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Index Section Topics 1 Cover letter 2 Overview 3 Fraudulent activities 4 How this occurred 5 Critical evidence tax commission emails 6 Evidence - examination and results 7 Ongoing tax credit investigation and achievements 8 Summary

June 7, 2010

SEC letter - Evidence of suspected fraudulent tax claims involving BOK and Cimarron Business Capital (cont)

Overview

The recent surfacing of an Oklahoma Tax Commission auditor's report questioning BOK tax credit claims revealed evidence suggesting long-standing fraud, benefiting BOK insiders in the form of state income tax credits. Complete evidence for 2006-2009 clearly suggests $91 million in fraud. Partial evidence for additional years suggests potentially more than $400 million.

BOK misrepresented and failed to fully and properly disclose in SEC filings:

• financial transactions used to facilitate the fraud;
• the full amount BOK received in fraudulent tax credits;
• tax credits were sold to insiders' at nearly 80% discount;
• the personal gain of more than $72 million by insiders'.

BOK SEC filings available and examined for years 2001 - 2009 View

BOK state income tax credit claims available and examined for years 2006 thru 2009 View

The following conclusions will be restricted to the 2006 thru 2009 period with complete evidence.

Assuming the 2006 thru 2009 model was used, the following would apply:

• SEC filings suggest $188 million more in tax credits for 2001 through 2005. View
• amended 2008 claim $140 million was certified and to be taken in out years. View

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