Small business and community development loans

SASB: FN-CB-240a.1
Loans designed to promote small business and small farms

Loans designed to promote community development

¹ 2021 data includes Paycheck Protection Loans meeting CRA reporting criteria.

We continue to respond to the credit needs across our footprint through community development lending. Our community development lending supports the development and retention of affordable housing, economic development, the revitalization/stabilization of low- to moderate-income (LMI) areas and organizations that provide community services for LMI individuals and families.

Related documents

Standards of Conduct
The Audit Committee of the Board of Directors annually reviews and approves the company’s Standards of Conduct on which employees are annually trained and attest to. Each member of the Board of Directors takes an annual Oath of Office prescribed by the Office of the Comptroller of the Currency (OCC) and is bound by the company’s Code of Ethics.

Proxy Statement
The company’s annual proxy statement identifies responsibilities of board committees.

10-K
The company’s 10-K reviews a wide array of company performance factors, including any legal proceedings associated with fraud, insider trading, anti-trust, anti-competitive behavior, market manipulation, malpractice, or other related financial industry laws or regulations.

Community Reinvestment Act program

BOK Financial has maintained an Outstanding Community Reinvestment Act (CRA) rating since 2013 with an exam cycle every three years, signifying the bank’s ongoing commitment to providing lending, investments and services in the communities we serve. The company maintains a strong CRA program by:

• Tracking lending opportunities in our communities and working with government, business and non-profit partners.
• Reviewing lending distribution quarterly.
• Annually (or as needed) reviewing assessment area boundaries.
• Establishing and communicating goals for CRA performance.
• Measuring the bank against our peers.
• Considering CRA implications for opening and closing retail bank offices.
• Investing in our communities.
• Partnering and volunteering with nonprofits and organizations that impact LMI individuals and communities.

BOK Financial actively monitors compliance with the Home Mortgage Disclosure Act (HMDA) and CRA requirements. Teams monitor activities; identify, track and report issues discovered in the lines of business; and incorporate findings into formal reporting back to the lines of business. Monitoring also aids in identifying opportunities to inform the scoping of testing performed by HMDA and CRA management. The CRA Officer is responsible for coordinating, developing, implementing and administering the CRA compliance program and reports to the Chief Compliance Officer.

CRA Public Files

Fair and responsible banking

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

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

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

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