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                            December 21, 2021

       Steven E. Nell
       Director, Executive Vice President and Chief Financial Officer
       BOK Financial Corp
       Bank of Oklahoma Tower
       Boston Avenue at Second Street
       Tulsa, OK 74172

                                                        Re: BOK Financial Corp.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Filed February 24,
2021
                                                            Form 10-Q for the
Quarterly Period Ended September 30, 2021
                                                            Filed November 3,
2021
                                                            File No. 001-37811

       Dear Mr. Nell:

              We have limited our review of your filings to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Fiscal Year Ended December 31, 2020

       Cover Page

   1.                                                   We note that with the
filing of your Form 8-A on June 24, 2016 your Commission File
                                                        Number changed to
001-37811. Please represent to us that in all future periodic and
                                                        current reports filed
under the Exchange Act you will provide the correct file number.
 Steven E. Nell
FirstName  LastNameSteven E. Nell
BOK Financial   Corp
Comapany21,
December   NameBOK
               2021 Financial Corp
December
Page 2    21, 2021 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Lines of Business, page 42

2.       In the individual segment tables and accompanying narrative
disclosures you present and
         discuss "net loans charged off," which appear to be the amounts of the
provision for credit
         losses for the periods presented in your segment footnote. For
example, the 2020 "net
         loans charged off" for your Commercial Banking business of $69,475,000
from the table
         on page 43 agrees with the provision for credit losses amount for this
segment presented
         in Note 17 on page 140. Please represent to us that in future filings
you will revise your
         lines of business tables and discussions to properly identify your
provision or benefit for
         credit losses because charge-offs have a different connotation as you
disclose in Note 4
         and elsewhere.
Form 10-Q for the Quarterly Period Ended September 30, 2021

Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 1

3.       Please revise your disclosure in your future quarterly periodic
filings to include a
         discussion of material changes in your results of operations on a
year-to-date basis in
         addition to the quarterly basis you currently disclose. Refer to
Regulation S-K, Item
         303(c)(2)(i).
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Rolf Sundwall at 202-551-3105 or Mark Brunhofer at
202-551-3638
with any questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Finance