# BOK Financial Corporation: AI strategy

Source: https://www.bankingnewsai.com/banks/bok-financial
Last updated: Oct 13, 2026

*A data-first rebuild under a new chief data and analytics officer, with AI discussed publicly mostly through the bank's own journalism on fraud, healthcare and the economy rather than through product launches.*

## How is BOK Financial using AI?

BOK Financial, the $53 billion Tulsa-based parent of BOKF, N.A. with operations across Oklahoma, Texas, Colorado, Arizona, Kansas, Missouri, New Mexico and Arkansas, has said little about its own AI deployments and has not disclosed AI spending, use-case counts or productivity claims. The one deployment on record comes from a vendor: in an August 2026 case study, Vanilla says BOK's Advisor Trust Services team uses its AI platform, with custom prompts, to review trust documents and saves roughly four hours on average on each initial trust review, that BOK ran a security review of close to a year before adopting it and developed its own AI governance policy along the way, and that people stay in the loop for decisions such as discretionary distributions. What is on the record is organisational: Shanthi Pudota, a 30-year data executive from Expedia, Discover and Fannie Mae, is senior vice-president and chief data and analytics officer and 'leads BOK Financial's enterprise data and AI strategy', described in March 2026 as a shift to a 'data-first model' in which data is a shared enterprise asset so that 'analytics and AI [can] scale responsibly'. The bank's public voice on AI otherwise comes through its own editorial site, The Statement, where chief information security and privacy officer Paul Tucker warned in January 2026 that 'AI is making scams faster, cheaper, and more convincing than ever', and where its fraud and healthcare specialists write about generative-AI-enabled phishing and deepfake scams (a 'double-edged sword'), social engineering behind ACH and wire fraud, and AI in healthcare operations (57% of healthcare executives rank AI clinical solutions as their top technology initiative). Financially the bank earned $155.8 million in the first quarter of 2026 with operating expense falling to $354.2 million, CEO Stacy Kymes is counting on a new mortgage-finance unit for 2026 growth, and BOK ranked 18th among banks for customer reputation in American Banker's 2026 survey. Treat this page as a thin record: a national bank with a named AI and data leader, an explicit governance framing and a specialty-lending data heritage (a warehouse of forecasts on more than 200,000 oil and gas wells), but no disclosed AI product roadmap. The filings add a little: the 2025 10-K (February 2026) says BOK 'continue[s] to evaluate and selectively deploy' AI, machine learning and generative AI, and, new against the prior year's risk factor, that the board gets periodic updates on AI governance but 'does not approve individual AI capabilities', with each initiative going through an internal review of data quality, bias, regulatory compliance and ethics. None of the four earnings calls from October 2025 to July 2026 touched on AI, and the first- and second-quarter 2026 10-Qs mention it only in the glossary and in a macro scenario.

*Thin public record: No AI remarks on its last four earnings calls (Q3 2025 to Q2 2026), no bank-disclosed AI product, spend or use-case count (the one deployment on record, Vanilla trust-document review, comes from a vendor case study), and a 10-K AI passage that is a risk factor with a short governance description.*

## At a glance

| Field | Value |
| --- | --- |
| Lead bank | BOKF, National Association |
| Ticker | BOKF |
| Headquarters | Tulsa, OK |
| Consolidated assets | $52,985 million |
| Federal Reserve rank | 45 |
| Charter | National bank (OCC) |

## What AI partnerships and patents does BOK Financial have?

BOK Financial names one AI vendor, Vanilla, for trust and estate document review. Mastercard has been its exclusive card network since January 2024. No frontier-lab agreement, GPU purchase, AI capital figure or AI patent assigned to BOKF, N.A. is public; Google Patents searches under the bank's names did not identify one. ([Vanilla (vendor case study)](https://justvanilla.com/customer-stories/how-bok-financial-uses-vanilla-to-review-trusts-faster), [Mastercard](https://www.mastercard.com/global/en/news-and-trends/press/2024/January/mastercard-and-bok-financial-corporation-announce-expanded-payments-agreement.html))

| Item | What it is | Status | Date | Sources |
| --- | --- | --- | --- | --- |
| Vanilla | AI platform for trust and estate document review, with custom prompts and a human in the loop | In production (vendor-reported) | 2026-08-13 | [Vanilla (vendor case study)](https://justvanilla.com/customer-stories/how-bok-financial-uses-vanilla-to-review-trusts-faster), [Vanilla (vendor webinar page)](https://justvanilla.com/webinars/how-trust-companies-can-use-ai-to-serve-more-clients) |
| Mastercard (network) | Exclusive network for BOK debit and commercial portfolios and extended TransFund processing relationship | In production | 2024-01-30 | [Mastercard](https://www.mastercard.com/global/en/news-and-trends/press/2024/January/mastercard-and-bok-financial-corporation-announce-expanded-payments-agreement.html) |
| Mastercard (security services) | Cyber and intelligence solutions, digital identity and tokenization offered to BOK customers; no AI product named | In production | 2024-01-30 | [Mastercard](https://www.mastercard.com/global/en/news-and-trends/press/2024/January/mastercard-and-bok-financial-corporation-announce-expanded-payments-agreement.html) |

## Key points

- Named leader: Shanthi Pudota, SVP and chief data and analytics officer, owns 'enterprise data and AI strategy' and a shift to a data-first operating model (March 2026).
- Framing is governance-led: build data foundations so that 'analytics and AI [can] scale responsibly while remaining aligned with business priorities'.
- Public AI content is defensive: the bank's fraud team warns that ChatGPT-class tools write convincing phishing and that deepfake imagery is rising; ACH and wire fraud guidance stresses human verification over tools.
- Vendor-reported deployment: Vanilla's AI platform reviews trust documents for BOK's Advisor Trust Services team, saving roughly four hours per initial review (Vanilla case study, August 2026); BOK wrote its own AI governance policy during a near year-long security review.
- CISO Paul Tucker (January 2026): AI makes scams 'faster, cheaper, and more convincing', including voice and video impersonation, so old red flags such as bad grammar no longer work.
- Data heritage in energy lending: a three-year data warehouse centralising evaluations on 200,000-plus oil and gas wells improved risk analysis and lending outcomes.
- No disclosed AI spend, use-case count or customer-facing AI product; first-quarter 2026 net income $155.8 million with operating expense down $6.9 million.
- Filings: the 2025 10-K describes a per-initiative AI governance review (data quality, bias, compliance, ethics) with periodic board updates; the board does not approve individual AI capabilities. AI did not come up on the last four earnings calls.
- Reputation: 18th among banks by customer reputation in 2026 (score 79.7), down from 10th in 2025.
- Governance chain: CIO Derek Martin runs enterprise operations and IT; the CISO reports to Chief Risk Officer Mindy Mahaney, and the CISO briefs the board Risk Committee quarterly (2025 10-K, 2026 proxy).
- Fraud is the one area where the bank says it is applying AI itself: in July 2025 CISO Paul Tucker said BOK is 'implementing AI into our systems to better protect them', and in August 2026 treasury officer Joseph Rangel said AI-powered tools help identify anomalies.
- Only a proxy for technology spend exists: data processing and communications expense was $198.5 million in 2025, up $11.3 million (6%) on 'ongoing projects', and professional fees rose 15% to $62.2 million; no line is labelled AI.
- Zero of four earnings calls (Q3 2025 to Q2 2026) carried an AI remark; the 10-Qs for the first and second quarters of 2026 mention AI only in the glossary and in the macro forecast ('AI investments help lift consumer spending levels and labor force productivity').
- No patent or published application assigned to BOKF, N.A. or BOK Financial was identified in Google Patents searches; the one named AI vendor, Vanilla, is a third party.

## Timeline

- Aug 17, 2026 — **18th for customer reputation** Score 79.7 in American Banker's 2026 survey. ([American Banker](https://www.americanbanker.com/news/top-banks-by-reputation-2026-customers))
- Aug 13, 2026 — **Vanilla case study: AI trust-document review** Vendor-reported: the Advisor Trust Services team saves roughly four hours on average per initial trust review; BOK reviewed Vanilla's security for close to a year and developed its own AI governance policy; humans keep discretionary decisions. ([Vanilla (vendor case study)](https://justvanilla.com/customer-stories/how-bok-financial-uses-vanilla-to-review-trusts-faster))
- Aug 11, 2026 — **Treasury officer on AI-driven fraud** Joseph Rangel describes voice cloning and deepfake impersonation of bank staff and recommends dual approvals, Positive Pay and call-back verification; he notes AI-powered tools also help detect anomalies. ([BOK Financial](https://bokfinancial.com/Insights/articles/How-to-protect-your-business-from-AI-driven-fraud-and-payment-scams))
- Aug 4, 2026 — **Second-quarter 2026 10-Q** AI appears only in the glossary and in the economic forecast ('Benefits from the One Big Beautiful Bill and AI investments help lift consumer spending levels and labor force productivity'). ([BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000048/bokf-20260630.htm))
- Jul 21, 2026 — **Second-quarter call: record loans, no AI** Net income $176.5 million ($156.5 million adjusted for a Visa gain), loans up 3.4% in the quarter and 11.5% on the year; the transcript has no AI remark. ([BOK Financial](https://investor.bokf.com/Q2-2026-Earnings-Full-Release-PDF), [Yahoo Finance (MarketBeat)](https://finance.yahoo.com/markets/stocks/articles/bok-financial-q2-earnings-call-180327529.html), [Investing.com](https://investing.com/news/transcripts/earnings-call-transcript-bok-financial-beats-q2-2026-eps-forecast-shares-slip-93CH-4803980))
- Jul 8, 2026 — **BOK experts frame AI as a productivity cycle** Cavanal Hill president Matt Stephani calls AI and automation 'deflationary'; chief investment strategist Steve Wyett says jobs will be 'different'; this is market commentary, not bank operations. ([BOK Financial](https://bokfinancial.com/Insights/articles/railroads-and-the-internet-may-offer-insight-into-the-path-ahead-with-ai))
- Jun 23, 2026 — **Vanilla announces BOK trust-operations webinar** Randy Kimmel is billed to speak on 23 July 2026 on how BOK uses AI in trust and estate operations; the page promises 'real workflows from BOK Financial's team'. ([Vanilla (vendor webinar page)](https://justvanilla.com/webinars/how-trust-companies-can-use-ai-to-serve-more-clients))
- Jun 17, 2026 — **Pudota on the American Banker Digital Banking agenda** Scheduled panel 'AI and Data Analytics' on data quality, lineage governance and 'AI debt' in banks, listed on her speaker profile. ([American Banker](https://digital-banking.americanbanker.com/profile/shanthi-pudota))
- May 6, 2026 — **First-quarter 2026 10-Q** AI appears in the glossary and in the macro scenario (AI investments lifting productivity and GDP); no AI deployment, spend or risk update beyond the 10-K. ([BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000034/bokf-20260331.htm))
- Apr 21, 2026 — **First-quarter call: no AI, efficiency ratio 63.2%** Kymes and CFO Martin Grunst discuss loans, fees and expenses; the transcript has no AI remark. Personnel expense fell $11.6 million; 2026 efficiency guidance stays near 63%. ([The Motley Fool (earnings call transcript)](https://fool.com/earnings/call-transcripts/2026/04/21/bok-financial-bokf-q1-2026-earnings-transcript))
- Apr 20, 2026 — **First-quarter 2026 results** Net income $155.8 million; operating expense $354.2 million. ([BOK Financial](https://investor.bokf.com/Q1-2026-Earnings-Full-Release-PDF))
- Mar 30, 2026 — **Pudota on data lineage and Customer 360** Forbes quotes the chief data and analytics officer: lineage 'enables trust, change management, regulatory confidence, and responsible AI'; governance, not technology, is the hard part of Customer 360. ([Forbes](https://forbes.com/sites/pamkaur/2026/03/30/the-women-behind-fintechs-most-important-infrastructure-decisions))
- Mar 30, 2026 — **Healthcare research on AI adoption** 57% of healthcare C-suites rank AI clinical solutions as their top technology initiative. ([BOK Financial (The Statement)](https://www.bokfinancial.com/insights/articles/ai-helps-healthcare-tackle-burnout-and-labor-shortages))
- Mar 24, 2026 — **Chief data and analytics officer profiled** Pudota leads enterprise data and AI strategy and a 'data-first' shift. ([American Banker](https://digital-banking.americanbanker.com/profile/shanthi-pudota))
- Mar 6, 2026 — **ACH and wire fraud guidance** Human verification, daily reconciliation and dual controls as the layer AI tools cannot replace. ([BOK Financial (The Statement)](https://www.bokfinancial.com/insights/articles/human-behavior-as-a-layer-of-defense-in-helping-prevent-ach-and-wire-fraud))
- Feb 18, 2026 — **2025 10-K adds an AI governance description** The board receives periodic updates on AI governance and risk management but does not approve individual AI capabilities; each initiative goes through an internal review of data quality, bias, regulatory compliance and ethics. ([BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000013/bokf-20251231.htm), [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535725000013/bokf-20241231.htm))
- Jan 27, 2026 — **CEO counts on mortgage finance for 2026** New unit could reach $1 billion in commitments; high-single-digit loan growth forecast. ([American Banker](https://www.americanbanker.com/news/bok-counting-on-mortgage-finance-for-a-boost-in-2026))
- Jan 26, 2026 — **CISO on AI-enabled business fraud** Paul Tucker: AI lets fraudsters produce convincing emails, calls, texts and voice or video impersonations, so businesses cannot rely on old red flags; layered payment controls and verification recommended. ([BOK Financial](https://bokfinancial.com/Insights/articles/business-fraud-has-changed-so-have-the-warning-signs))
- Jan 20, 2026 — **Fourth-quarter call has no AI remarks** The Q3 2025 (21 October) and Q4 2025 (20 January) earnings calls carry no AI remark in the transcripts. ([The Motley Fool (earnings call transcript)](https://www.fool.com/earnings/call-transcripts/2026/04/20/bok-financial-bokf-q3-2025-earnings-transcript/), [Investing.com](https://investing.com/news/transcripts/earnings-call-transcript-bok-financial-q4-2025-earnings-beat-expectations-93CH-4456059))
- Oct 20, 2025 — **Pudota at Gartner: cloud is foundational for AI** Speaking at the Gartner IT Symposium/Xpo, the chief data officer says cloud spend management is 'pretty high' on her agenda because AI spend 'is going to be exponentially higher if we don't manage it well'. ([CIO Dive](https://ciodive.com/news/ai-drives-cloud-spend-focus/803279))
- Jul 15, 2025 — **CISO on AI-enabled B2B payment fraud** After the TEXPO conference, Paul Tucker says criminals use machine learning to mimic legitimate users and that 'we're implementing AI into our systems to better protect them'; the bank advises AI-based detection, MFA, velocity controls and staff training. ([BOK Financial](https://www.bokfinancial.com/insights/articles/businesses-brace-for-fraudulent-payments))
- Feb 19, 2025 — **2024 10-K: AI 'selectively' deployed** The risk factor says BOK continues to evaluate and selectively deploy AI, machine learning and generative AI, and flags flawed or biased data and evolving AI law, including at third-party providers. ([BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535725000013/bokf-20241231.htm))
- Mar 21, 2024 — **Energy data warehouse profiled** Three-year effort centralised evaluations on 200,000-plus wells for risk and pricing analysis. ([BOK Financial (The Statement)](https://www.bokfinancial.com/about-us/newsroom/articles/community_from-wildcatting-to-data-mapping))
- Feb 21, 2024 — **'AI a double-edged sword' on fraud** Fraud team ties rising phishing losses to tools like ChatGPT and warns of AI-generated imagery. ([BOK Financial (The Statement)](https://www.bokfinancial.com/insights/articles/ai-a-double-edged-sword))
- Jan 30, 2024 — **Mastercard becomes exclusive card network** Expanded agreement makes Mastercard the exclusive payments network across BOK debit and commercial portfolios and extends its TransFund processing relationship; BOK cites Mastercard cyber and intelligence solutions, digital identity and tokenization. ([Mastercard](https://www.mastercard.com/global/en/news-and-trends/press/2024/January/mastercard-and-bok-financial-corporation-announce-expanded-payments-agreement.html))

## Where AI runs

| Use case | What | Status | Detail | Sources |
| --- | --- | --- | --- | --- |
| [AI governance (general)](https://www.bankingnewsai.com/ai-regulation/by-use-case#governance-general) | Data-first model for responsible AI scaling | Rolling out | Enterprise data treated as a shared asset under the chief data and analytics officer. | [American Banker](https://digital-banking.americanbanker.com/profile/shanthi-pudota) |
| [Credit scoring & underwriting](https://www.bankingnewsai.com/ai-regulation/by-use-case#credit-underwriting) | Energy portfolio data warehouse | In production | Historical and forecast data on 200,000-plus wells for production, pricing and expense risk. | [BOK Financial (The Statement)](https://www.bokfinancial.com/about-us/newsroom/articles/community_from-wildcatting-to-data-mapping) |
| [Model risk management](https://www.bankingnewsai.com/ai-regulation/by-use-case#model-risk) | Per-initiative AI governance review (10-K risk factor) | In production | Each AI initiative is assessed for data quality, bias, regulatory compliance and ethical considerations; the board is updated periodically on the governance structure but does not approve individual capabilities. The same risks are flagged for third-party providers building AI into their services. | [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000013/bokf-20251231.htm) |
| [Third-party & vendor AI](https://www.bankingnewsai.com/ai-regulation/by-use-case#third-party-vendors) | Vanilla AI trust-document review (Advisor Trust Services) | In production | Vendor-reported: custom prompts run BOK's own trust and synoptic review questions, cite the article and section behind each answer, and save roughly four hours on average per initial trust review; a human stays in the loop. | [Vanilla (vendor case study)](https://justvanilla.com/customer-stories/how-bok-financial-uses-vanilla-to-review-trusts-faster) |
| [Fraud detection](https://www.bankingnewsai.com/ai-regulation/by-use-case#fraud) | AI-enabled fraud awareness and controls | In production | Client guidance on generative-AI phishing, deepfakes and ACH/wire social engineering. | [BOK Financial (The Statement)](https://www.bokfinancial.com/insights/articles/ai-a-double-edged-sword), [BOK Financial (The Statement)](https://www.bokfinancial.com/insights/articles/human-behavior-as-a-layer-of-defense-in-helping-prevent-ach-and-wire-fraud), [BOK Financial](https://bokfinancial.com/Insights/articles/business-fraud-has-changed-so-have-the-warning-signs) |
| [Fraud detection](https://www.bankingnewsai.com/ai-regulation/by-use-case#fraud) | AI in BOK's own fraud defences (CISO statement) | Rolling out | Paul Tucker said in July 2025 that BOK is implementing AI in its systems to protect them while attackers use the same tools, and a treasury officer said in August 2026 that AI-powered tools help detect anomalies. No tool, vendor or result is named. | [BOK Financial](https://www.bokfinancial.com/insights/articles/businesses-brace-for-fraudulent-payments), [BOK Financial](https://bokfinancial.com/Insights/articles/How-to-protect-your-business-from-AI-driven-fraud-and-payment-scams) |

## Disclosed numbers

| Measure | Value | As of | Sources |
| --- | --- | --- | --- |
| First-quarter 2026 net income | $155.8 million | Apr 20, 2026 | [BOK Financial](https://investor.bokf.com/Q1-2026-Earnings-Full-Release-PDF) |
| Operating expense, Q1 2026 | $354.2 million (down $6.9 million) | Apr 20, 2026 | [BOK Financial](https://investor.bokf.com/Q1-2026-Earnings-Full-Release-PDF) |
| Oil and gas wells in the energy data warehouse | > 200,000 | Mar 21, 2024 | [BOK Financial (The Statement)](https://www.bokfinancial.com/about-us/newsroom/articles/community_from-wildcatting-to-data-mapping) |
| Time saved per initial trust review with Vanilla (vendor-reported) | ≈ 4 hours on average | Aug 13, 2026 | [Vanilla (vendor case study)](https://justvanilla.com/customer-stories/how-bok-financial-uses-vanilla-to-review-trusts-faster) |
| Customer reputation rank | 18th (79.7) | Aug 17, 2026 | [American Banker](https://www.americanbanker.com/news/top-banks-by-reputation-2026-customers) |
| Second-quarter 2026 net income | $176.5 million ($2.92 per share); $156.5 million adjusted for a Visa gain | Jul 20, 2026 | [BOK Financial](https://investor.bokf.com/Q2-2026-Earnings-Full-Release-PDF), [Yahoo Finance (MarketBeat)](https://finance.yahoo.com/markets/stocks/articles/bok-financial-q2-earnings-call-180327529.html) |
| Operating expense, Q2 2026 | $361.7 million (up $7.5 million); efficiency ratio 60.2%, 63.5% adjusted | Jul 20, 2026 | [BOK Financial](https://investor.bokf.com/Q2-2026-Earnings-Full-Release-PDF) |
| Period-end loans, 30 June 2026 | $27.1 billion (up $896 million in the quarter, 11.5% on the year) | Jul 20, 2026 | [BOK Financial](https://investor.bokf.com/Q2-2026-Earnings-Full-Release-PDF), [Yahoo Finance (MarketBeat)](https://finance.yahoo.com/markets/stocks/articles/bok-financial-q2-earnings-call-180327529.html) |
| Data processing and communications expense, 2025 | $198.5 million (up $11.3 million, 6%, on ongoing projects) | Feb 18, 2026 | [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000013/bokf-20251231.htm) |
| Professional fees and services, 2025 | $62.2 million (up 15%, additional projects) | Feb 18, 2026 | [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000013/bokf-20251231.htm) |
| Net income, full-year 2025 | $578.0 million ($9.17 per diluted share) | Feb 18, 2026 | [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000013/bokf-20251231.htm) |
| Earnings calls with an AI remark, Q3 2025 to Q2 2026 | 0 of 4 | Jul 21, 2026 | [The Motley Fool (earnings call transcript)](https://www.fool.com/earnings/call-transcripts/2026/04/20/bok-financial-bokf-q3-2025-earnings-transcript/), [Investing.com](https://investing.com/news/transcripts/earnings-call-transcript-bok-financial-q4-2025-earnings-beat-expectations-93CH-4456059), [The Motley Fool (earnings call transcript)](https://fool.com/earnings/call-transcripts/2026/04/21/bok-financial-bokf-q1-2026-earnings-transcript), [Investing.com](https://investing.com/news/transcripts/earnings-call-transcript-bok-financial-beats-q2-2026-eps-forecast-shares-slip-93CH-4803980) |

## Quotes

> "Building the foundations that enable analytics and AI to scale responsibly while remaining aligned with business priorities and enterprise decision-making." — Shanthi Pudota, SVP, Chief Data and Analytics Officer, Mar 24, 2026 ([American Banker](https://digital-banking.americanbanker.com/profile/shanthi-pudota))

> "AI is making scams faster, cheaper, and more convincing than ever." — Paul Tucker, Chief Information Security and Privacy Officer, Jan 26, 2026 ([BOK Financial](https://bokfinancial.com/Insights/articles/business-fraud-has-changed-so-have-the-warning-signs))

> "I think the setup for 2026 is probably as good as I can remember, both from a company-performance perspective and from an economic-backdrop perspective." — Stacy Kymes, President and CEO, Jan 27, 2026 ([American Banker](https://www.americanbanker.com/news/bok-counting-on-mortgage-finance-for-a-boost-in-2026))

> "While we're implementing AI into our systems to better protect them, scammers are using the same tools to defraud businesses, making it critical to understand what we're up against." — Paul Tucker, Chief Information Security and Privacy Officer, Jul 15, 2025 ([BOK Financial](https://www.bokfinancial.com/insights/articles/businesses-brace-for-fraudulent-payments))

> "With AI, [cloud spend] is going to be exponentially higher if we don't manage it well." — Shanthi Pudota, Chief Data Officer (later titled SVP, Chief Data and Analytics Officer), Oct 20, 2025 ([CIO Dive](https://ciodive.com/news/ai-drives-cloud-spend-focus/803279))

> "Lineage isn't documentation for documentation's sake. It's what enables trust, change management, regulatory confidence, and responsible AI." — Shanthi Pudota, SVP, Chief Data and Analytics Officer, Mar 30, 2026 ([Forbes](https://forbes.com/sites/pamkaur/2026/03/30/the-women-behind-fintechs-most-important-infrastructure-decisions))

> "You can't have an AI trust officer, and that's not what we're trying to do. We always have the human in the loop, and with the complexities of trust, we have to." — Randy Kimmel, National Trust Consultant, Advisor Trust Services, Aug 13, 2026 ([Vanilla (vendor case study)](https://justvanilla.com/customer-stories/how-bok-financial-uses-vanilla-to-review-trusts-faster))

## Who runs AI

- **Stacy Kymes** — President and CEO ([LinkedIn](https://www.linkedin.com/in/stacy-kymes-718460b6/)) ([American Banker](https://www.americanbanker.com/news/bok-counting-on-mortgage-finance-for-a-boost-in-2026), [CNBC](https://cnbc.com/video/2025/10/22/kymes-credit-is-still-very-benign-despite-recent-headlines.html))
- **Shanthi Pudota** — SVP, Chief Data and Analytics Officer (enterprise data and AI strategy) ([LinkedIn](https://www.linkedin.com/in/shanthipudota/)) ([American Banker](https://digital-banking.americanbanker.com/profile/shanthi-pudota))
- **Paul Tucker** — Chief Information Security and Privacy Officer ([BOK Financial](https://bokfinancial.com/Insights/articles/business-fraud-has-changed-so-have-the-warning-signs), [BOK Financial (The Statement)](https://www.bokfinancial.com/insights/articles/ai-a-double-edged-sword))
- **Derek Martin** — EVP and Chief Information Officer (since 2022; leads enterprise operations and information technology) ([LinkedIn](https://www.linkedin.com/in/derek-martin-71460312/)) ([BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000023/bokf-20260318.htm))
- **Mindy Mahaney** — EVP and Chief Risk Officer (enterprise-wide risk management, information security and compliance; the CISO reports to her) ([BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000023/bokf-20260318.htm), [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000013/bokf-20251231.htm))
- **Randy Kimmel** — Vice President and National Trust Consultant, Advisor Trust Services (owner of the Vanilla trust-review deployment) ([Vanilla (vendor case study)](https://justvanilla.com/customer-stories/how-bok-financial-uses-vanilla-to-review-trusts-faster), [Vanilla (vendor webinar page)](https://justvanilla.com/webinars/how-trust-companies-can-use-ai-to-serve-more-clients))
- **Scott Grauer** — EVP, Wealth Management Executive and CEO of BOK Financial Securities (chairs Cavanal Hill Investment Management and BOK Financial Private Wealth; no AI remit disclosed) ([BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000023/bokf-20260318.htm))
- **David Stratton** — EVP, Regional Banking Executive (responsible for the treasury services division, which sells the payment-fraud controls BOK promotes) ([BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000023/bokf-20260318.htm), [BOK Financial](https://bokfinancial.com/Insights/articles/How-to-protect-your-business-from-AI-driven-fraud-and-payment-scams))
- **Joseph Rangel** — Treasury Management Officer, Houston (teaches clients to recognise voice cloning and deepfake payment fraud) ([BOK Financial](https://bokfinancial.com/Insights/articles/How-to-protect-your-business-from-AI-driven-fraud-and-payment-scams))

## Open AI roles

Data as of Oct 13, 2026 (2026-10-13) · read from the bank's own careers site, re-checked weekly.

3 open AI-related postings on [the careers site](https://jobs.bokf.com/) as of Oct 13, 2026. A snapshot of current openings, not a source: postings close.

- [Technical Analyst III - Microsoft 365 Collaboration & Automation](https://jobs.bokf.com/job/Tulsa-Technical-Analyst-III-Microsoft-365-Collaboration-&-Automation-OK-74101/1410287500) — Tulsa, OK
- [Tech Lead - Sr. Software Engineer](https://jobs.bokf.com/job/Tulsa-Tech-Lead-Sr_-Software-Engineer-OK-74101/1414357700) — Tulsa, OK
- [Director, Enterprise Data Architecture](https://jobs.bokf.com/job/Tulsa-Director%2C-Enterprise-Data-Architecture-OK-74101/1432079500) — Tulsa, OK (+2 more)

## Which AI vendors and fintechs does BOK Financial work with?

| Company | What BOK Financial uses it for | Status | Category |
| --- | --- | --- | --- |
| [Vanilla](https://www.bankingnewsai.com/vendors/vanilla) | AI trust-document review for BOK Financial's Advisor Trust Services team, using custom prompts for its synoptic and trust reviews; the team reports saving about four hours on an initial review (Vanilla case study). | In production | [Document AI](https://www.bankingnewsai.com/ai-tools/document-ai) |

Each vendor and fintech page cites the source for the relationship. [AI tools for banks](https://www.bankingnewsai.com/ai-tools) · [fintech and neobank AI dossiers](https://www.bankingnewsai.com/fintech).

## Regulators it answers to

- [OCC](https://www.bankingnewsai.com/ai-regulation/occ) — BOKF, N.A. is a national bank; any AI models in credit, fraud or operations fall under the OCC's model-risk and gen-AI supervisory expectations. See [OCC Bulletin 2026-13](https://www.bankingnewsai.com/ai-regulation/documents/occ-bulletin-2026-13), [OCC Semiannual Risk Perspective, Spring 2026](https://www.bankingnewsai.com/ai-regulation/documents/occ-semiannual-risk-perspective-spring-2026).
- [Federal Reserve](https://www.bankingnewsai.com/ai-regulation/federal-reserve) — Holding-company supervision of model risk and third-party AI vendors. See [SR 11-7](https://www.bankingnewsai.com/ai-regulation/documents/fed-sr-11-7), [SR 23-4](https://www.bankingnewsai.com/ai-regulation/documents/fed-sr-23-4).
- [CFPB](https://www.bankingnewsai.com/ai-regulation/cfpb) — Consumer and mortgage lending bring ECOA adverse-action and UDAAP duties to any AI in decisioning. See [ECOA / Regulation B adverse action (15 U.S.C. 1691(d); 12 CFR 1002.9)](https://www.bankingnewsai.com/ai-regulation/documents/cfpb-ecoa-regulation-b-adverse-action).

## What the record suggests

### The data-first hire is the signal

Appointing a chief data and analytics officer with an explicit AI remit is what precedes disclosure at peers; expect use-case announcements to follow.

### Fraud content is a governance asset

BOK's own writing on AI-enabled phishing and ACH fraud documents that it understands the threat; the next step is disclosing the detection tools it runs.

### Energy data is a moat

A curated warehouse on 200,000-plus wells is exactly the proprietary dataset AI underwriting needs; it is a differentiated place to build.

### Thin record, not no record

Investors and examiners will read silence as caution; publishing AI governance principles would cost little and match the responsible-scaling framing.

## FAQ

### Who leads AI at BOK Financial?

Shanthi Pudota, senior vice-president and chief data and analytics officer, leads BOK Financial's enterprise data and AI strategy. She joined from roles at Expedia Group, Discover Financial Services and Fannie Mae and is moving the bank to a data-first model designed to let analytics and AI scale responsibly. Chief Information Officer Derek Martin runs enterprise operations and IT; Chief Risk Officer Mindy Mahaney owns information security, to whom CISO Paul Tucker reports; Randy Kimmel runs the Vanilla trust-review deployment. There is no chief AI officer.

### Has BOK Financial announced AI products?

No. As of September 2026 BOK Financial has not disclosed customer-facing AI products, AI spending or use-case counts. The one internal deployment on record comes from a vendor case study: Vanilla says BOK's Advisor Trust Services team uses its AI to review trust documents, saving roughly four hours per initial review. Its public AI content focuses on fraud awareness and healthcare industry research published on its editorial site, The Statement (now on bokfinancial.com/insights).

### Does BOK Financial use AI against fraud?

It says so but gives no detail. In July 2025 Chief Information Security and Privacy Officer Paul Tucker said that while BOK is implementing AI in its systems to protect them, scammers use the same tools. In August 2026 treasury management officer Joseph Rangel said AI-powered tools can identify anomalies and recognise patterns humans miss. The bank names no fraud vendor, model or loss figure, and its client guidance stresses dual approvals, Positive Pay and call-back verification over technology alone.

### How does BOK Financial govern AI?

The 2025 10-K says the board receives periodic updates on AI governance and risk management but does not approve individual AI capabilities; each initiative goes through an internal review of data quality, bias, regulatory compliance and ethics. BOK also wrote its own AI governance policy during a security review of nearly a year before adopting Vanilla. The CISO reports to Chief Risk Officer Mindy Mahaney and briefs the board Risk Committee quarterly.

### What AI partners and patents does BOK Financial have?

Named technology relationships are Vanilla (AI trust-document review) and Mastercard (exclusive card network since January 2024). No Microsoft, AWS, OpenAI, Anthropic or Google Cloud AI agreement, GPU purchase or AI capital figure is public. Searches of Google Patents under BOKF, N.A., BOK Financial and Bank of Oklahoma did not identify any AI patent or published application assigned to the bank.

## Sources (29)

1. Shanthi Pudota, SVP, Chief Data and Analytics Officer, BOK Financial (Digital Banking speaker profile) — American Banker, Mar 24, 2026. https://digital-banking.americanbanker.com/profile/shanthi-pudota
2. BOK counting on mortgage finance for a boost in 2026 — American Banker, Jan 27, 2026. https://www.americanbanker.com/news/bok-counting-on-mortgage-finance-for-a-boost-in-2026
3. Top Banks by Reputation 2026: Customers — American Banker, Aug 17, 2026. https://www.americanbanker.com/news/top-banks-by-reputation-2026-customers
4. BOK Financial Corporation reports quarterly earnings of $156 million in the first quarter — BOK Financial, Apr 20, 2026. https://investor.bokf.com/Q1-2026-Earnings-Full-Release-PDF
5. Kymes: Credit is still very benign despite recent headlines — CNBC, Oct 22, 2025. https://cnbc.com/video/2025/10/22/kymes-credit-is-still-very-benign-despite-recent-headlines.html
6. AI a double-edged sword — BOK Financial (The Statement), Feb 21, 2024. https://www.bokfinancial.com/insights/articles/ai-a-double-edged-sword
7. From wildcatting to data mapping — BOK Financial (The Statement), Mar 21, 2024. https://www.bokfinancial.com/about-us/newsroom/articles/community_from-wildcatting-to-data-mapping
8. How to help mitigate the risks of ACH and wire fraud — BOK Financial (The Statement), Mar 6, 2026. https://www.bokfinancial.com/insights/articles/human-behavior-as-a-layer-of-defense-in-helping-prevent-ach-and-wire-fraud
9. BOK Financial Corporation Annual Report on Form 10-K for the fiscal year ended December 31, 2025 — BOK Financial (SEC filings), Feb 18, 2026. https://www.sec.gov/Archives/edgar/data/875357/000087535726000013/bokf-20251231.htm
10. BOK Financial Corporation Annual Report on Form 10-K for the fiscal year ended December 31, 2024 — BOK Financial (SEC filings), Feb 19, 2025. https://www.sec.gov/Archives/edgar/data/875357/000087535725000013/bokf-20241231.htm
11. BOK Financial Corporation 2026 Proxy Statement (DEF 14A): executive officers — BOK Financial (SEC filings), Mar 19, 2026. https://www.sec.gov/Archives/edgar/data/875357/000087535726000023/bokf-20260318.htm
12. How BOK Financial Streamlines Trust Reviews with Vanilla — Vanilla (vendor case study), Aug 13, 2026. https://justvanilla.com/customer-stories/how-bok-financial-uses-vanilla-to-review-trusts-faster
13. How to protect your business from AI-enabled fraud — BOK Financial, Jan 26, 2026. https://bokfinancial.com/Insights/articles/business-fraud-has-changed-so-have-the-warning-signs
14. Healthcare looks to AI to alleviate burnout, labor shortages — BOK Financial (The Statement), Mar 30, 2026. https://www.bokfinancial.com/insights/articles/ai-helps-healthcare-tackle-burnout-and-labor-shortages
15. Businesses brace for fraudulent payments — BOK Financial, Jul 15, 2025. https://www.bokfinancial.com/insights/articles/businesses-brace-for-fraudulent-payments
16. AI shapes cloud spend amid adoption efforts — CIO Dive, Oct 21, 2025. https://ciodive.com/news/ai-drives-cloud-spend-focus/803279
17. Mastercard and BOK Financial Corporation announce expanded payments agreement — Mastercard, Jan 30, 2024. https://www.mastercard.com/global/en/news-and-trends/press/2024/January/mastercard-and-bok-financial-corporation-announce-expanded-payments-agreement.html
18. BOK Financial (BOKF) Q3 2025 earnings call transcript — The Motley Fool (earnings call transcript), Oct 21, 2025. https://www.fool.com/earnings/call-transcripts/2026/04/20/bok-financial-bokf-q3-2025-earnings-transcript/
19. Earnings call transcript: BOK Financial Q4 2025 earnings beat expectations — Investing.com, Jan 20, 2026. https://investing.com/news/transcripts/earnings-call-transcript-bok-financial-q4-2025-earnings-beat-expectations-93CH-4456059
20. The Women Behind Fintech's Most Important Infrastructure Decisions — Forbes, Mar 30, 2026. https://forbes.com/sites/pamkaur/2026/03/30/the-women-behind-fintechs-most-important-infrastructure-decisions
21. BOK Financial (BOKF) Q1 2026 earnings call transcript — The Motley Fool (earnings call transcript), Apr 21, 2026. https://fool.com/earnings/call-transcripts/2026/04/21/bok-financial-bokf-q1-2026-earnings-transcript
22. BOK Financial Corporation Quarterly Report on Form 10-Q for the quarter ended March 31, 2026 — BOK Financial (SEC filings), May 6, 2026. https://www.sec.gov/Archives/edgar/data/875357/000087535726000034/bokf-20260331.htm
23. How Trust Companies Can Use AI to Serve More Clients (webinar with BOK Financial) — Vanilla (vendor webinar page), Jun 23, 2026. https://justvanilla.com/webinars/how-trust-companies-can-use-ai-to-serve-more-clients
24. Railroads and the internet may offer insight into the path ahead with AI — BOK Financial, Jul 8, 2026. https://bokfinancial.com/Insights/articles/railroads-and-the-internet-may-offer-insight-into-the-path-ahead-with-ai
25. BOK Financial Corporation reports quarterly earnings of $177 million in the second quarter — BOK Financial, Jul 20, 2026. https://investor.bokf.com/Q2-2026-Earnings-Full-Release-PDF
26. BOK Financial Q2 Earnings Call Highlights — Yahoo Finance (MarketBeat), Jul 21, 2026. https://finance.yahoo.com/markets/stocks/articles/bok-financial-q2-earnings-call-180327529.html
27. Earnings call transcript: BOK Financial beats Q2 2026 EPS forecast, shares slip — Investing.com, Jul 21, 2026. https://investing.com/news/transcripts/earnings-call-transcript-bok-financial-beats-q2-2026-eps-forecast-shares-slip-93CH-4803980
28. BOK Financial Corporation Quarterly Report on Form 10-Q for the quarter ended June 30, 2026 — BOK Financial (SEC filings), Aug 4, 2026. https://www.sec.gov/Archives/edgar/data/875357/000087535726000048/bokf-20260630.htm
29. How to protect your business from AI-driven fraud: Q&A — BOK Financial, Aug 11, 2026. https://bokfinancial.com/Insights/articles/How-to-protect-your-business-from-AI-driven-fraud-and-payment-scams

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