October 25, 2024

Martin Grunst
Chief Financial Officer
BOK Financial Corporation
Bank of Oklahoma Tower
Boston Avenue at Second Street
Tulsa, OK 74192

       Re: BOK Financial Corporation
           Form 10-Q for Fiscal Quarter Ended June 30, 2024
           File No. 001-37811
Dear Martin Grunst:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-Q for Fiscal Quarter Ended June 30, 2024
Financial Condition - Securities, page 19

1.     Please provide us with, and revise future filings disclosures to
include, a detailed
       explanation of how you accounted for the Exchange Offer, separately
addressing your
       accounting for the exchange and subsequent accounting for the Visa Class
B-2 and
       Class C shares. Specifically, disclose your basis of accounting for both
the Visa Class
       B-2 and Class C shares and identify where these shares are included in
the balance
       sheet. In addition, please provide us with and revise future filings to
include a brief
       description of the transfer restrictions and the conversion rate of the
Class B-2 shares
       as of the most recent period end, noting if true that this conversion
rate may be
       adjusted by Visa depending on developments related to the litigation
matters.
2.     We note your disclosure on pages 2, 6 and 11 that the second quarter of
2024 included
       a $53.8 million pre-tax gain on the conversion of Visa B shares under
the recently
       announced Exchange Offer by Visa, Inc. Please tell us, and revise future
filings to
       clarify, whether this gain relates to the exchange of the Visa Class B-1
shares to Visa
 October 25, 2024
Page 2

       Class C shares and how the gain was determined (e.g., as a result of
recording the
       Visa Class C Visa shares at the associated fair value of the converted
Class A shares).
        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.

       Please contact Ben Phippen at 202-551-3697 or John Spitz at 202-551-3484
with any
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Finance