

The Federal Reserve Bank requires member banks to maintain certain minimum average cash balances. Member banks may 
satisfy reserve balance requirements through holdings of vault cash and balances maintained directly with a Federal Reserve 
Bank. The combined average balance of vault cash and balances held at the Federal Reserve Bank was $1.2 billion for the year 
ended December 31, 2018 and $1.9 billion for the year ended December 31, 2017.

137

(15) Shareholders Equity 

Preferred Stock

One billion shares of preferred stock with a par value of $0.00005 per share are authorized. The Series A Preferred Stock has no 
voting rights except as otherwise provided by Oklahoma corporate law and may be converted into one share of Common Stock 
for each 36 shares of Series A Preferred Stock at the option of the holder. Dividends are cumulative at an annual rate of ten 
percent of the $0.06 per share liquidation preference value when declared and are payable in cash. Aggregate liquidation 
preference is $15 million. No Series A Preferred Stock was outstanding in 2018, 2017 or 2016.

Common Stock

Common stock consists of 2.5 billion authorized shares with a $0.00006 par value. Holders of common shares are entitled to 
one vote per share at the election of the Board of Directors and on any question arising at any shareholders’ meeting and to 
receive dividends when and as declared. Additionally, regulations restrict the ability of national banks and bank holding 
companies to pay dividends.

Subsidiary Banks

The amounts of dividends that BOK Financial’s subsidiary banks can declare and the amounts of loans the subsidiary banks can 
extend to affiliates are limited by various federal banking regulations and state corporate law. Generally, dividends declared 
during a calendar year are limited to net profits, as defined, for the year plus retained profits for the preceding two years. The 
amounts of dividends are further restricted by minimum capital requirements. 

Regulatory Capital

BOK Financial and the subsidiary banks are subject to various capital requirements administered by the federal banking 
agencies. Failure to meet minimum capital requirements can initiate certain mandatory and additional discretionary actions by 
regulators that could have a material effect on BOK Financial's operations. These capital requirements include quantitative 
measures of assets, liabilities and certain off-balance sheet items. The capital standards are also subject to qualitative judgments 
by the regulators.

New capital rules were effective for BOK Financial on January 1, 2015. Components of these rules will phase in through 
January 1, 2019. A bank falling below the minimum capital requirements, including the capital conservation buffer, would be 
subject to regulatory restrictions on capital distributions (including but not limited to dividends and share repurchases) and 
executive bonus payments. For a banking institution to qualify as well capitalized, Common Equity Tier 1, Tier I, Total and 
Leverage capital ratios must be at least 6.5%, 8%, 10% and 5%, respectively. Tier I capital consists primarily of common 
stockholders' equity, excluding unrealized gains or losses on available for sale securities, less goodwill, core deposit premiums 
and certain other intangible assets. Total capital consists primarily of Tier I capital plus preferred stock, subordinated debt and 
allowances for credit losses, subject to certain limitations. The subsidiary banks exceeded the regulatory definition of well 
capitalized as of December 31, 2018 and December 31, 2017.

138

A summary of regulatory capital minimum requirements and levels follows (dollars in thousands):

Minimum
Capital
Requirement

Capital 
Conservation 
Buffer1

Minimum
Capital
Requirement
Including
Capital
Conservation
Buffer

Well
Capitalized
Bank
Requirement

December 31, 2018

December 31, 2017

Common Equity Tier 1
Capital (to Risk
Weighted Assets):

Consolidated

BOKF, NA
CoBiz Bank2

Tier I Capital (to Risk
Weighted Assets):

Consolidated

BOKF, NA
CoBiz Bank2

Total Capital (to Risk
Weighted Assets):

Consolidated

BOKF, NA
CoBiz Bank2

Leverage (Tier I Capital
to Average Assets):

Consolidated

BOKF, NA
CoBiz Bank2

4.50%

4.50%

4.50%

6.00%

6.00%

6.00%

8.00%

8.00%

8.00%

4.00%

4.00%

2.50%

N/A

N/A

2.50%

N/A

N/A

2.50%

N/A

N/A

N/A

N/A

7.00%

4.50%

4.50%

8.50%

6.00%

6.00%

10.50%

8.00%

8.00%

N/A

6.50%

6.50%

$ 3,356,524

10.92% $ 3,074,981

2,894,119

10.50% 2,870,694

317,944

10.65%

399,768

N/A

8.00%

8.00%

$ 3,356,524

10.92% $ 3,074,981

2,894,119

10.50% 2,870,694

317,944

10.65%

399,768

N/A

$ 3,841,684

12.50% $ 3,455,709

10.00%

10.00%

3,103,366

11.26% 3,105,117

382,944

12.83%

434,012

4.00%

4.00%

N/A

5.00%

$ 3,356,524

8.96% $ 3,074,981

2,894,119

8.56% 2,870,694

12.05 %

11.34 %

12.19 %

12.05 %

11.34 %

12.19 %

13.54 %

12.27 %

13.23 %

9.31 %

8.73 %

10.47 %

399,768
1  Capital conservation buffer is effective January 1, 2016 and is phased in through 2019. The phased in capital conservation buffer was 

317,944

5.00%

4.00%

4.00%

8.25%

N/A

1.875% at December 31, 2018 and 1.25% at December 31, 2017. The fully phased in requirement of 2.50% is included in the table above. 

2  CoBiz Bank was acquired by BOK Financial effective October 1, 2018.

139

Accumulated Other Comprehensive Income (Loss)

AOCI includes unrealized gains and losses on available for sale ("AFS") securities and non-credit related unrealized losses on 
AFS securities for which an other-than-temporary impairment has been recorded in earnings. AOCI also includes unrealized 
gains on AFS securities that were transferred from AFS to investment securities in 2011. Such amounts were amortized over the 
estimated remaining life of the security as an adjustment to yield, offsetting the related amortization of premium on the 
transferred securities. Unrealized losses on employee benefit plans will be reclassified into income as pension plan costs are 
recognized over the remaining service period of plan participants. Gains and losses in AOCI are net of deferred income taxes.

A rollforward of the components of accumulated other comprehensive income (loss) is included as follows (in thousands):

Balance, December 31, 2015

Net change in unrealized gain (loss)

Reclassification adjustments included in earnings:

Interest revenue, Investment securities, Taxable securities

Gain on available for sale securities, net

Other comprehensive income (loss), before income taxes
Federal and state income tax1
Other comprehensive income (loss), net of income taxes

Balance, December 31, 2016

Net change in unrealized gain (loss)

Reclassification adjustments included in earnings:

Interest revenue, Investment securities, Taxable securities

Gain on available for sale securities, net

Other comprehensive income (loss), before income taxes
Federal and state income tax1
Other comprehensive income (loss), net of income taxes

Reclassification of stranded accumulated other comprehensive loss related to tax
reform

Balance, December 31, 2017

Transition adjustment for net unrealized gains on equity securities

Net change in unrealized gain (loss)

Reclassification adjustments included in earnings:

Interest revenue, Investment securities, Taxable securities

Loss on available for sale securities, net

Other comprehensive income (loss), before income taxes
Federal and state income tax2
Other comprehensive income (loss), net of income taxes

Unrealized Gain (Loss) on

Available
for Sale
Securities

Investment
Securities
Transferred
from AFS

Employee
Benefit
Plans

Total

$

23,284

$

(41,333)

—

(11,675)

(53,008)

(20,637)

(32,371)

(9,087)

(28,170)

—

(4,428)

(32,598)

(12,708)

(19,890)

(6,408)

(35,385)

(2,709)

(46,941)

—

2,801

(44,140)

(11,235)

(32,905)

68

—

(112)

—

(112)

(44)

(68)

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

$

(1,765) $

21,587

(188)

(41,521)

—

—

(188)

(73)

(115)

(1,880)

2,018

—

—

2,018

785

1,233

(142)

(789)

—

(112)

(11,675)

(53,308)

(20,754)

(32,554)

(10,967)

(26,152)

—

(4,428)

(30,580)

(11,923)

(18,657)

(6,550)

(36,174)

(2,709)

(1,069)

(48,010)

—

—

(1,069)

(272)

(797)

—

2,801

(45,209)

(11,507)

(33,702)

Balance, December 31, 2018
1  Calculated using a 39 percent blended federal and state statutory tax rate.
2  Calculated using a 25 percent blended federal and state statutory tax rate.

$

(70,999) $

— $

(1,586) $

(72,585)

140

(16)  Earnings Per Share 

The following table presents the computation of basic and diluted earnings per share (dollars in thousands, except per share 
data):

Year Ended

2018

2017

2016

Numerator:

Net income attributable to BOK Financial Corp. shareholders

$

445,646

$

334,644

$

232,668

Less: Earnings allocated to participating securities

Numerator for basic earnings per share – income available to common shareholders

Effect of reallocating undistributed earnings of participating securities

3,737

3,561

441,909

331,083

1

2

2,883

229,785

1

Numerator for diluted earnings per share – income available to common shareholders

$

441,910

$

331,085

$

229,786

Denominator:

Weighted average shares outstanding

67,190,257

65,440,832

65,901,110

Less:  Participating securities included in weighted average shares outstanding

561,617

695,468

815,483

Denominator for basic earnings per common share
Dilutive effect of employee stock compensation plans1
Denominator for diluted earnings per common share

Basic earnings per share

Diluted earnings per share
1  Excludes employee stock options with exercise prices greater than current market price.

(17)  Reportable Segments 

66,628,640

64,745,364

65,085,627

33,633

60,920

58,271

66,662,273

64,806,284

65,143,898

$

$

$

$

6.63

6.63

—

$

$

5.11

5.11

—

3.53

3.53

—

BOK Financial operates three principal lines of business: Commercial Banking, Consumer Banking and Wealth Management. 
Commercial Banking includes lending, treasury and cash management services and customer risk management products to 
small businesses, middle market and larger commercial customers. Commercial Banking also includes the TransFund EFT 
network. Consumer Banking includes retail lending and deposit services, lending and deposit services to small business 
customers served through the consumer branch network and all mortgage banking activities. Wealth Management provides 
fiduciary services, private bank services and investment advisory services in all markets. Wealth Management also underwrites 
state and municipal securities and engages in brokerage and trading activities. 

In addition to its lines of business, BOK Financial has a Funds Management unit. The primary purpose of this unit is to manage 
overall liquidity needs and interest rate risk. Each line of business borrows funds from and provides funds to the Funds 
Management unit as needed to support their operations. Operating results for Funds Management and Other include the effect 
of interest rate risk positions and risk management activities, securities gains and losses including impairment charges, the 
provision for credit losses in excess of net loans charged off, tax planning strategies and certain executive compensation costs 
that are not attributed to the lines of business. 

BOK Financial allocates resources and evaluates performance of its lines of business after allocation of funds, actual net credit 
losses and capital costs. In addition, we measure the performance of our business lines after allocation of certain indirect 
expenses and taxes on statutory rates. The allocation for the prior comparable periods have been revised on a comparable basis. 

The cost of funds borrowed from the Funds Management unit by the operating lines of business is transfer priced at rates that 
approximate market rates for funds with similar duration. Market rates are generally based on the applicable LIBOR or interest 
rate swap rates, adjusted for prepayment risk. This method of transfer-pricing funds that support assets of the operating lines of 
business tends to insulate them from interest rate risk.

141

The value of funds provided by the operating lines of business to the Funds Management unit is based on rates which 
approximate the wholesale market rates for funds with similar duration and re-pricing characteristics. Market rates are 
generally based on LIBOR or interest rate swap rates. The funds credit formula applied to deposit products with indeterminate 
maturities is established based on their re-pricing characteristics reflected in a combination of the short-term LIBOR rates and a 
moving average of an intermediate term swap rate, with an appropriate spread applied to both. Shorter duration products are 
weighted towards the short-term LIBOR rate and longer duration products are weighted towards intermediate swap rates. The 
expected duration ranges from 30 days for certain rate-sensitive deposits to five years.

Substantially all revenue is from domestic customers. No single external customer accounts for more than 10% of total 
revenue.

Net loans charged off and provision for credit losses represents net loans charged off as attributed to the lines of business and 
the provision for credit losses in excess of net charge-offs attributed to Funds Management and Other.

The operations of CoBiz, acquired on October 1, 2018 were not yet allocated to the operating segments at December 31, 2018. 
Accordingly, the operations, assets and liabilities of CoBiz were included in Funds Management and Other for 2018. The 
acquisition of Mobank on December 1, 2016 was allocated to the operating segments in  2017. 

Reportable segments reconciliation to the Consolidated Financial Statements for the year ended December 31, 2018 is as 
follows (in thousands):

Net interest and dividend revenue from external

sources

Net interest revenue (expense) from internal

sources

Net interest and dividend revenue

Provision for credit losses

Net interest and dividend revenue after

provision for credit losses

Other operating revenue

Other operating expense

Net direct contribution

Gain (loss) on financial instruments, net

Change in fair value of mortgage servicing

rights

Gain (loss) on repossessed assets, net

Corporate expense allocations

Net income before taxes

Federal and state income taxes

Net income

Net income attributable to non-controlling

interests

Net income attributable to BOK Financial Corp.

shareholders

Average assets

Commercial

Consumer

Wealth
Management

Funds
Management
and Other

BOK
Financial
Consolidated

$

726,856

$

83,231

$

81,527

$

93,253

$

984,867

(156,254)

570,602

30,358

540,244

162,701

192,811

510,134

26

—

(6,532)

45,818

457,810

121,434

336,376

73,448

156,679

5,143

151,536

178,123

210,187

119,472

(25,021)

4,668

247

63,700

35,666

9,085

26,581

31,505

113,032

(288)

113,320

296,369

248,959

160,730

7

—

—

44,190

116,547

30,003

86,544

51,301

144,554

(27,213)

171,767

(20,409)

376,209

(224,851)

24,988

(4,668)

6,285

(153,708)

(44,538)

(41,461)

(3,077)

—

984,867

8,000

976,867

616,784

1,028,166

565,485

—

—

—

—

565,485

119,061

446,424

—

—

—

778

778

$

336,376

$ 18,431,411

$

$

26,581

$

86,544

8,303,262

$

8,446,006

$

$

(3,855) $

445,646

(243,149) $

34,937,530

142

Reportable segments reconciliation to the Consolidated Financial Statements for the year ended December 31, 2017 is as 
follows (in thousands):

Net interest and dividend revenue from external

sources

Net interest revenue (expense) from internal

sources

Net interest and dividend revenue

Provision for credit losses

Net interest and dividend revenue after

provision for credit losses

Other operating revenue

Other operating expense

Net direct contribution

Gain (loss) on financial instruments, net

Change in fair value of mortgage servicing

rights

Gain (loss) on repossessed assets, net

Corporate expense allocations

Net income before taxes

Federal and state income taxes

Net income

Net income attributable to non-controlling

interests

Net income attributable to BOK Financial Corp.

shareholders

Commercial

Consumer

Wealth
Management

Funds
Management
and Other

BOK
Financial
Consolidated

$

618,325

$

84,286

$

45,024

$

94,066

$

841,701

(89,106)

529,219

13,877

515,342

208,404

228,119

495,627

52

—

(2,681)

34,253

458,745

188,241

270,504

53,916

138,202

4,786

133,416

184,878

221,679

96,615

(2,054)

172

223

67,320

27,636

10,750

16,886

38,344

83,368

(696)

84,064

301,434

246,626

138,872

—

—

387

40,562

98,697

38,848

59,849

(3,154)

90,912

(24,967)

115,879

378

329,093

(212,836)

2,002

(172)

2,071

(142,135)

(66,800)

(55,246)

(11,554)

—

841,701

(7,000)

848,701

695,094

1,025,517

518,278

—

—

—

—

518,278

182,593

335,685

—

—

—

1,041

1,041

$

270,504

$

16,886

$

59,849

$

$

(12,595) $

334,644

(399,899) $

32,947,494

Average assets

$ 17,730,654

$

8,544,117

$

7,072,622

143

Reportable segments reconciliation to the Consolidated Financial Statements for the year ended December 31, 2016 is as 
follows (in thousands):

Net interest and dividend revenue from external

sources

Net interest revenue (expense) from internal

sources

Net interest and dividend revenue

Provision for credit losses

Net interest and dividend revenue after

provision for credit losses

Other operating revenue

Other operating expense

Net direct contribution

Gain (loss) on financial instruments, net

Change in fair value of mortgage servicing

rights

Gain on repossessed assets, net

Corporate expense allocations

Net income before taxes

Federal and state income taxes

Net income

Net loss attributable to non-controlling interests

Net income attributable to BOK Financial Corp.

shareholders

Commercial

Consumer

Wealth
Management

Funds
Management
and Other

BOK
Financial
Consolidated

$

501,042

$

77,283

$

33,006

$

135,897

$

747,228

(62,655)

438,387

32,961

405,426

198,902

217,993

386,335

10

—

669

36,134

350,880

146,740

204,140

—

43,156

120,439

4,925

115,514

216,285

247,478

84,321

(26,252)

(2,193)

979

65,567

(8,712)

(3,389)

(5,323)

—

29,043

62,049

(801)

62,850

283,222

250,995

95,077

(42)

—

—

42,378

52,657

20,976

31,681

—

(9,544)

126,353

27,915

98,438

(24,389)

301,124

(227,075)

26,284

2,193

(1,648)

(144,079)

(56,167)

(57,950)

1,783

(387)

—

747,228

65,000

682,228

674,020

1,017,590

338,658

—

—

—

—

338,658

106,377

232,281

(387)

$

204,140

$

(5,323) $

31,681

$

2,170

$

232,668

Average assets

$ 17,175,325

$

8,254,666

$

7,373,080

$

(524,669) $

32,278,402

144

(18) Fees and Commissions Revenue 

Fees and commissions revenue by reportable segment and primary service line is as follows for the year ended December 31, 
2018.

Commercial

Consumer

Wealth
Management

Funds
Management
and Other

Consolidated

Out of 
Scope1

In Scope2

Trading revenue

$

— $

— $

28,077

$

— $

28,077

$

28,077

$

Customer hedging revenue

Retail brokerage revenue

Investment banking revenue

Brokerage and trading

revenue

TransFund EFT network revenue

Merchant services revenue

Transaction card revenue

Personal trust revenue

Corporate trust revenue

Institutional trust & retirement

plan services revenue

Investment management services

and other

Fiduciary and asset
management revenue

Commercial account service

charge revenue

Overdraft fee revenue

Check card revenue

Automated service charge and
other deposit fee revenue

Deposit service charges and

fees

Mortgage production revenue

Mortgage servicing revenue

Mortgage banking revenue

Other revenue

Total fees and commissions

revenue

7,748

—

7,628

15,376

72,280

7,666

79,946

—

—

—

—

—

41,931

370

—

282

42,583

—

—

—

24,044

—

—

—

—

4,017

59

4,076

—

—

—

—

—

1,445

36,177

20,967

6,621

65,210

31,690

67,980

99,670

9,218

27,512

19,030

11,634

86,253

(82)

—

(82)

96,839

22,292

44,400

19,729

183,260

2,331

134

—

62

2,527

—

—

—

24,507

3,574

3,120

—

6,694

6

79

85

—

—

—

1,443

1,443

1,565

(145)

339

74

1,833

—

(1,883)

(1,883)

(1,118)

38,834

22,150

19,262

38,834

—

6,380

108,323

73,291

76,221

7,804

84,025

96,839

22,292

44,400

21,172

184,703

47,272

36,536

21,306

7,039

112,153

31,690

66,097

97,787

56,651

—

—

—

—

—

—

—

—

—

—

—

—

—

31,690

66,097

97,787

38,306

—

—

22,150

12,882

35,032

76,221

7,804

84,025

96,839

22,292

44,400

21,172

184,703

47,272

36,536

21,306

7,039

112,153

—

—

—

18,345

$

161,949

$

178,174

$

296,465

$

7,054

$

643,642

$

209,384

$

434,258

1   Out of scope revenue generally relates to financial instruments or contractual rights and obligations within the scope of other applicable accounting 

guidance.

2  In scope revenue represents revenue subject to FASB ASC Topic 606, Revenue from Contracts with Customers.

145

(19) Fair Value Measurements 

Fair value is defined by applicable accounting guidance as the price to sell an asset or transfer a liability in an orderly 
transaction between market participants in the principal market for the given asset or liability at the measurement date based on 
market conditions at that date. An orderly transaction assumes exposure to the market for a customary period for marketing 
activities prior to the measurement date and not a forced liquidation or distressed sale. Certain assets and liabilities are recorded 
in the Company’s financial statements at fair value. Some are recorded on a recurring basis and some on a non-recurring basis.

For some assets and liabilities, observable market transactions and market information might be available. For other assets and 
liabilities, observable market transactions and market information might not be available. A hierarchy for fair value has been 
established which categorizes into three levels the inputs to valuation techniques used to measure fair value. The three levels 
are as follows:

Quoted Prices in Active Markets for Identical Assets or Liabilities (Level 1) - fair value is based on unadjusted quoted 
prices in active markets for identical assets or liabilities.

Significant Other Observable Inputs (Level 2) - fair value is based on significant other observable inputs which are 
generally determined based on a single price for each financial instrument provided to us by an applicable third-party 
pricing service and is based on one or more of the following:

•
•
•

•

Quoted prices for similar, but not identical, assets or liabilities in active markets;
Quoted prices for identical or similar assets or liabilities in inactive markets;
Inputs other than quoted prices that are observable, such as interest rate and yield curves, volatilities, prepayment
speeds, loss severities, credit risks and default rates;
Other inputs derived from or corroborated by observable market inputs.

Significant Unobservable Inputs (Level 3) - fair value is based upon model-based valuation techniques for which at least 
one significant assumption is not observable in the market. 

Transfers between levels are recognized as of the end of the reporting period. There were no transfers in or out of quoted prices 
in active markets for identical instruments to significant other observable inputs or significant unobservable inputs during the 
year ended December 31, 2018 and 2017, respectively. Transfers between significant other observable inputs and significant 
unobservable inputs during the year ended December 31, 2018 and 2017 are included in the summary of changes in recurring 
fair values measured using unobservable inputs. Additionally, $208 million of held-to-maturity other debt securities were 
transferred from significant other observable inputs to significant unobservable inputs at December 31, 2018 due to a lack of 
currently available observable inputs.

The underlying methods used by the third-party pricing services are considered in determining the primary inputs used to 
determine fair values. Management has evaluated the methodologies employed by the third-party pricing services by 
comparing the price provided by the pricing service with other sources, including brokers' quotes, sales or purchases of similar 
instruments and discounted cash flows to establish a basis for reliance on the pricing service values. Significant differences 
between the pricing service provided value and other sources are discussed with the pricing service to understand the basis for 
their values. Based on all observable inputs, management may adjust prices obtained from third-party pricing services to more 
appropriately reflect the prices that would be received to sell assets or paid to transfer liabilities in orderly transactions in the 
current market. No significant adjustments were made to prices provided by third-party pricing services at December 31, 2018 
and 2017. 

146

Assets and Liabilities Measured at Fair Value on a Recurring Basis

The fair value of financial assets and liabilities that are measured on a recurring basis is as follows as of December 31, 2018 (in 
thousands):

Quoted
Prices in
Active
Markets for
Identical
Instruments

Total

Significant
Other
Observable
Inputs

Significant
Unobservable
Inputs

Assets:

Trading securities:

U.S. government agency debentures

$

63,765

$

— $

63,765

$

U.S. government agency residential mortgage-backed securities

1,791,584

Municipal and other tax-exempt securities

Asset-backed securities

Other trading securities

Total trading securities

Available for sale securities:

U.S. Treasury securities

Municipal and other tax-exempt securities

U.S. government agency residential mortgage-backed securities

Privately issued residential mortgage-backed securities

Commercial mortgage-backed securities guaranteed by U.S.

government agencies

Other debt securities

Total available for sale securities

Fair value option securities – U.S. government agency residential

mortgage-backed securities

Residential mortgage loans held for sale
Mortgage servicing rights, net1
Derivative contracts, net of cash margin2

Liabilities:

Derivative contracts, net of cash margin2

34,507

42,656

24,411

1,956,923

493

2,864

5,804,708

59,736

2,953,889

35,430

8,857,120

283,235

149,221

259,254

320,929

—

—

—

—

—

493

—

—

—

—

—

1,791,584

34,507

42,656

24,411

1,956,923

—

2,864

5,804,708

59,736

2,953,889

34,958

493

8,856,155

—

—

—

283,235

134,014

—

44,074

276,855

—

—

—

—

—

—

—

—

—

—

—

472

472

—

15,207

259,254

—

—

362,306

—

362,306

1  A reconciliation of the beginning and ending fair value of mortgage servicing rights and disclosures of significant assumptions used to 

determine fair value are presented in Note 7, Mortgage Banking Activities.

2  See Note 3 for detail of fair value of derivative contracts by contract type. Derivative contracts in a net asset position that were valued 
based on quoted prices in active markets or identical instruments (Level 1) are exchange-traded interest rate, energy and agricultural 
derivative contracts, net of cash margin. Derivative contracts in a net liability position that were valued using quoted prices in active 
markets for identical instruments (Level 1) are exchange-traded interest rate derivative contracts, fully offset by cash margin.

147

The fair value of financial assets and liabilities that are measured on a recurring basis is as follows as of December 31, 2017 (in 
thousands):

Quoted
Prices in
Active
Markets for
Identical
Instruments

Total

Significant
Other
Observable
Inputs

Significant
Unobservable
Inputs

Assets:

Trading securities:

U.S. government agency debentures

$

21,196

$

— $

21,196

$

U.S. government agency residential mortgage-backed securities

Municipal and other tax-exempt securities

Asset-backed securities

Other trading securities

Total trading securities

Available for sale securities:

U.S. Treasury securities

Municipal and other tax-exempt securities

U.S. government agency residential mortgage-backed securities

Privately issued residential mortgage-backed securities

Commercial mortgage-backed securities guaranteed by U.S.

government agencies

Other debt securities

Perpetual preferred stock

Equity securities and mutual funds

Total available for sale securities

Fair value option securities – U.S. government agency residential

mortgage-backed securities

Residential mortgage loans held for sale
Mortgage servicing rights, net1
Derivative contracts, net of cash margin2

Liabilities:

Derivative contracts, net of cash margin 2

392,673

13,559

23,885

11,363

462,676

1,000

27,080

5,309,152

93,221

2,834,961

25,481

15,767

14,916

—

—

—

—

—

1,000

—

—

—

—

—

—

—

392,673

13,559

23,885

11,363

462,676

—

22,278

5,309,152

93,221

2,834,961

25,009

15,767

14,916

—

—

—

—

—

—

—

4,802

—

—

—

472

—

—

8,321,578

1,000

8,315,304

5,274

755,054

221,378

252,867

220,502

—

—

—

755,054

209,079

—

8,179

212,323

171,963

—

171,963

—

12,299

252,867

—

—

1  A reconciliation of the beginning and ending fair value of mortgage servicing rights and disclosures of significant assumptions used to 

determine fair value are presented in Note 7, Mortgage Banking Activities.

2  See Note 3 for detail of fair value of derivative contracts by contract type. Derivative contracts in a net asset position that were valued 
based on quoted prices in active markets for identical instruments (Level 1) are exchange-traded interest rate, energy and agricultural 
derivative contracts, net of cash margin. Derivative contracts in a net liability position that were valued using quoted prices in active 
markets for identical instruments based on quoted prices in active markets for identical instruments (Level 1) are exchange-traded interest 
rate and energy derivative contracts, fully offset by cash margin.

148

Following is a description of the Company's valuation methodologies used for assets and liabilities measured on a recurring 
basis:

Securities

The fair values of trading, available for sale and fair value option securities are based on quoted prices for identical instruments 
in active markets, when available. If quoted prices for identical instruments are not available, fair values are based on 
significant other observable inputs such as quoted prices of comparable instruments or interest rates and credit spreads, yield 
curves, volatilities, prepayment speeds and loss severities. 

The fair value of certain available for sale and held-to-maturity municipal and other debt securities may be based on significant 
unobservable inputs. These significant unobservable inputs include limited observed trades, projected cash flows, current credit 
rating of the issuers and, when applicable, the insurers of the debt and observed trades of similar debt. Discount rates are 
primarily based on reference to interest rate spreads on comparable securities of similar duration and credit rating as 
determined by the nationally-recognized rating agencies adjusted for a lack of trading volume. Significant unobservable inputs 
are developed by investment securities professionals involved in the active trading of similar securities. A summary of 
significant inputs used to value these securities follows. A management committee composed of senior members from the 
Company's Capital Markets, Risk Management and Finance departments assess the appropriateness of these inputs quarterly.

Derivatives 

All derivative instruments are carried on the balance sheet at fair value. Fair values for exchange-traded contracts are based on 
quoted prices. Fair values for over-the-counter interest rate, commodity and foreign exchange contracts are based on valuations 
provided either by third-party dealers in the contracts, quotes provided by independent pricing services, or a third-party 
provided pricing model that uses significant other observable market inputs. 

Credit risk is considered in determining the fair value of derivative instruments. Management determines fair value adjustments 
based on various risk factors including but not limited to counterparty credit rating or equivalent loan grading, derivative 
contract notional size, price volatility of the underlying commodity, duration of the derivative contracts and expected loss 
severity. Expected loss severity is based on historical losses for similarly risk graded commercial loan customers. Decreases in 
counterparty credit rating or grading and increases in price volatility and expected loss severity all tend to increase the credit 
quality adjustment which reduces the fair value of asset contracts. 

We also consider our own credit risk in determining the fair value of derivative contracts. Changes in our credit rating would 
affect the fair value of our derivative liabilities. In the event of a credit downgrade, the fair value of our derivative liabilities 
would increase. 

Residential Mortgage Loans Held for Sale

Residential mortgage loans held for sale are carried on the balance sheet at fair value. The fair values of conforming residential 
mortgage loans held for sale are based upon quoted market prices of such loans sold in securitization transactions, including 
related unfunded loan commitments. The fair value of mortgage loans that are unable to be sold to U.S. government agencies is 
determined using quoted prices of loans that are sold in securitization transactions with a liquidity discount applied.

149

The following represents the changes related to assets measured at fair value on a recurring basis using significant 
unobservable inputs (in thousands):

Balance, December 31, 2016
Transfer to Level 3 from Level 21
Purchases and capital calls

Redemptions and distributions

Proceeds from sales

Gain (loss) recognized in earnings:

Mortgage banking revenue

Other comprehensive income (loss):

Net change in unrealized gain (loss)

Balance, December 31, 2017
Transfer to Level 3 from Level 21
Purchases and capital calls

Redemptions and distributions

Proceeds from sales

Gain (loss) recognized in earnings:

Mortgage banking revenue

Other comprehensive income (loss):

Net change in unrealized gain (loss)

Available for Sale

Securities

Municipal
and other
tax-exempt
securities

Other debt
securities

Residential
mortgage
loans held
for sale

$

5,789

$

4,152

$

11,617

—

—

(1,100)

—

—

113

4,802

—

—

(5,095)

—

—

293

—

—

—

3,507

—

—

(3,900)

(2,944)

—

220

472

—

—

—

—

—

—

119

—

12,299

6,183

—

—

(2,706)

(569)

—

Balance, December 31, 2018
15,207
1  Recurring transfers to Level 3 from Level 2 consist of residential mortgage loans intended for sale to U.S. government agencies that fail to 

— $

472

$

$

meet conforming standards.

A summary of quantitative information about assets measured at fair value on a recurring basis using significant unobservable 
inputs (Level 3) as of December 31, 2018 follows (in thousands):

Quantitative Information about Level 3 Recurring Fair Value Measurements

Fair
Value

Valuation Technique(s)

Significant Unobservable
Input

Range
(Weighted Average)

Available for sale securities:

Other debt securities

472

Discounted cash flows

1

Interest rate spread

94.44%-94.44% (94.44%)

7.88%-7.88% (7.88%)

3

2

Residential mortgage loans held for sale
1  Discounted cash flows developed using discount rates primarily based on reference to interest rate spreads for comparable securities of similar duration and 

92.38%

15,207

Quoted prices of loans
sold in securitization
transactions, with a
liquidity discount
applied

Liquidity discount applied to
the market value of mortgage
loans qualifying for sale to
U.S. government agencies

credit rating as determined by the nationally-recognized rating agencies, adjusted for lack of trading volume.

2  Represents fair value as a percentage of par value.
3  Interest rate yields used to value investment grade taxable securities based on comparable short-term taxable securities which are generally yielding 

approximately 3%. 

150

A summary of quantitative information about Recurring Fair Value Measurements based on Significant Unobservable Inputs 
(Level 3) as of December 31, 2017 follows (in thousands):

Quantitative Information about Level 3 Recurring Fair Value Measurements

Fair
Value

Valuation Technique(s)

Significant Unobservable
Input

Range
(Weighted Average)

Available for sale securities:

Municipal and other tax-exempt securities

$

4,802

Discounted cash flows

Other debt securities

472

Discounted cash flows

1

1

Interest rate spread

92.25%-94.76% (93.75%)

6.60%-6.60% (6.60%)

Interest rate spread

94.39%-94.39% (94.39%)

6.85%-6.85% (6.85%)

2

3

4

3

Quoted prices of loans
sold in securitization
transactions, with a
liquidity discount
applied

Liquidity discount applied to
the market value of mortgage
loans qualifying for sale to U.S.
government agencies

Residential mortgage loans held for sale
1  Discounted cash flows developed using discount rates primarily based on reference to interest rate spreads for comparable securities of similar duration and 

94.75%

12,299

credit rating as determined by the nationally-recognized rating agencies, adjusted for lack of trading volume.

2  Interest rate yields used to value investment grade tax-exempt securities represent a spread of 372 to 466 basis points over average yields for comparable 

tax-exempt securities.

3  Represents fair value as a percentage of par value.
4  Interest rate yields used to value investment grade taxable securities based on comparable short-term taxable securities which are generally yielding less than 

3%. 

151

Fair Value of Assets and Liabilities Measured on a Non-Recurring Basis

Assets measured at fair value on a non-recurring basis include pension plan assets, which are based on quoted prices in active 
markets for identical instruments, collateral for certain impaired loans and real property and other assets acquired to satisfy 
loans, which are based primarily on comparisons to completed sales of similar assets. See Note 6 for information related to the 
non-recurring fair value measurement of CoBiz Financial.

The following represents the carrying value of assets measured at fair value on a non-recurring basis and related losses 
recorded during the year. The carrying value represents only those assets with the balance sheet date for which the fair value 
was adjusted during the year:

Carrying Value at December 31, 2018

Fair Value Adjustments for the
Year Ended December 31, 2018
Recognized In:

Quoted Prices
in Active 
Markets for 
Identical 
Instruments

Significant
Other
Observable
Inputs

Significant
Unobservable
Inputs

Gross charge-
offs against
allowance for
loan losses

Net losses and
expenses of
repossessed
assets, net

Impaired loans
Real estate and other repossessed assets

$

— $
—

$

1,074
4,795

$

17,401
6,366

$

17,434
—

—
7,269

Carrying Value at December 31, 2017

Fair Value Adjustments for the
 Year Ended December 31, 2017
Recognized In:

Quoted Prices
in Active 
Markets for 
Identical 
Instruments

Significant
Other
Observable
Inputs

Significant
Unobservable
Inputs

Gross charge-
offs against
allowance for
loan losses

Net losses and
expenses of
repossessed
assets, net

Impaired loans
Real estate and other repossessed assets

$

— $
—

$

7,436
3,483

$

7,626
5,481

$

12,145
—

—
6,372

The fair value of collateral-dependent impaired loans and real estate and other repossessed assets and the related fair value 
adjustments are generally based on unadjusted third-party appraisals. Our appraisal review policies require appraised values to 
be supported by observed inputs derived principally from or corroborated by observable market data. Appraisals that are not 
based on observable inputs or that require significant adjustments or fair value measurements that are not based on third-party 
appraisals are considered to be based on significant unobservable inputs. Non-recurring fair value measurements of collateral-
dependent impaired loans and real estate and other repossessed assets based on significant unobservable inputs are generally 
due to estimates of current fair values between appraisal dates. Significant unobservable inputs include listing prices for 
comparable assets, uncorroborated expert opinions or management's knowledge of the collateral or industry. Non-recurring fair 
value measurements of collateral dependent loans secured by mineral rights are generally determined by our internal staff of 
engineers on projected cash flows under current market conditions and are based on significant unobservable inputs. Projected 
cash flows are discounted according to risk characteristics of the underlying oil and gas properties. Assets are evaluated to 
demonstrate with reasonable certainty that crude oil, natural gas and natural gas liquids can be recovered from known oil and 
gas reservoirs under existing economic and operating conditions at current prices with existing conventional equipment, 
operating methods and costs. Significant unobservable inputs are developed by asset management and workout professionals 
and approved by senior Credit Administration executives.

152

A summary of quantitative information about Non-recurring Fair Value Measurements based on Significant Unobservable 
Inputs (Level 3) as of December 31, 2018 follows (in thousands):

Quantitative Information about Level 3 Non-recurring Fair Value Measurements

Impaired loans

Fair
Value

Valuation
Technique(s)

$ 17,401 Discounted cash

flows

Real estate and other repossessed assets

6,366 Discounted cash

flows

1  Represents fair value as a percentage of the unpaid principal balance.

Significant Unobservable Input
Management knowledge of industry
and non-real estate collateral including
but not limited to recoverable oil & gas
reserves, forward looking commodity
prices, and estimated operating costs

Recoverable oil and gas reserves,
forward-looking commodity prices,
estimated operating costs

Range
(Weighted Average)
35% - 80% (50%)1

N/A

The table above excludes the initial measurement of assets and liabilities that were acquired as part of the CoBiz acquisition in 
October 1, 2018. These assets and liabilities were recorded at their fair value upon acquisition in accordance with U.S. GAAP 
and were not re-measured during the periods presented unless specifically required by U.S. GAAP. Acquisition date fair values 
represent either Level 2 fair value measurements (investment securities, deposits, property, equipment, and debt) or Level 3 fair 
value measurements (loans and core deposit intangible assets). Refer to Note 6, Goodwill and Intangible Assets, for further 
detail regarding the CoBiz acquisition. 

A summary of quantitative information about Non-recurring Fair Value Measurements based on Significant Unobservable 
Inputs (Level 3) as of December 31, 2017 follows (in thousands):

Quantitative Information about Level 3 Non-recurring Fair Value Measurements

Impaired loans

Fair
Value

Valuation
Technique(s)

$

7,626 Discounted cash

flows

Real estate and other repossessed assets

5,481 Discounted cash

flows

1  Represents fair value as a percentage of the unpaid principal balance.

Significant Unobservable Input
Recoverable oil and gas reserves,
forward-looking commodity prices and
estimated operating costs

Recoverable oil and gas reserves,
forward-looking commodity prices and
estimated operating costs

Range
(Weighted Average)
40% - 86% (59%)1

N/A

The fair value of pension plan assets was approximately $34 million at December 31, 2018 and $40 million at December 31, 
2017, determined by significant other observable inputs. Fair value adjustments of pension plan assets along with changes in 
the projected benefit obligation are recognized in other comprehensive income. 

153

Fair Value of Financial Instruments

The following table presents the carrying values and estimated fair values of all financial instruments, including those financial 
assets and liabilities that are not measured and reported at fair value on a recurring basis or non-recurring (dollars in 
thousands): 

December 31, 2018

Quoted
Prices in
Active
Markets for
Identical
Instruments
(Level 1)

Significant
Other
Observable
Inputs
(Level 2)

Significant
Unobservable
Inputs
(Level 3)

Carrying
Value

Estimated
Fair Value

Cash and due from banks

$

741,749

$

741,749

$

741,749

$

Interest-bearing cash and cash equivalents

401,675

401,675

401,675

— $

—

Trading securities:

U.S. government agency debentures

63,765

63,765

U.S. government agency residential mortgage-backed securities

1,791,584

1,791,584

Municipal and other tax-exempt securities

Asset-backed securities

Other trading securities

Total trading securities

Investment securities:

Municipal and other tax-exempt securities

U.S. government agency residential mortgage-backed securities

Other debt securities

Total investment securities

Available for sale securities:

U.S. Treasury securities

Municipal and other tax-exempt securities

34,507

42,656

24,411

34,507

42,656

24,411

1,956,923

1,956,923

137,296

12,612

205,279

355,187

493

2,864

138,562

12,770

215,966

367,298

493

2,864

U.S. government agency residential mortgage-backed securities

5,804,708

5,804,708

Privately issued residential mortgage-backed securities

59,736

59,736

Commercial mortgage-backed securities guaranteed by U.S.

government agencies

Other debt securities

Total available for sale securities

Fair value option securities – U.S. government agency residential

mortgage-backed securities

Residential mortgage loans held for sale

Loans:

Commercial

Commercial real estate

Residential mortgage

Personal

Total loans

Allowance for loan losses

Loans, net of allowance

Mortgage servicing rights

Derivative instruments with positive fair value, net of cash margin

Deposits with no stated maturity

Time deposits

Other borrowed funds

Subordinated debentures

Derivative instruments with negative fair value, net of cash margin

2,953,889

2,953,889

35,430

35,430

283,235

149,221

283,235

149,221

13,636,078

13,526,162

4,764,813

2,230,033

1,025,806

4,713,747

2,213,951

1,024,368

21,656,730

21,478,228

(207,457)

—

21,449,273

21,478,228

259,254

320,929

259,254

320,929

23,150,383

23,150,383

2,113,380

7,142,801

275,913

362,306

2,073,538

6,771,953

261,977

362,306

154

—

—

—

—

—

—

—

—

—

—

208,061

208,061

—

—

—

—

—

472

472

—

15,207

13,526,162

4,713,747

2,213,951

1,024,368

21,478,228

—

21,478,228

259,254

—

—

—

—

—

—

—

—

—

—

493

—

—

—

—

—

63,765

1,791,584

34,507

42,656

24,411

1,956,923

138,562

12,770

7,905

159,237

—

2,864

5,804,708

59,736

2,953,889

34,958

—

—

—

—

—

—

—

—

—

—

283,235

134,014

—

—

—

—

—

—

—

—

44,074

276,855

—

—

—

—

—

—

—

—

—

261,977

362,306

23,150,383

2,073,538

6,771,953

—

—

8,857,120

8,857,120

493

8,856,155

December 31, 2017

Quoted
Prices in
Active
Markets for
Identical
Instruments
(Level 1)

Significant
Other
Observable
Inputs
(Level 2)

Significant
Unobservable
Inputs
(Level 3)

Carrying
Value

Estimated
Fair Value

Cash and due from banks

$

602,510

$

602,510

$

602,510

$

Interest-bearing cash and cash equivalents

1,714,544

1,714,544

1,714,544

— $

—

—

—

—

—

—

—

—

—

—

—

1,000

—

—

—

—

—

—

—

21,196

392,673

13,559

23,885

11,363

438,791

230,349

16,242

233,444

480,035

—

22,278

5,309,152

93,221

2,834,961

25,009

15,767

14,916

Trading securities:

U.S. government agency debentures

U.S. government agency residential mortgage-backed securities

Municipal and other tax-exempt securities

Asset-backed securities

Other trading securities

Total trading securities

Investment securities:

Municipal and other tax-exempt securities

U.S. government agency residential mortgage-backed securities

Other debt securities

Total investment securities

Available for sale securities:

U.S. Treasury securities

Municipal and other tax-exempt securities

21,196

392,673

13,559

23,885

11,363

21,196

392,673

13,559

23,885

11,363

462,676

438,791

228,186

15,891

217,716

461,793

1,000

27,080

230,349

16,242

233,444

480,035

1,000

27,080

U.S. government agency residential mortgage-backed securities

5,309,152

5,309,152

Privately issued residential mortgage-backed securities

93,221

93,221

Commercial mortgage-backed securities guaranteed by U.S.

government agencies

Other debt securities

Perpetual preferred stock

Equity securities and mutual funds

Total available for sale securities

Fair value option securities – U.S. government agency residential

mortgage-backed securities

Residential mortgage loans held for sale

Loans:

Commercial

Commercial real estate

Residential mortgage

Personal

Total loans

Allowance for loan losses

Loans, net of allowance

Mortgage servicing rights

Derivative instruments with positive fair value, net of cash margin

Deposits with no stated maturity

Time deposits

Other borrowed funds

Subordinated debentures

Derivative instruments with negative fair value, net of cash margin

2,834,961

2,834,961

25,481

15,767

14,916

25,481

15,767

14,916

8,321,578

8,321,578

1,000

8,315,304

755,054

221,378

755,054

221,378

10,733,975

10,524,627

3,479,987

1,973,686

965,776

3,428,733

1,977,721

956,706

17,153,424

16,887,787

(230,682)

—

16,922,742

16,887,787

252,867

220,502

252,867

220,502

19,962,889

19,962,889

2,098,416

5,709,860

144,677

171,963

2,064,558

5,703,121

148,207

171,963

—

—

—

—

—

—

—

—

—

—

755,054

208,946

—

—

—

—

—

—

—

—

8,179

212,323

—

—

—

—

—

—

—

—

148,207

171,963

—

—

—

—

—

—

—

—

—

—

—

—

—

4,802

—

—

—

472

—

—

5,274

—

12,432

10,524,627

3,428,733

1,977,721

956,706

16,887,787

—

16,887,787

252,867

—

19,962,889

2,064,558

5,703,121

—

—

Because no market exists for certain of these financial instruments and management does not intend to sell these financial 
instruments, the fair values shown in the tables above may not represent values at which the respective financial instruments 
could be sold individually or in the aggregate at the given reporting date.

155

Fair Value Election

As more fully disclosed in Note 2 and Note 7 to the Consolidated Financial Statements, the Company has elected to carry all 
U.S. government agency residential mortgage-backed securities held as economic hedges against changes in the fair value of 
mortgage servicing rights and all residential mortgage loans originated for sale at fair value. Changes in the fair value of these 
financial instruments are recognized in earnings.

156

(20) Parent Company Only Financial Statements 

Summarized financial information for BOK Financial – Parent Company Only follows:

Balance Sheets
(In thousands)

Assets

Cash and cash equivalents

Available for sale securities

Loan to bank subsidiary

Investment in bank subsidiaries

Investment in non-bank subsidiaries

Other assets

Total assets

Liabilities and Shareholders’ Equity

Liabilities:

Other liabilities

Subordinated debentures

Total liabilities

Shareholders’ equity:

Common stock

Capital surplus

Retained earnings

Treasury stock

Accumulated other comprehensive loss

Total shareholders’ equity

Total liabilities and shareholders’ equity

December 31,

2018

2017

$

167,093

$

205,876

—

65,228

16,185

—

4,236,654

3,255,912

218,007

32,999

170,966

4,065

$

4,719,981

$

3,653,004

$

11,959

$

275,913

287,872

12,960

144,677

157,637

5

4

1,334,030

3,369,654

(72,585)

(198,995)

1,035,895

3,048,487

(36,174)

(552,845)

4,432,109

3,495,367

$

4,719,981

$

3,653,004

157

Statements of Earnings
(In thousands)

Year Ended December 31,

2018

2017

2016

Dividends, interest and fees received from bank subsidiaries

$

426,071

$

150,149

$

Dividends, interest and fees received from non-bank subsidiaries

Other revenue

Total revenue

Interest expense

Other operating expense

Total expense

Net income before taxes, other losses, net, and equity in undistributed income of

subsidiaries

Other losses, net

Net income before taxes and equity in undistributed income of subsidiaries

Federal and state income taxes

Net income before equity in undistributed income of subsidiaries

Equity in undistributed income of bank subsidiaries

Equity in undistributed income of non-bank subsidiaries

12,800

954

439,825

9,827

12,110

21,937

417,888

(3,921)

413,967

(7,078)

421,045

37,515

(12,914)

17,500

936

168,585

8,239

2,014

10,253

158,332

—

158,332

(4,305)

162,637

181,552

(9,545)

15,237

25,923

1,612

42,772

4,182

1,978

6,160

36,612

—

36,612

(1,920)

38,532

216,120

(21,984)

Net income attributable to BOK Financial Corp. shareholders

$

445,646

$

334,644

$

232,668

158

Statements of Cash Flows
(In thousands)

Cash Flows From Operating Activities:

Net income

Adjustments to reconcile net income to net cash provided by operating activities:

Equity in undistributed income of bank subsidiaries

Equity in undistributed income of non-bank subsidiaries

Change in other assets

Change in other liabilities

Net cash provided by operating activities

Cash Flows From Investing Activities:

Proceeds from sales of available for sale securities

Investment in subsidiaries

Acquisitions, net of cash acquired

Net cash used in investing activities

Cash Flows From Financing Activities:

Net change in other borrowed funds

Issuance of subordinated debentures, net of issuance costs

Issuance of common and treasury stock, net

Dividends paid

Repurchase of common stock

Net cash used in financing activities

Net increase (decrease) in cash and cash equivalents

Cash and cash equivalents at beginning of period

Cash and cash equivalents at end of period

Cash paid for interest

(21) Subsequent Events 

Year Ended December 31,

2018

2017

2016

$

445,646

$

334,644

$

232,668

(37,515)

12,914

(1,072)

(13,434)

406,539

—

(31,901)

(232,680)

(264,581)

—

—

(88)

(127,188)

(53,465)

(180,741)

(38,783)

205,876

167,093

11,457

(181,552)

(216,120)

9,545

12

7,457

170,106

3,000

(4,355)

—

(1,355)

(7,217)

—

4,368

21,984

(2,933)

(1,285)

34,314

1,632

(26,000)

(105,520)

(129,888)

—

144,615

12,455

(116,041)

(113,455)

(7,403)

(126,293)

42,458

163,418

205,876

6,211

$

$

(66,792)

(23,177)

(118,751)

282,169

163,418

4,127

$

$

$

$

The Company evaluated events from the date of the Consolidated Financial Statements on December 31, 2018 through the 
issuance of those consolidated financial statements included in this Annual Report on Form 10-K. No events were identified 
requiring recognition in and/or disclosure in the Consolidated Financial Statements.

159

Annual Financial Summary – Unaudited
Consolidated Daily Average Balances, Average Yields and Rates

(Dollars in Thousands, Except Per Share Data)

Assets

Interest-bearing cash and cash equivalents
Trading securities
Investment securities
Available for sale securities
Fair value option securities
Restricted equity securities
Residential mortgage loans held for sale
Loans
Allowance for loan losses

Loans, net of allowance
Total earning assets

Receivable on unsettled securities sales
Cash and other assets
Total assets

Liabilities and equity

Interest-bearing deposits:

Transaction
Savings
Time

Total interest-bearing deposits
Funds purchased and repurchase agreements

Other borrowings
Subordinated debentures

Total interest-bearing liabilities
Non-interest bearing demand deposits
Due on unsettled securities purchases
Other liabilities
Total equity

Total liabilities and equity

Tax-equivalent Net Interest Revenue
Tax-equivalent Net Interest Revenue to Earning Assets
Less tax-equivalent adjustment
Net Interest Revenue
Provision for credit losses
Other operating revenue
Other operating expense
Net income before taxes
Federal and state income taxes
Net income
Net income attributable to non-controlling interests
Net income attributable to BOK Financial Corporation shareholders
Earnings Per Average Common Share Equivalent:

Net income:
Basic
Diluted

Year Ended
December 31, 2018

Average
Balance

Revenue/
Expense

Yield/
Rate

1.80%
3.84%
4.00%
2.35%
3.18%
6.20%
4.07%
4.80%

4.86%
3.98%

0.62%
0.09%
1.37%
0.72%
1.04%

2.07%
5.52%
1.19%

22,333
57,948
15,848
197,472
15,205
21,555
8,123
898,896

898,896
1,237,380

65,859
439
29,219
95,517
9,207

129,008
9,827
243,559

$

$

$

$

$

$

1,240,600
1,530,400
395,895
8,309,355
464,160
347,447
201,218
18,709,433
(218,840)
18,490,593
30,979,668
795,723
3,162,139
34,937,530

10,581,732
503,597
2,133,427
13,218,756
883,904

6,236,441
177,884
20,516,985
9,590,455
531,071
559,802
3,739,217
34,937,530

$

993,821

2.79%
3.20%

8,954
984,867
8,000
616,784
1,028,166
565,485
119,061
446,424
778
445,646

6.63
6.63

$

$
$

Yield calculations are shown on a tax equivalent at the statutory federal and state rates for the periods presented.The yield calculations exclude security trades 
that have been recorded on trade date with no corresponding interest income and the unrealized gains and losses. The yield calculation also include average 
loan balances for which the accrual of interest has been discontinued and are net of unearned income. Yield/rate calculations are generally based on the 
conventions that determine how interest income and expense is accrued.

160

Annual Financial Summary – Unaudited (continued)
Consolidated Daily Average Balances, Average Yields and Rates

(Dollars in Thousands, Except Per Share Data)

Year Ended

December 31, 2017

December 31, 2016

Average
Balance

Revenue/
Expense

Yield/
Rate

Average
Balance

Revenue/
Expense

Yield/
Rate

Assets

Interest-bearing cash and cash equivalents
Trading securities
Investment securities
Available for sale securities
Fair value option securities
Restricted equity securities
Residential mortgage loans held for sale
Loans
Allowance for loan losses

Loans, net of allowance
Total earning assets

Receivable on unsettled securities sales
Cash and other assets
Total assets

Liabilities and equity

Interest-bearing deposits:

Transaction
Savings
Time

Total interest-bearing deposits
Funds purchased and repurchase agreements
Other borrowings
Subordinated debentures

Total interest-bearing liabilities
Non-interest bearing demand deposits
Due on unsettled securities purchases
Other liabilities
Total equity

Total liabilities and equity

Tax-equivalent Net Interest Revenue
Tax-equivalent Net Interest Revenue to

Earning Assets

Less tax-equivalent adjustment
Net Interest Revenue
Provision for credit losses
Other operating revenue
Other operating expense
Net income before taxes
Federal and state income taxes
Net income
Net income attributable to non-controlling

interests

Net income attributable to BOK Financial

Corporation shareholders

Earnings Per Average Common Share

Equivalent:

Net income:
Basic
Diluted

22,128
17,637
18,792
178,068
16,755
18,490
8,706
709,378

709,378
989,954

28,627
359
24,817
53,803
856
68,152
8,239
131,050

$

$

$

$

$

$

2,009,011
521,742
491,989
8,453,415
593,744
318,744
245,133
17,176,102
(249,430)
16,926,672
29,560,450
545,338
2,841,706
32,947,494

10,220,068
458,451
2,193,273
12,871,792
491,855
5,919,292
147,954
19,430,893
9,312,989
183,902
584,842
3,434,868
32,947,494

$

858,904

17,203
841,701
(7,000)
695,094
1,025,517
518,278
182,593
335,685

1,041

334,644

5.11
5.11

$

$
$

161

0.53%
3.43%
3.54%
2.03%
1.93%
5.37%
3.45%
3.63%

3.68%
2.95%

0.14%
0.09%
1.16%
0.33%
0.07%
0.58%
2.82%
0.42%

2.53%

2.66%

1.10% $
3.51%
3.82%
2.13%
2.81%
5.80%
3.59%
4.13%

4.19%
3.36%

$

0.28% $
0.08%
1.13%
0.42%
0.17%
1.15%
5.57%
0.67%

$

2.69%

2.92%

10,726
9,213
19,835
176,625
6,723
17,238
12,658
593,700

593,700
846,718

13,906
386
26,202
40,494
434
34,882
6,079
81,889

$

$

2,038,919
317,808
561,254
8,867,383
323,695
320,975
370,600
16,357,867
(243,631)
16,114,236
28,914,870
253,915
3,109,617
32,278,402

9,744,998
414,103
2,259,242
12,418,343
667,367
6,019,036
215,453
19,320,199
8,474,230
137,488
997,069
3,349,416
32,278,402

$

764,829

17,601
747,228
65,000
674,020
1,017,590
338,658
106,377
232,281

(387)

232,668

3.53
3.53

$

$
$

Quarterly Financial Summary – Unaudited
Consolidated Daily Average Balances, Average Yields and Rates

(In Thousands, Except Per Share Data)

Three Months Ended

Average
Balance

December 31, 2018
Revenue/
Expense

Yield/
Rate

Average
Balance

September 30, 2018
Revenue/
Expense

Yield/
Rate

Assets

Interest-bearing cash and cash equivalents
Trading securities
Investment securities
Available for sale securities
Fair value option securities
Restricted equity securities
Residential mortgage loans held for sale
Loans
Allowance for loan losses

Loans, net of allowance
Total earning assets

Receivable on unsettled securities sales
Cash and other assets
Total assets
Liabilities and equity

Interest-bearing deposits:

Transaction
Savings
Time

Total interest-bearing deposits
Funds purchased and repurchase agreements
Other borrowings
Subordinated debentures

Total interest-bearing liabilities
Non-interest bearing demand deposits
Due on unsettled securities purchases
Other liabilities
Total equity

Total liabilities and equity
Tax-equivalent Net Interest Revenue
Tax-equivalent Net Interest Revenue to Earning

Assets

Less tax-equivalent adjustment
Net Interest Revenue
Provision for credit losses
Other operating revenue
Other operating expense
Net income before taxes
Federal and state income taxes
Net income
Net income attributable to non-controlling interests

Net income attributable to BOK Financial Corp.

shareholders

Earnings Per Average Common Share Equivalent:

Basic
Diluted

3,170
19,636
3,887
55,085
2,578
5,798
1,795
276,711

276,711
368,660

23,343
148
8,309
31,800
4,135
40,220
3,752
79,907

$

$

$

563,132
1,929,601
364,737
8,704,963
277,575
362,729
179,553
21,579,331
(209,613)
21,369,718
33,752,008
799,548
3,834,187
$ 38,385,743

$ 11,773,651
526,275
2,146,786
14,446,712
1,205,568
6,361,141
276,378
22,289,799
10,648,683
493,887
610,286
4,343,088
$ 38,385,743

$

288,753

3,067
285,686
9,000
136,455
284,643
128,498
20,121
108,377
(79)

108,456

1.50
1.50

$

$
$

2.23% $
688,872
4.10%
1,762,794
4.26%
379,566
2.51%
8,129,214
3.56%
469,398
6.39%
328,842
4.00%
207,488
5.09% 18,203,785
(214,160)
5.14% 17,989,625
4.33% 29,955,799
768,785
2,971,233
$ 33,695,817

0.79% $ 10,010,031
0.11%
503,821
1.54%
2,097,441
0.87% 12,611,293
1.36%
1,193,583
2.51%
5,765,440
5.38%
144,702
1.42% 19,715,018
9,325,002
544,263
496,634
3,614,900
$ 33,695,817

2.91%

3.40%

$

$

3,441
17,419
3,856
48,916
3,881
5,232
2,151
220,245

220,245
305,141

17,029
108
7,398
24,535
3,768
32,036
2,025
62,364

$

242,777

1,894
240,883
4,000
167,941
252,617
152,207
34,662
117,545
289

117,256

1.79
1.79

$

$
$

1.98%
3.98%
4.06%
2.37%
3.25%
6.36%
4.27%
4.80%

4.86%
4.04%

0.67%
0.09%
1.40%
0.77%
1.25%
2.20%
5.55%
1.25%

2.79%

3.21%

Yield calculations are shown on a tax equivalent at the statutory federal and state rates for the periods presented.The yield calculations exclude security trades 
that have been recorded on trade date with no corresponding interest income and the unrealized gains and losses. The yield calculation also include average 
loan balances for which the accrual of interest has been discontinued and are net of unearned income. Yield/rate calculations are generally based on the 
conventions that determine how interest income and expense is accrued

162

Quarterly Financial Summary – Unaudited (continued)
Consolidated Daily Average Balances, Average Yields and Rates

June 30, 2018
Revenue /
Expense

Yield /
Rate

Average Balance

Three Months Ended
March 31, 2018
Revenue /
Expense

Average Balance

December 31, 2017

Yield /
Rate

Average Balance

Revenue /
Expense

Yield /
Rate

1.27%
3.38%
3.98%
2.21%
2.90%
5.87%
3.72%
4.29%

4.35%
3.49%

0.35%
0.07%
1.17%
0.48%
0.28%
1.36%
5.55%
0.79%

2.70%

2.97%

1.57% $
3.40%
3.78%
2.23%
2.95%
5.86%
3.71%
4.45%

4.51%
3.61%

$

0.45% $
0.07%
1.25%
0.57%
0.40%
1.60%
5.61%
0.93%

$

2.68%

2.99%

6,311
4,629
4,606
45,623
5,770
4,956
2,389
185,614

185,614
259,898

8,914
87
6,296
15,297
340
21,242
2,025
38,904

$

$

1,976,395
560,321
462,869
8,435,916
792,647
337,673
257,927
17,181,007
(246,143)
16,934,864
29,758,612
821,275
2,872,228
33,452,115

10,142,744
466,496
2,134,469
12,743,709
488,330
6,209,903
144,673
19,586,615
9,417,351
332,155
600,604
3,515,390
33,452,115

$

220,994

4,131
216,863
(7,000)
166,836
263,987
126,712
54,347
72,365
(127)
72,492

1.11
1.11

$

$
$

1.86% $
3.63%
3.95%
2.30%
3.16%
6.21%
4.28%
4.80%

4.86%
3.91%

$

0.55% $
0.08%
1.29%
0.66%
0.53%
1.96%
5.67%
1.11%

$

2.80%

3.17%

7,740
13,084
3,941
47,463
3,927
5,408
2,333
212,266

212,266
296,162

13,993
95
6,875
20,963
782
31,825
2,047
55,617

$

$

$

$

$

$

1,673,387
1,482,302
399,088
8,163,142
487,192
348,546
218,600
17,751,242
(222,856)
17,528,386
30,301,191
618,240
2,986,604
33,906,035

10,189,354
503,671
2,138,880
12,831,905
593,250
6,497,020
144,692
20,066,867
9,223,327
527,804
575,865
3,512,172
33,906,035

$

240,545

1,983
238,562
—
156,399
246,476
148,485
33,330
115,155
783
114,372

1.75
1.75

$

$
$

7,982
7,809
4,164
46,008
4,819
5,117
1,844
189,674

189,674
267,417

11,494
88
6,637
18,219
522
24,927
2,003
45,671

$

$

2,059,517
933,404
441,207
8,236,938
626,251
349,176
199,380
17,261,481
(228,996)
17,032,485
29,878,358
998,803
2,847,791
33,724,952

10,344,469
480,110
2,151,044
12,975,623
532,412
6,326,967
144,682
19,979,684
9,151,272
558,898
556,524
3,478,574
33,724,952

$

221,746

2,010
219,736
(5,000)
155,989
244,430
136,295
30,948
105,347
(215)
105,562

1.61
1.61

$

$
$

163

ITEM 9.  CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND FINANCIAL 
DISCLOSURE

None.

ITEM 9A.  CONTROLS AND PROCEDURES

As of the end of the period covered by this report and pursuant to Rule 13a-15 of the Securities Exchange Act of 1934 (the 
“Exchange Act”), the Company's management, including the Chief Executive Officer and Chief Financial Officer, conducted an 
evaluation of the effectiveness and design of the Company's disclosure controls and procedures (as that term is defined in Rules 
13a-15(e) and 15d-15(e) of the Exchange Act). Based upon that evaluation, the Company's Chief Executive Officer and Chief 
Financial Officer concluded, as of the end of the period covered by this report, that the Company's disclosure controls and 
procedures were effective in recording, processing, summarizing and reporting information required to be disclosed by the 
Company, within the time periods specified in the Securities and Exchange Commission's rules and forms.

In addition and as of the end of the period covered by this report, there have been no changes in internal control over financial 
reporting (as defined in Rule 13a-15(f) and 15d-15(f), as amended, of the Exchange Act) during the Company's fourth fiscal 
quarter that have materially affected, or are reasonably likely to materially affect, the internal control over financial reporting.

Management's Report on Internal Control over Financial Reporting appears within Item 8, “Financial Statements and 
Supplementary Data.” The independent registered public accounting firm, Ernst & Young LLP, has audited the financial 
statements included in Item 8 and has issued an audit report on the Company's internal control over financial reporting, which 
appears therein.

ITEM 9B.  OTHER INFORMATION

None.

PART III

ITEM 10.  DIRECTORS, EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE

The information set forth under the headings “Election of Directors,” “Executive Officers, “Insider Reporting,” “Director 
Nominations,” and “Report of the Audit Committee” in BOK Financial's 2019 Annual Proxy Statement is incorporated herein 
by reference.

The Company has a Code of Ethics which is applicable to all Directors, officers and employees of the Company, including the 
Chief Executive Officer and the Chief Financial Officer, the principal executive officer and principal financial and accounting 
officer, respectively. A copy of the Code of Ethics will be provided without charge to any person who requests it by writing to 
the Company's headquarters at Bank of Oklahoma Tower, P.O. Box 2300, Tulsa, Oklahoma 74192 or telephoning the Chief 
Risk Officer at (918) 588-6000. The Company will also make available amendments to or waivers from its Code of Ethics 
applicable to Directors or executive officers, including the Chief Executive Officer and the Chief Financial Officer, in 
accordance with all applicable laws and regulations.

There are no material changes to the procedures by which security holders may recommend nominees to the Company's board 
of directors since the Company's 2018 Annual Proxy Statement to Shareholders.

ITEM 11.  EXECUTIVE COMPENSATION

The information set forth under the heading “Compensation Discussion and Analysis,” “Compensation Committee Interlocks 
and Insider Participation", “Compensation Committee Report,” “Executive Compensation Tables,” and “Director 
Compensation” in BOK Financial's 2019 Annual Proxy Statement is incorporated herein by reference.

164

ITEM 12.  SECURITY OWNERSHIP OF CERTAIN BENEFICIAL OWNERS AND MANAGEMENT AND 
RELATED STOCKHOLDER MATTERS

The information set forth under the headings “Security Ownership of Certain Beneficial Owners and Management” and 
“Election of Directors” in BOK Financial's 2019 Annual Proxy Statement is incorporated herein by reference.

ITEM 13.  CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS, AND DIRECTOR INDEPENDENCE

Information regarding related parties is set forth in Note 13 of the Company's Notes to Consolidated Financial Statements, 
which appears elsewhere herein. Additionally, the information set forth under the headings “Certain Transactions,” “Director 
Independence” and “Related Party Transaction Review and Approval Process” in BOK Financial's 2019 Annual Proxy 
Statement is incorporated herein by reference.

ITEM 14.  PRINCIPAL ACCOUNTANT FEES AND SERVICES

The information set forth under the heading “Principal Accountant Fees and Services” in BOK Financial's 2019 Annual Proxy 
Statement is incorporated herein by reference.

PART IV

ITEM 15.  EXHIBITS, FINANCIAL STATEMENT SCHEDULES

(a) (1)  Financial Statements

The following financial statements of BOK Financial Corporation are filed as part of this Form 10-K in Item 8:

Consolidated Statements of Earnings for the years ended December 31, 2018, 2017 and 2016 
Consolidated Statements of Comprehensive Income for the years ended December 31, 2018, 2017 and 2016
Consolidated Balance Sheets as of December 31, 2018 and 2017
Consolidated Statements of Changes in Equity for the years ended December 31, 2018, 2017 and 2016
Consolidated Statements of Cash Flows for the years ended December 31, 2018, 2017 and 2016 
Notes to Consolidated Financial Statements
Annual Financial Summary - Unaudited
Quarterly Financial Summary - Unaudited
Reports of Independent Registered Public Accounting Firm

(a) (2)  Financial Statement Schedules

The schedules to the Consolidated Financial Statements required by Regulation S-X are not required under the related 
instructions or are inapplicable and are therefore omitted.

165

(a) (3)  Exhibits

Exhibit
Number

Description of Exhibit

2.0

3.0

3.1

4.0

4.1

4.2

4.3

4.5

10.4

10.4.2

10.4.2 (a)

10.4.2 (b)

10.4.7

10.4.9

10.4.10

10.4.11

10.7.7

Agreement and Plan of Merger by and among BOK Financial Corporation, CoBiz Financial Inc., and BOKF 
Merger Corporation Number Sixteen dated June 17, 2018, incorporated by reference to EX 99.1 of Form 8-
K filed on June 18, 2018. 

The Articles of Incorporation of BOK Financial, incorporated by reference to (i) Amended and Restated
Certificate of Incorporation of BOK Financial filed with the Oklahoma Secretary of State on May 28, 1991,
filed as Exhibit 3.0 to S-1 Registration Statement No. 33-90450, and (ii) Amendment attached as Exhibit A to
Information Statement and Prospectus Supplement filed November 20, 1991.

Bylaws of BOK Financial, as amended and restated as of October 30, 2007, incorporated by reference to 
Exhibit 3.1 of Form 8-K filed on November 5, 2007.

The rights of the holders of the Common Stock of BOK Financial are set forth in its Certificate of
Incorporation.

Subordinated Notes Indenture, dated as of June 27, 2016, between the Company and U.S. Bank National 
Association, as trustee (incorporated by reference to Exhibit 4.1 to the Company's filing on Form 8-K filed 
June 27, 2016).

Form of 5.375% Subordinated Notes due 2056 Global Security (incorporated by reference to Exhibit 4.2 to the 
Company's Registration Statement on Form 8-A filed on June 24, 2016).

Pursuant to Item 601(b)(4)(iii)(A) of Regulation S-K, BOK Financial is not filing certain documents. BOK
Financial agrees to furnish a copy of each such documents to the Commission upon the request of the
Commission.

Form of Subordinated Notes Indenture, to be dated as of June 25, 2015 between CoBiz Financial Inc. and U.S. 
Bank National Association, as trustee, incorporated by reference to Exhibit 4.1 to CoBiz Financial Inc. Form 
8-K filed June 25, 2015.

Form of 5.625% Subordinated Notes due June 25, 2030, incorporated by reference to Exhibit 4.2 to CoBiz 
Financial Inc. Form 8-K filed June 25, 2015.

Employment and Compensation Agreements.

Amended and Restated Deferred Compensation Agreement (Amended as of December 1, 2003) between 
Steven G. Bradshaw and BOK Financial Corporation, incorporated by reference to Exhibit 10.4.2 of Form 10-
K for the fiscal year ended December 31, 2003.

409A Deferred Compensation Agreement between Steven G. Bradshaw and BOK Financial Corporation dated 
December 31, 2004, incorporated by reference to Exhibit 10.4.2 (a) of Form 8-K filed on January 5, 2005.

Amended and Restated Employment Agreement (amended as of June 30, 2013) between BOK Financial and 
Steven G. Bradshaw, incorporated by reference to Exhibit 99.A of Form 8-K filed August 20, 2013.

Amended and Restated Employment Agreement (amended June 15, 2013) between BOK Financial and Steven 
Nell incorporated by reference to Exhibit 99.B of Form 8-K filed September 4, 2013.

Amended and Restated Employment Agreement (amended as of June 15, 2013) between BOK Financial and 
Norman Bagwell, incorporated by reference to Exhibit 99.A of Form 8-K filed September 4, 2013.

Amended and Restated Employment Agreement (amended as of June 15, 2013) between BOK Financial and 
Stacy C. Kymes incorporated by reference to Exhibit 10.4.10 of Form 10-K for the fiscal year ended December 
31, 2015.

Employment Agreement between BOK Financial and Scott B. Grauer dated December 18, 2013.

BOK Financial Corporation 2001 Stock Option Plan, incorporated by reference to Exhibit 4.0 of S-8 
Registration Statement No. 333-62578.

166

Exhibit
Number

10.7.8

10.7.9

10.7.10

10.7.11

10.7.12

10.7.13

10.7.14

10.7.16

10.8

21

23

31.1

31.2

32

99

101

Description of Exhibit

BOK Financial Corporation Directors' Stock Compensation Plan, incorporated by reference to Exhibit 4.0 of
S-8 Registration Statement No. 33-79836.

Bank of Oklahoma Thrift Plan (Amended and Restated Effective as of January 1, 1995), incorporated by
reference to Exhibit 10.7.6 of Form 10-K for the year ended December 31, 1994.

Trust Agreement for the Bank of Oklahoma Thrift Plan (December 30, 1994), incorporated by reference to
Exhibit 10.7.7 of Form 10-K for the year ended December 31, 1994.

BOK Financial Corporation 2003 Stock Option Plan, incorporated by reference to Exhibit 4.0 of S-8 
Registration Statement No. 333-106531.

BOK Financial Corporation 2003 Executive Incentive Plan, incorporated by reference to Exhibit 4.0 of S-8 
Registration Statement No. 333-106530.

10b5-1 Repurchase Plan between BOK Financial Corporation and BOSC, Inc. dated May 27, 2008, 
incorporated by reference to Exhibit 10.1 of Form 8-K filed May 30, 2008.

BOK Financial Corporation 2003 Executive Incentive Plan, as amended and restated, for the Chief Executive 
Officer and for Direct Reports to the Chief Executive Officer, incorporated by reference to the Schedule 14 
A Definitive Proxy Statement filed on March 15, 2011.

BOK Financial Corporation 2009 Omnibus Incentive Plan, Amended and Restated effective April 30, 
2013, incorporated by reference to the Schedule 14A Definitive Proxy Statement filed on March 20, 2013.

Lease Agreement between One Williams Center Co. and National Bank of Tulsa (predecessor to BOk) dated
June 18, 1974, incorporated by reference to Exhibit 10.9 of S-1 Registration Statement No. 33-90450.

Subsidiaries of BOK Financial, filed herewith.

Consent of independent registered public accounting firm - Ernst & Young LLP, filed herewith.

Certification of Chief Executive Officer Pursuant to Section 302 of the Sarbanes-Oxley Act of 2002, 
filed herewith.

Certification of Chief Financial Officer Pursuant to Section 302 of the Sarbanes-Oxley Act of 2002, 
filed herewith.

Certification of Chief Executive Officer and Chief Financial Officer Pursuant to 18 U.S.C. Section 1350, 
as Adopted Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, filed herewith.

Additional Exhibits.

Interactive data files pursuant to Rule 405 of Regulation S-T: (i) the Consolidated Balance Sheets, (ii) the
Consolidated Statements of Earnings, (iii) the Consolidated Statements of Changes in Equity, (iv) the
Consolidated Statement of Cash Flows and (v) the Notes to the Consolidated Financial Statements, filed
herewith.

(b) 

Exhibits

See Item 15 (a) (3) above.

(c) 

Financial Statement Schedules

See Item 15 (a) (2) above.

167

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this 
report to be signed on its behalf by the undersigned, thereunto duly authorized.

SIGNATURES

DATE: March 1, 2019                                                           BY:  /s/ George B. Kaiser
George B. Kaiser 
Chairman of the Board of Directors

BOK FINANCIAL CORPORATION

Pursuant to the requirements of the Securities Exchange Act of 1934, this report has been signed below on March 1, 2019, by 
the following persons on behalf of the registrant and in the capacities indicated.

OFFICERS

/s/ George B. Kaiser
George B. Kaiser
Chairman of the Board of Directors

/s/ Steven G. Bradshaw

Steven G. Bradshaw
Director, President and Chief Executive Officer

/s/ Steven E. Nell
Steven E. Nell
Director, Executive Vice President and
Chief Financial Officer

/s/ John C. Morrow
John C. Morrow
Senior Vice President and
Chief Accounting Officer

168

/s/ Alan S. Armstrong
Alan S. Armstrong

/s/ C. Frederick Ball, Jr.
C. Frederick Ball, Jr.

/s/ Steve Bangert
Steve Bangert

Peter C. Boylan III

/s/ Chester E. Cadieux, III
Chester E. Cadieux, III 

Gerard P. Clancy

/s/ John W. Coffey
John W. Coffey

/s/ Joseph W. Craft, III
Joseph W. Craft, III

/s/ Jack E. Finley
Jack E. Finley

/s/ David F. Griffin
David F. Griffin 

DIRECTORS

/s/ V. Burns Hargis
V. Burns Hargis

/s/ Douglas D. Hawthorne
Douglas D. Hawthorne

/s/ Kimberley D. Henry

Kimberley D. Henry

/s/ E. Carey Joullian, IV
E. Carey Joullian, IV

/s/ Stanley A. Lybarger
Stanley A. Lybarger

/s/ Steven J. Malcolm
Steven J. Malcolm

/s/ Emmet C. Richards
Emmet C. Richards

/s/ Claudia San Pedro
Claudia San Pedro

/s/ Michael C. Turpen
Michael C. Turpen

/s/ R.A. Walker
R.A. Walker

169

Exhibit 10.4.11

EMPLOYMENT AGREEMENT

December 18, 2013

This  Employment  Agreement  (“Agreement”)  is  made  this  18th  day  of  December,  2013  (the 

“Agreement Date”) between the following parties (“Parties”):

(i) 

(ii) 

BOK Financial Corporation, an Oklahoma corporation (“BOK Financial”); and,

Scott  B.  Grauer,  an  individual  currently  residing  in  Tulsa,  Oklahoma  (the 
“Executive”).

BOK Financial and Executive, in consideration of the promises and covenants set forth herein (the 
receipt and adequacy of which are hereby acknowledged) and intending to be legally bound hereby, agree 
as follows:

(1) 

Purpose of This Agreement.  The purpose of this Agreement is as follows:

(a) 

(b) 

(c) 

BOK  Financial  is  a  financial  holding  company,  subject  to  regulation  by  the  Board  of 
Governors  of  the  Federal  Reserve  System.   The  subsidiaries  of  BOK  Financial  include 
BOKF, NA, a national association engaged in banking and BOSC, Inc., a registered broker-
dealer.

The  Executive  has  extensive  prior  experience  in  financial  services  and  banking  and  is 
currently employed as Executive Vice President, Wealth Management and Chief Executive 
Officer, BOSC, Inc. of BOK Financial and BOKF, NA, reporting to the Chief Executive 
Officer. 

The  purpose  of  this Agreement  is  to  set  forth  the  terms  and  conditions  on  which  BOK 
Financial shall employ the Executive and the Executive shall serve as an officer of BOK 
Financial, BOKF, NA, and other of their affiliates. 

Prior Agreement Superseded.  This agreement supersedes, from and after the Effective Date, any 
employment agreement between Executive and BOK Financial and/or BOKF, NA (excluding, for 
avoidance of doubt, any rights of Executive arising under the BOK Financial 2003 Stock Option 
Plan or, the BOK Financial 2009 Omnibus Incentive Plan.

Employment.  Effective as of the Agreement Date, BOK Financial hereby employs the Executive, 
and the Executive hereby accepts employment with  BOK Financial, on the following terms and 
conditions:

(a) 

Executive shall serve as Executive Vice President, Wealth Management and Chief Executive 
Officer, BOSC, Inc. of BOK Financial and BOKF, NA.  Executive shall be responsible for 
those divisions and business lines of BOK Financial and BOKF, NA as the Chief Executive 
has heretofore established and as may hereafter be established by the Chief Executive Officer 
from time to time.

(2) 

(3) 

Exhibit 10.4.11

(b) 

(c) 

(d) 

Executive shall devote all time and attention reasonably necessary to the affairs of BOK 
Financial and BOKF, NA and shall serve BOK Financial and BOKF, NA diligently, loyally, 
and to the best of his ability. 

Executive shall serve in such other or additional positions as an officer and/or director of 
BOK Financial and BOKF, NA or any of their affiliates as the Chief Executive Officer of 
BOK Financial may reasonably request; provided, however, Executive’s residence and place 
of work shall be in the Tulsa, Oklahoma area.

Notwithstanding anything herein to the contrary, Executive shall not be precluded from 
engaging in any charitable, civic, political or community activity or membership in any 
professional organization.

(4) 

Compensation.  As the sole, full and complete compensation to the Executive for the performance 
of all duties of Executive under this Agreement and for all services rendered by Executive to BOK 
Financial and/or to any affiliate of BOK Financial:

(a) 

(b) 

(c) 

(d) 

BOK Financial shall pay the Executive an annual salary (the “Annual Salary”) equal to 
Executive’s Annual Salary in effect as of the Agreement Date during the Term (as hereafter 
defined).   The Annual  Salary  shall  be  payable  in  installments  in  arrears,  less  usual  and 
customary payroll deductions for FICA, federal and state withholding, and the like, at the 
times and in the manner in effect in accordance with the usual and customary payroll policies 
generally in effect from time to time at BOK Financial. 

The Annual Salary shall not be decreased at any time during the Term of this Agreement. 
The  Annual  Salary  may  be  increased  annually  in  accordance  with  BOK  Financial’s 
compensation review practices in effect from time to time for senior executives.

BOK  Financial  shall  pay  and  provide  to  Executive  pension,  thrift,  medical  insurance, 
disability insurance plan benefits, and other fringe benefits, on the same terms and conditions 
generally in effect for senior executive employees of the BOK Financial and its affiliates 
(the “Additional Benefits”).  

BOK Financial may, from time to time in BOK Financial’s sole discretion consistent with 
the practices generally in effect for senior executive employees of the BOK Financial and 
its affiliates, pay or provide, or agree to pay or provide Executive a bonus, stock option, 
restricted stock, other incentive or performance based compensation.  

(i) 

(ii) 

BOKF Financial shall provide annual incentive and long term incentive awards to 
Executive in accordance with BOK Financial’s Executive Incentive Compensation 
Plan as adopted by the BOK Financial’s Board of Directors from time to time. 

All such bonus, stock option, restricted stock, or other incentive or performance 
based  compensation,  regardless  of  its  nature  (hereinafter  called  “Performance 
Compensation”) shall not constitute Annual Salary.

(e) 

BOK Financial shall reimburse Executive for reasonable and necessary entertainment, travel 
and other expenses in accordance with BOK Financial’s standard policies in general effect 
for senior executives of BOK Financial.

2

Exhibit 10.4.11

(f) 

(g) 

(h) 

Executive shall be allowed vacation, holidays, and other employee benefits not described 
above  in  accordance  with  BOK  Financial’s  standard  policy  in  general  effect  for  BOK 
Financial’s senior executives. Executive shall be entitled to four weeks paid vacation each 
year.

BOK Financial shall permit Executive to participate in a deferred compensation plan on the 
terms and conditions established by BOK Financial for senior executives.

Executive hereby agrees to accept the foregoing compensation as the sole, full and complete 
compensation  to  Executive  for  the  performance  of  all  duties  of  Executive  under  this 
Agreement and for all services rendered by Executive to BOK Financial or any affiliate of 
BOK Financial.

(5) 

Term  of  Employment.    The  term  (the  “Term”)  of  Executive’s  employment  (“Employment”) 
pursuant to this Agreement shall commence on the Agreement Date (the “Commencement”) and 
shall  continue  thereafter  provided  that  upon  ninety  days  prior  written  notice,  either  Party  may 
terminate this Agreement.

(6) 

Termination of Employment.  Notwithstanding the provisions of paragraph 5 of this Agreement, 
the Employment may be terminated on the following terms and conditions:

(a) 

Termination by BOK Financial Without Cause.  In the event BOK Financial terminates 
Employment  of  Executive  without  cause  during  the  Term  or  upon  termination  of  this 
Agreement as provided in Paragraph 5:

(i) 

BOK Financial shall forthwith upon such termination (A) pay to Executive BOK 
Financial’s  standard  severance  pay  for  senior  executives  in  effect  at  the  time  of 
termination and, in addition, an amount equal to Executive’s then Annual Salary 
payable in one lump sum payment, (B) the Executive shall be entitled to receive any 
Additional  Benefits  accrued  through,  but  not  beyond  the  effective  date  of  such 
termination which are payable under the terms and provisions of benefit plans then 
in effect in accordance with paragraph 4(c) above, (C) Executive shall be entitled 
to receive pay for vacation in accordance with BOK Financial’s then existing policy 
for terminating senior executives, (D) options held by Executive under the BOKF 
2003 Stock Option Plan and the BOKF 2009 Omnibus Incentive Plan shall vest shall 
be exercisable for a period of ninety days following such termination as provided 
in such plans, (E) Restricted stock held by Executive shall continue to be owned by 
the Executive, but shall remain subject to all restrictions applicable to the restricted 
stock  as  provided  under  the  Executive  Incentive  Plan  and  the  2009  Omnibus 
Incentive Plan, and (F) Executive shall be entitled to receive those amounts due 
Executive pursuant to paragraph 8(b) and shall be bound by the Non-Solicitation 
Agreement (as hereafter defined).

(ii) 

If Executive is terminated for any reason other than for cause following a Change 
of Control (as hereafter defined), BOK Financial shall pay Executive upon such 
termination in one lump sum payment an amount equal to two times Executive’s 
then Annual  Salary  at  the  time  of  termination  in  addition  to  an  amount  equal  to 
Executive’s then Annual Salary through, but not beyond the effective date of the 

3

Exhibit 10.4.11

termination.  This payment shall be in lieu of any payment that would otherwise be 
paid pursuant to paragraph 6(a)(i)(A), but Executive shall be entitled to the benefit 
of the other provisions of paragraph 6(a)(i).   As used herein, a Change of Control 
shall be deemed to have occurred if, and only if: 

(A) 

George  B.  Kaiser,  affiliates  of  George  B.  Kaiser,  George  B.  Kaiser 
Foundation,  George  Kaiser  Family  Foundation,  and/or  members  of  the 
family of George B. Kaiser collectively cease to own more shares of the 
voting capital stock of BOK Financial than any other shareholder (or group 
of shareholders acting in concert to control BOK Financial to the exclusion 
of  George  B.  Kaiser,  affiliates  of  George  B.  Kaiser,  George  B.  Kaiser 
Foundation,  George  Kaiser  Family  Foundation,  and/or  members  of  the 
family of George B. Kaiser); or,

(B) 

BOK Financial shall cease to own directly and indirectly more than fifty 
percent (50%) of the voting capital stock of BOKF, NA.

(b) 

Termination by BOK Financial for Cause.  BOK Financial may terminate the Employment 
for cause on the following terms and conditions:

(i) 

BOK Financial shall be deemed to have cause to terminate Executive’s Employment 
only in one or more of the following events:

(A) 

(B) 

(C) 

(D) 

(E) 

The Executive shall fail to substantially perform his obligations under this 
Agreement (except as a result of Executive’s incapacity due to physical or 
mental illness) after having first received notice of such failure and thirty 
days within which to correct the failure;

The Executive commits any act which is reasonably deemed to have been 
intended by Executive to injure BOK Financial or any of its affiliates;

The Executive is charged, indicted or convicted of any criminal act or act 
involving moral turpitude which BOK Financial reasonably deems adversely 
affects  the  suitability  of  Executive  to  serve  BOK  Financial  or  any  of  its 
affiliates;

The Executive commits any dishonest or fraudulent act which BOK Financial 
reasonably deems material to BOK Financial or any of its affiliates, including 
the reputation of BOK Financial or any of its affiliates; or,

Any refusal by Executive to obey orders or instructions of the Chief Executive 
Officer  of  BOK  Financial  or  BOKF,  NA,  unless  such  instructions  would 
require  Executive  to  commit  an  illegal  act,  could  subject  Executive  to 
personal  liability,  would  require  Executive  to  violate  the  terms  of  this 
Agreement,  are  inconsistent  with  recognized  ethical  standards,  or  would 
otherwise be inconsistent with the duties of an officer of a bank.

(ii) 

BOK Financial shall be deemed to have cause to terminate Executive’s Employment 
only when a majority of the members of the Board of Directors of BOK Financial 

4

Exhibit 10.4.11

finds that, in the good faith opinion of such majority, the Executive committed one 
or more of the acts set forth in clauses (A) through (E) of the preceding subparagraph, 
such finding to have been made after at least twenty (20) business days’ notice to 
the Executive and an opportunity for the Executive, together with his counsel, to be 
heard before such majority.  The determination of such majority, made as set forth 
above, shall be binding upon BOK Financial and the Executive.

(iii) 

The effective date of a termination for cause shall be the date of the action of such 
majority  finding  the  termination  was  with  cause.    In  the  event  BOK  Financial 
terminates  Executive’s  Employment  for  cause,  (A)  BOK  Financial  shall  pay 
Executive the Executive’s then Annual Salary through, but not beyond, the effective 
date of the termination and (B) the Executive shall receive those Additional Benefits 
accrued through but not beyond the effective date of such termination which are 
payable under the terms and provisions of benefit plans then in effect in accordance 
with paragraph 4(c) above, (C) BOK Financial shall pay the Executive for vacation 
in accordance with BOK Financial’s then existing policy for senior executives, and 
(D)Executive shall be entitled to receive those amounts due Executive pursuant to 
paragraph  8(b)  and  Executive  shall  be  bound  by  the  provisions  of  the  Non-
Solicitation Agreement.

(7) 

Provisions Respecting Illness and Death.  In the event Executive becomes disabled as defined in 
Section 409A(a)(2)(C) of the Internal Revenue Code, BOK Financial may terminate Executive’s 
Employment  without  further  or  additional  compensation  being  due  the  Executive  from  BOK 
Financial except Annual Salary accrued through the date of termination, Additional Benefits accrued 
through the date of such termination under benefit plans then in effect in accordance with paragraph 
4(c)  above,  and  vacation  in  accordance  with  BOK  Financial’s  then  existing  policy  for  senior 
executives,    and  the  provisions  of  paragraph  8  shall  apply.  Without  limiting  the  generality  of 
paragraph 4(c), Executive shall upon such termination receive those benefits provided in BOK 
Financial’s long term disability policy then in effect. In the event of the death of the Executive, the 
Employment of the Executive shall automatically terminate as of the date of death without further 
or additional compensation being due the Executive, except BOK Financial shall pay to the estate 
of the Executive the Annual Salary in effect on the date of death and accrued through the date of 
termination and the Additional Benefits accrued through the date of such termination under benefit 
plans  then  in  effect  in  accordance  with  paragraph  4(c)  above.    BOK  Financial  shall  make  the 
payments due Executive in one lump sum within forty-five days following the date of termination.

(8) 

Agreement  Not  to  Solicit.    The  provisions  of  this  paragraph  are  hereafter  called  the  “Non-
Solicitation Agreement”. 

(a) 

Executive  agrees  that,  for  a  period  of  two  (2)  years  following  any  termination  of  the 
Employment for cause, and for a period of one (1) year following any termination of the 
Employment for any reason other than cause (including expiration of the Term), Executive 
shall not directly or indirectly (whether as an officer, director, employee, partner, stockholder, 
creditor or agent, or representative of other persons or entities) contact or solicit, in any 
manner indirectly or directly, individuals or entities who were at any time during the original 
or any extended Term clients of BOK Financial or any of its affiliates for the purpose of 
providing banking, trust,  investment, or other services provided by BOK Financial or any 
of its affiliates during the Term or contact or solicit employees of BOK Financial or any 
affiliates of BOK Financial to seek employment with any person or entity except BOK 

5

(b) 

(c) 

(d) 

Exhibit 10.4.11

Financial and its affiliates. This Non-Solicitation Agreement shall not apply to ownership 
by Executive of up to ten percent (10%) of the common stock of a corporation traded on 
the facilities of a national securities exchange engaged in the banking business of which 
Executive is not a director, officer, employee, agent or representative.

BOK Financial shall pay Executive, in addition to any other amounts which may be due 
Executive, during each year in which the Non-Solicitation Agreement is in effect, $3,000 
payable in installments in arrears, less usual and customary payroll deductions for FICA, 
federal  and  state  withholding,  and  the  like,  at  the  times  and  in  the  manner  in  effect  in 
accordance with the usual and customary payroll policies generally in effect from time to 
time at BOK Financial.  Notwithstanding the foregoing, the amounts due for the first six 
months  of  the  Non-Competition  Agreement  shall  be  paid  in  a  lump  sum  as  soon 
administratively possible following such six month period if Executive is determined to be 
a "specified employee as defined in Section 409A(a)(2)(B)(i).

Executive agrees that the Non-Solicitation Agreement and all the restrictions set forth in 
this Non-Solicitation Agreement are fair and reasonable.

Executive agrees that (i) any remedy at law for any breach of this Non- Agreement would 
be inadequate, (ii) in the event of any breach of this Non-Solicitation Agreement, the terms 
of this Non-Solicitation Agreement shall constitute incontrovertible evidence of irreparable 
injury to BOK Financial, and (iii) BOK Financial shall be entitled to both immediate and 
permanent injunctive relief without the necessity of establishing or posting any bond therefor 
to preclude any such breach (in addition to any remedies of law to which BOK Financial 
may be entitled).

(9) 

Confidential Information.  All references in this Section 9 to BOK Financial shall include BOK 
Financial’s affiliates.

(a) 

(b) 

Executive acknowledges that, during the Term and prior to the Term, Executive has had and 
will have access to Confidential Information (as hereinafter defined), all of which shall be 
made  accessible  to  Executive  only  in  strict  confidence;  that  unauthorized  disclosure  of 
Confidential  Information  will  damage  BOK  Financial’s  business;    that  Confidential 
Information would be susceptible to immediate competitive application by a competitor of 
BOK Financial; that BOK Financial’s business is substantially dependent on access to and 
the continuing secrecy of Confidential Information; that Confidential Information is unique 
to BOK Financial and known only to Executive and certain key employees and contractors 
of BOK Financial;  that BOK Financial shall at all times retain ownership and control of all 
Confidential Information; and that the restrictions contained in this  Section 9 are reasonable 
and necessary for the protection of BOK Financial’s business.

All  documents  or  other  records  containing  or  reflecting  Confidential  Information 
(“Confidential Documents”) prepared by or to which Executive has access are and shall 
remain the property of BOK Financial.  Executive shall not copy or use any Confidential 
Document  for  any  purpose  not  relating  directly  to  Executive’s  Employment  on  BOK 
Financial’s behalf, or use or disclose any Confidential Document to any party other than 
BOK Financial or its employees and shall not sell Confidential Documents to any party. 
Upon the termination of this Agreement or upon BOK Financial’s request before or after 
such termination, Executive shall immediately deliver to BOK Financial or its designee 

6

(c) 

(d) 

Exhibit 10.4.11

(and shall not keep in Executive’s possession or deliver to anyone else) all Confidential 
Documents and all other property belonging to BOK Financial.  This paragraph shall not 
bar Employee from complying with any subpoena or court order, provided that Executive 
shall at the earliest practicable date provide a copy of the subpoena or court order to BOK 
Financial’s  Chief Executive Officer.

During the Term and for a period of four (4) years thereafter, regardless of the reason for 
termination of Executive’s employment, (i) Executive shall not disclose any Confidential 
Information to any third party and (ii) Executive shall use Confidential Information only in 
connection with and in furtherance of Executive’s Employment by BOK Financial and on 
behalf of its affiliates.

As used herein, Confidential Information means all nonpublic information concerning or 
arising from BOK Financial’s business, including particularly but not by way of limitation 
trade secrets used, developed or acquired by BOK Financial in connection with its business; 
information concerning the manner and details of BOK Financial’s operations, organization 
and  management;  financial  information  and/or  documents  and  nonpublic  policies, 
procedures and other printed or written material generated or used in connection with BOK 
Financial’s  business;  BOK  Financial’s  business  plans  and  strategies;  electronic  files  or 
documents  prepared  by  BOK  Financial  or  Executive  containing  the  identities  of  BOK 
Financial’s customers (including their addresses and telephone numbers), the nature and 
amounts of their assets and liabilities, and the specific individual customer needs being 
addressed by BOK Financial; the nature of fees and charges assessed by BOK Financial; 
nonpublic  forms,  contracts  and  other  documents  used  in  BOK  Financial’s  business;  the 
nature and content of any proprietary computer software used in BOK Financial’s business, 
whether owned by BOK Financial or used by BOK Financial under license from a third 
party; and all other nonpublic information concerning BOK Financial’s concepts, prospects, 
customers, employees, contractors, earnings, products, services, equipment, systems, and/
or  prospective  and  executed  contracts  and  other  business  arrangements.  Confidential 
Information  shall  not  include  (i)  general  skills  and  general  knowledge  of  the  industry 
obtained by reason of Executive’s association with BOK Financial; (ii) information that is 
or becomes public knowledge through no fault or action of Executive; (iii) any information 
received from an independent third party who is under no duty of confidentiality with respect 
to the information; or (iv) any information that, on advice of counsel, Executive is required 
to disclose by law or regulation.

(10) 

Surrender of Records and Property.  Upon termination of Executive’s employment with BOK 
Financial for whatever reason, in addition to Executive’s obligations pursuant to Paragraph 9(b), 
Executive  shall  deliver  promptly  to  BOK  Financial  all  records,  manuals,  books,  blank  forms, 
documents, letters, memoranda, notes, notebooks, reports, data, tables, calculations or copies thereof 
that relate in any way to the business, products, practices or techniques of BOK Financial or any 
of its affiliates, and all other information of BOK Financial or any of its affiliates, including, but 
not limited to, all documents that in whole or in part contain any information which is defined in 
this Agreement as Confidential Information and which is in the possession or under the control of 
Executive.

(11)  Compliance with Section 409A.  This Agreement is subject to the following provisions in order 
to ensure compliance with Section 409A of the Internal Revenue Code of 1986, as amended (Section 
409A”).

7

Exhibit 10.4.11

(a) 

(b) 

If  any  payment,  compensation  or  other  benefit  provided  to  the  Executive  in 
connection with his employment termination is determined, in whole or in part, to 
constitute  “nonqualified  deferred  compensation”  within  the  meaning  of  Section 
409A and the Executive is a specified employee as defined in Section 409A(2)(B)
(i), no part of such payments shall be paid before the day that is six (6) months plus 
one (1) day after the date of termination.  

The Parties acknowledge and agree that Section 409A and its application, if any, to 
the terms of this Agreement may be subject to change as additional guidance and 
regulations become available.  Anything to the contrary herein notwithstanding, all 
benefits  or  payments  provided  by  the  Company  to  the  Executive  that  would  be 
deemed to constitute “nonqualified deferred compensation” within the meaning of 
Section 409A are intended to comply with Section 409A.  If, however, any such 
benefit or payment is deemed to not comply with Section 409A, the Company and 
the  Executive  agree  to  renegotiate  in  good  faith  any  such  benefit  or  payment 
(including, without limitation, as to the timing of any severance payments payable 
hereof) so that either (i) Section 409A will not apply or (ii) compliance with Section 
409A will be achieved.

(c) 

All  payments  required  to  be  made  by  Bank  hereunder  to  the  Executive  may  be 
adjusted to the withholding of such amounts, if any, relating to tax and other payroll 
deductions as the Bank may reasonably determine should be withheld pursuant to 
any applicable law or regulation.

(12)  Miscellaneous Provisions.  The following miscellaneous provisions shall apply to this Agreement:

(a) 

All notices or advices required or permitted to be given by or pursuant to this Agreement, 
shall be given in writing.  All such notices and advices shall be (i) delivered personally or 
(ii) delivered for overnight delivery by a nationally recognized overnight courier service. 
Such  notices  and  advices  shall  be  deemed  to  have  been  given  (i)  the  first  business  day 
following the date of delivery if delivered personally or (ii) on the date of receipt if delivered 
for overnight delivery by a nationally recognized overnight courier service.  All such notices 
and advices and all other communications related to this Agreement shall be given as follows:

If to BOK Financial: 

BOK Financial Corporation
Attn: Stanley A. Lybarger
Bank of Oklahoma Tower
P.O. Box 2300
Tulsa, Oklahoma 74192
Telephone No.: (918) 588-6000
Facsimile No.: (918) 295-6379
slybarger@mail.bok.com

and

Chief Human Resources Officer
Attn:  Stephen D. Grossi
Bank of Oklahoma Tower

8

Exhibit 10.4.11

With a Copy to: 

P.O. Box 2300
Tulsa, Oklahoma 74192
Telephone No. 918- 595-3153

Frederic Dorwart
Old City Hall
124 East Fourth Street
Tulsa, OK 74103-5010
Telephone No.: (918) 583-9945
Facsimile No.: (918) 583-8251
FDorwart@FDLaw.com

If to Executive: 

Scott B. Grauer
9629 Colonial Drive
Claremore, OK  74019

(b) 

(c) 

(d) 

(e) 

(f) 

(g) 

(h) 

or to such other address as the Party may have furnished to the other Parties in accordance 
herewith, except that notice of change of addresses shall be effective only upon receipt.

This Agreement is made and executed in Tulsa, Oklahoma and all actions or proceedings 
with respect to, arising directly or indirectly in connection with, out of, related to or from 
this Agreement, shall be litigated in courts having situs in Tulsa, Oklahoma.

This Agreement shall be subject to, and interpreted by and in accordance with, the laws of 
the State of Oklahoma without regard to its conflict of law provisions.

This Agreement is the entire Agreement of the Parties respecting the subject matter hereof. 
There  are  no  other  agreements,  representations  or  warranties,  whether  oral  or  written, 
respecting the subject matter hereof, except as stated in this Agreement.

This Agreement, and all the provisions of this Agreement, shall be deemed drafted by all of 
the Parties hereto.

This Agreement  shall  not  be  interpreted  strictly  for  or  against  any  Party,  but  solely  in 
accordance with the fair meaning of the provisions hereof to effectuate the purposes and 
interest of this Agreement.

Each  Party  hereto  has  entered  into  this Agreement  based  solely  upon  the  agreements, 
representations and warranties expressly set forth herein and upon her or his own knowledge 
and investigation. Neither Party has relied upon any representation or warranty of any other 
Party hereto except any such representations or warranties as are expressly set forth herein.

Each of the persons signing below on behalf of a Party hereto represents and warrants that 
he or she has full requisite power and authority to execute and deliver this Agreement on 
behalf of the Parties for whom he or she is signing and to bind such Party to the terms and 
conditions of this Agreement.

9

(i) 

(j) 

(k) 

(l) 

(m) 

(n) 

(o) 

(p) 

This Agreement may be executed in counterparts, each of which shall be deemed an original.  
This Agreement  shall  become  effective  only  when  all  of  the  Parties  hereto  shall  have 
executed the original or counterpart hereof.  This Agreement may be executed and delivered 
by a facsimile transmission of a counterpart signature page hereof.

Exhibit 10.4.11

In any action brought by a Party hereto to enforce the obligations of any other Party hereto, 
the prevailing Party shall be entitled to collect from the opposing Party to such action such 
Party’s reasonable litigation costs and attorneys fees and expenses (including court costs, 
reasonable fees of accountants and experts, and other expenses incidental to the litigation).

This Agreement shall be binding upon and shall inure to the benefit of the Parties and their 
respective heirs, personal representatives, successors and assigns. 

This is not a third party beneficiary contract, except BOK Financial (including each affiliate 
thereof) shall be a third party beneficiary of this Agreement. 

This Agreement may be amended or modified only in a writing, as agreed to by the Parties 
hereto, which specifically references this Agreement.

A Party to this Agreement may decide or fail to require full or timely performance of any 
obligation arising under this Agreement. The decision or failure of a Party hereto to require 
full or timely performance of any obligation arising under this Agreement (whether on a 
single occasion or on multiple occasions) shall not be deemed a waiver of any such obligation. 
No such  decisions or  failures shall  give rise  to any claim of estoppel, laches, course of 
dealing, amendment of this Agreement by course of dealing, or other defense of any nature 
to any obligation arising hereunder.

In the event any provision of this Agreement, or the application of such provision to any 
person or set of circumstances, shall be determined to be invalid, unlawful, or unenforceable 
to any extent for any reason, the remainder of this Agreement, and the application of such 
provision to persons or circumstances other than those as to which it is determined to be 
invalid, unlawful, or unenforceable, shall not be affected and shall continue to be enforceable 
to the fullest extent permitted by law.

None of the compensation or other payments to Executive provided for in, or that may be 
made pursuant to, this Agreement are intended by the Parties to be deferred compensation 
within the meaning of Section 409A.  If, however, the Executive is a " specified employee" 
as  defined  in  Section  409A(a)(2)(B)(i),  then  the  other  provisions  of  this  Agreement 
notwithstanding, no compensation that is "deferred compensation" within the meaning of 
Section 409A shall be paid to Executive sooner than six months and one day following the 
date of Executive s separation from service from the Company, as such date is determined 
in accordance with Section 409A.

10

 
 
 
 
 
 
 
 
 
 
 
 
Dated as of the Agreement Date.

Exhibit 10.4.11

BOK Financial Corporation

/s/ Stanley A. Lybarger
Name: Stanley A. Lybarger
Title: President and Chief Executive
Officer    

Executive

/s/ Scott B. Grauer
Individually

11

 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit 21

BOK FINANCIAL CORPORATION

SUBSIDIARIES OF THE REGISTRANT

Banking Subsidiaries

BOKF, National Association (1)

CoBiz Bank (7)

Other subsidiaries of BOK Financial Corporation

BOK Capital Service Corporation 

BOKC Real Estate Corporation (6)

BOKF Capital Corporation 

BOKF-CC (Collision Works), LLC 

BOKF-CC (FSE), LLC 

BOKF-CC (Heartland), LLC 

BOKF-CC (O2 Concepts), LLC 

BOKF-CC (QRC), LLC 

BOKF-CC (Switchgrass), LLC 

BOKF Energy Fund Investment I, LLC 

BOKF Equity, LLC 

BOKF Private Equity Limited Partnership 

BOKF Private Equity Limited Partnership II 

BOK Financial Securities, Inc. 

Cavanal Hill Distributors, Inc. 

CoBiz IM, Inc.  (7)

CoBiz Insurance, Inc.  (7)

CoBiz Risk Management, Inc.  (8)

CoBiz Wealth, LLC  (7)

HFP II, LLC 

The Milestone Group, Inc. (5)

RMA Holdings, Inc.  (7)

Switchgrass I, LLC 

Switchgrass II, LLC 

Switchgrass III, LLC 

Switchgrass IV, LLC 

Switchgrass V, LLC 

Switchgrass VI, LLC 

Switchgrass Holdings, LLC 

Switchgrass Management, LLC 

Switchgrass Properties, LLC 

Subsidiaries of BOKF, National Association (1)

Affiliated BancServices, Inc. 

Affiliated Financial Holding Co. 

Affiliated Financial Insurance Agency, Inc. 

BancOklahoma Agri-Service Corporation 

BOK Delaware, Inc. (3)

BOK Financial Asset Management, Inc. (2)

BOK Financial Equipment Finance, Inc. 

BOK Funding Trust (3)

BOKFCDF Fund I, LLC 

BOKF Community Development Fund, LLC 

BOKF Community Development Fund II 

BOKF Community Development Corporation 

BOKF Petro Holding, LLC 

BOKF Special Assets I, LLC 

BOSC Agency, Inc. (Oklahoma)

BOSC Agency, Inc. (New Mexico) (4)

BOSC Agency, Inc. (Texas) (2)

Calicotte Ranch HOA, LLC 

Cavanal Hill Investment Management, Inc. 

Cottonwood Valley Ventures, Inc. 

CVV Management, Inc. 

CVV Partnership, an Oklahoma General Partnership

Oklahoma New Markets Fund I, LLC 

Ottawa Land Partners, LLC (6)

Subsidiaries of CoBiz Bank (7)

AWREI, Inc. 

CoBiz Public Finance Inc.  

Western Real Estate Investors, Inc. 

All Subsidiaries listed above were incorporated in Oklahoma, except as noted.

(1)  Chartered by the United States Government
(2)  Incorporated in Texas
(3)  Incorporated in Delaware
(4)  Incorporated in New Mexico
(5)  Incorporated in Colorado
(6)  Incorporated in Kansas
(7)  Incorporated in Colorado
(8)  Incorporated in Nevada

Exhibit 23

Consent of Independent Registered Public Accounting Firm

We consent to the incorporation by reference in the following Registration Statements:

•  Registration Statement (Form S-8, No. 33-44121) pertaining to the Reoffer Prospectus of the Bank of Oklahoma Master 

Thrift Plan and Trust Agreement as amended October 6, 2008.

•  Registration Statement (Form S-8, No. 333-40280) pertaining to the Reoffer Prospectus of the BOK Financial Corporation 

Master Thrift Plan for Hourly Employees as amended October 6, 2008.

•  Registration Statement (Form S-8, No. 33-79836) pertaining to the Reoffer Prospectus of the BOK Financial Corporation 

Directors' Stock Compensation Plan.

•  Registration Statement (Form S-8, No. 333-32649) pertaining to the Reoffer Prospectus of the BOK Financial Corporation 

1997 Stock Option Plan.

•  Registration Statement (Form S-8, No. 333-93957) pertaining to the Reoffer Prospectus of the BOK Financial Corporation 

2000 Stock Option Plan.

•  Registration Statement (Form S-8, No. 333-62578) pertaining to the Reoffer Prospectus of the BOK Financial Corporation 

2001 Stock Option Plan.

•  Registration  Statement  (Form  S-8,  No.  333-106530)  pertaining  to  the  Reoffer  Prospectus  of  the  BOK  Financial 

Corporation 2003 Executive Incentive Plan.

•  Registration  Statement  (Form  S-8,  No.  333-106531)  pertaining  to  the  Reoffer  Prospectus  of  the  BOK  Financial 

Corporation 2003 Stock Option Plan.

•  Registration  Statement  (Form  S-8,  No.  333-135224)  pertaining  to  the  Reoffer  Prospectus  of  the  BOK  Financial 

Corporation 2003 Stock Option Plan.

•  Registration  Statement  (Form  S-8,  No.  333-158846)  pertaining  to  the  Reoffer  Prospectus  of  the  BOK  Financial 

Corporation 2009 Omnibus Incentive Plan.

•  Registration  Statement  (Form  S-3,  (No.  333-212120)  pertaining  to  the  Reoffer  Prospectus  of  the  BOK  Financial 

Corporation 2016 Subordinated Note Issuance.

•  Registration Statement (Form S-4, (No. 333-226211) pertaining to the Registration Statement for the registration of BOK 

Financial Corporation's common stock.

of our reports dated March 1, 2019, with respect to the consolidated financial statements of BOK Financial Corporation and the 
effectiveness of internal control over financial reporting of BOK Financial Corporation included in this Annual Report (Form 10-
K) of BOK Financial Corporation for the year ended December 31, 2018.

/s/ Ernst & Young LLP

Tulsa, Oklahoma

March 1, 2019 

CERTIFICATION PURSUANT TO
 SECTION 302 
OF THE SARBANES-OXLEY ACT OF 2002 
FOR THE CHIEF EXECUTIVE OFFICER

Exhibit 31.1

I, Steven G. Bradshaw, President and Chief Executive Officer of BOK Financial Corporation (“BOK Financial”), certify that:

1. 

I have reviewed this Annual Report on Form 10-K of BOK Financial;

2.  Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact 

necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading 
with respect to the period covered by this report;

3.  Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all 
material respects the financial condition, results of operations and cash flows of the registrant as of, and for, the periods 
presented in this report;

4.  The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and 
procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as 
defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and have:

a.  Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed 
under our supervision, to ensure that material information relating to the registrant, including its consolidated 
subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is 
being prepared;

b.  Designed such internal control over financial reporting, or caused such internal control over financial reporting to be 

designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the 
preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

c.  Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our 

conclusions about the effectiveness of the disclosure controls and procedures, as of the end of the period covered by this 
report based on such evaluation; and

d.  Disclosed in this report any change in the registrant's internal control over financial reporting that occurred during the 
registrant's most recent fiscal quarter (the registrant's fourth fiscal quarter in the case of an annual report) that has 
materially affected, or is reasonably likely to materially affect, the registrant's internal control over financial reporting; 
and

5.  The registrant's other certifying officer(s) and I have disclosed, based on our most recent evaluation of internal control over 
financial reporting, to the registrant's auditors and the audit committee of the registrant's board of directors (or persons 
performing the equivalent functions):

a.  All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting 

which are reasonably likely to adversely affect the registrant's ability to record, process, summarize and report financial 
information; and

b.  Any fraud, whether or not material, that involves management or other employees who have a significant role in the 

registrant's internal control over financial reporting.

Date:  March 1, 2019 

/s/ Steven G. Bradshaw

Steven G. Bradshaw

President

Chief Executive Officer

BOK Financial Corporation

 
 
 
 
 
 
 
CERTIFICATION PURSUANT TO
 SECTION 302
 OF THE SARBANES-OXLEY ACT OF 2002
 FOR THE CHIEF FINANCIAL OFFICER

Exhibit 31.2

I, Steven E. Nell, Chief Financial Officer of BOK Financial Corporation (“BOK Financial”), certify that:

1. 

I have reviewed this Annual Report on Form 10-K of BOK Financial;

2.  Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact 

necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading 
with respect to the period covered by this report;

3.  Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all 

material respects the financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented 
in this report;

4.  The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and 

procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined 
in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and have:

a.  Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under 

our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made 
known to us by others within those entities, particularly during the period in which this report is being prepared;

b.  Designed such internal control over financial reporting, or caused such internal control over financial reporting to be 

designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the 
preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

c. 

d. 

 Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions 
about the effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on 
such evaluation; and

 Disclosed in this report any change in the registrant's internal control over financial reporting that occurred during the 
registrant's most recent fiscal quarter (the registrant's fourth fiscal quarter in the case of an annual report) that has materially 
affected, or is reasonably likely to materially affect, the registrant's internal control over financial reporting; and

5.  The registrant's other certifying officer(s) and I have disclosed, based on our most recent evaluation of internal control over 

financial reporting, to the registrant's auditors and the audit committee of the registrant's board of directors (or persons performing 
the equivalent functions):

a.  All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting 

which are reasonably likely to adversely affect the registrant's ability to record, process, summarize and report financial 
information; and

b. 

 Any fraud, whether or not material, that involves management or other employees who have a significant role in the 
registrant's internal control over financial reporting.

Date:  March 1, 2019 

/s/ Steven E. Nell

Steven E. Nell

Executive Vice President

Chief Financial Officer

BOK Financial Corporation

 
  
 
 
 
 
 
 
CERTIFICATION PURSUANT TO
 18 U.S.C. SECTION 1350,
 AS ADOPTED PURSUANT TO
 SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002

Exhibit 32

In connection with the Annual Report of BOK Financial Corporation (“BOK Financial”) on Form 10-K for the fiscal year 
ending December 31, 2018 as filed with the Securities and Exchange Commission on the date hereof (the “Report”), we, 
Steven G. Bradshaw and Steven E. Nell, Chief Executive Officer and Chief Financial Officer, respectively, of BOK Financial, 
certify, pursuant to 18 U.S.C. § 1350, as adopted pursuant to § 906 of the Sarbanes-Oxley Act of 2002, that to our knowledge:

1. The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

2. The information contained in the Report fairly presents, in all material respects, the financial condition and results of

operations of BOK Financial as of, and for, the periods presented.

March 1, 2019 

/s/ Steven G. Bradshaw

Steven G. Bradshaw

President

Chief Executive Officer

BOK Financial Corporation

/s/ Steven E. Nell

Steven E. Nell

Executive Vice President

Chief Financial Officer

BOK Financial Corporation

This page has been left blank intentionally.

This page has been left blank intentionally.

This page has been left blank intentionally.

OUR FAMILY OF BRANDS

Consumer and Commercial Banking:

Wealth Management:

Transaction and Payment Processing:

Mortgage Banking:

CORPORATE HEADQUARTERS:

Bank of Oklahoma Tower
P.O. Box 2300
Tulsa, Oklahoma 74192
918.588.6000

GE-BA-7010