# BOK Financial Corporation: AI strategy and technology vision

Source: https://www.bankingnewsai.com/banks/bok-financial/ai-strategy
Last updated: Oct 16, 2026

*Part of the [BOK Financial Corporation AI strategy profile](https://www.bankingnewsai.com/banks/bok-financial).*

## What is BOK Financial's AI strategy?

BOK Financial has not published an AI strategy, and its filings describe a cautious one. The 10-K says the company continues 'to evaluate and selectively deploy' AI, machine learning and generative AI; since the 10-K filed on February 18, 2026 it adds that the board gets periodic updates on AI governance but 'does not approve individual AI capabilities', and that each initiative goes through an internal review of data quality, bias, regulatory compliance and ethics. The organising idea is data: Shanthi Pudota, senior vice-president and chief data and analytics officer, 'leads BOK Financial's enterprise data and AI strategy' and a shift to a 'data-first model' so that analytics and AI can 'scale responsibly' (March 2026), and she warned in October 2025 that AI-driven cloud spend could be 'exponentially higher' without management. The only deployment on record is vendor-reported: Vanilla's AI reviews trust documents for the Advisor Trust Services team, saving about four hours per initial review (August 2026). CEO Stacy Kymes's 2025 shareholder letter does not mention AI, and none of the four earnings calls from October 2025 to July 2026 carried an AI remark. No AI budget is disclosed; data processing and communications expense was $198.5 million in 2025. ([BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535725000013/bokf-20241231.htm), [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000013/bokf-20251231.htm), [American Banker](https://digital-banking.americanbanker.com/profile/shanthi-pudota), [CIO Dive](https://ciodive.com/news/ai-drives-cloud-spend-focus/803279), [Vanilla (vendor case study)](https://justvanilla.com/customer-stories/how-bok-financial-uses-vanilla-to-review-trusts-faster), [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000024/a2025bokfannualreport-fina.pdf), [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))

## What have BOK Financial and its executives said about AI, and when?

In date order. Words in quotation marks are as published by the cited source.

| Date | Who | What was said | Where | Sources |
| --- | --- | --- | --- | --- |
| February 19, 2025 | The company | Continues 'to evaluate and selectively deploy' AI, machine learning and generative AI; flags flawed or biased data and evolving AI law, including at third-party providers | 2024 10-K | [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535725000013/bokf-20241231.htm) |
| July 15, 2025 | Paul Tucker, chief information security and privacy officer | 'While we're implementing AI into our systems to better protect them, scammers are using the same tools' | BOK Financial insights | [BOK Financial](https://www.bokfinancial.com/insights/articles/businesses-brace-for-fraudulent-payments) |
| October 20, 2025 | Shanthi Pudota, then chief data officer | Cloud spend management is high on her agenda because with AI it 'is going to be exponentially higher if we don't manage it well' | Gartner IT Symposium, reported by CIO Dive | [CIO Dive](https://ciodive.com/news/ai-drives-cloud-spend-focus/803279) |
| December 22, 2025 | Brian Henderson, chief investment officer | On the economy, not the bank: 'equally important is how AI can make businesses more efficient. That's what drives long-term competitiveness' | BOK Financial insights | [BOK Financial](https://bokfinancial.com/insights/articles/ai-infrastructure-may-drive-growth-for-decades) |
| February 18, 2026 | The company | The board receives periodic updates on AI governance and risk management but does not approve individual AI capabilities; each initiative has its own internal review | 2025 10-K | [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000013/bokf-20251231.htm) |
| March 19, 2026 | Stacy Kymes, CEO | Shareholder letter framed around 'strong, stable, growing', records in fee businesses and $1.5 billion of loan growth; AI is not mentioned | 2025 annual report | [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000024/a2025bokfannualreport-fina.pdf) |
| March 24-30, 2026 | Shanthi Pudota, SVP and chief data and analytics officer | Building foundations 'that enable analytics and AI to scale responsibly'; lineage 'enables trust, change management, regulatory confidence, and responsible AI' | American Banker speaker profile; Forbes | [American Banker](https://digital-banking.americanbanker.com/profile/shanthi-pudota), [Forbes](https://forbes.com/sites/pamkaur/2026/03/30/the-women-behind-fintechs-most-important-infrastructure-decisions) |
| August 13, 2026 | Randy Kimmel, national trust consultant | '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' | Vanilla case study | [Vanilla (vendor case study)](https://justvanilla.com/customer-stories/how-bok-financial-uses-vanilla-to-review-trusts-faster) |

## What does the public record show about AI at BOK Financial?

Each line is the most recent evidence; gaps are stated as gaps.

| Item | What the record shows | As of | Sources |
| --- | --- | --- | --- |
| AI leadership | Chief data and analytics officer owns enterprise data and AI strategy; no chief AI officer | March 2026 | [American Banker](https://digital-banking.americanbanker.com/profile/shanthi-pudota) |
| Deployments | One, vendor-reported: Vanilla trust-document review, about four hours saved per initial review; BOK wrote its own AI governance policy during a near year-long security review | August 13, 2026 | [Vanilla (vendor case study)](https://justvanilla.com/customer-stories/how-bok-financial-uses-vanilla-to-review-trusts-faster) |
| Spend | No AI line; data processing and communications $198.5 million in 2025, up 6% on ongoing projects; professional fees $62.2 million, up 15% | 2025 | [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000013/bokf-20251231.htm) |
| Earnings calls | No AI remark on any of four calls, Q3 2025 to Q2 2026 | July 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) |
| Quarterly filings | AI appears only in the glossary and in the macro forecast of the Q1 and Q2 2026 10-Qs | August 4, 2026 | [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000034/bokf-20260331.htm), [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000048/bokf-20260630.htm) |
| Vendor concentration | Outsources a significant portion of information systems, data management and transaction processing and is 'heavily reliant on a single vendor' for many of these functions | March 2026 | [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000024/a2025bokfannualreport-fina.pdf) |
| Talent | Warns that demand for technology professionals is growing as the industry moves toward digital delivery, data-driven decisioning, automation and cybersecurity | March 2026 | [BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000024/a2025bokfannualreport-fina.pdf) |

## What has BOK Financial not disclosed about AI?

BOK has disclosed no AI use-case count, no AI spending figure, no productivity claim and no customer-facing AI product. The 10-K names the governance process but not the systems that have been through it, and the one named deployment is described by the vendor, Vanilla, rather than by the bank. ([BOK Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/875357/000087535726000013/bokf-20251231.htm), [Vanilla (vendor case study)](https://justvanilla.com/customer-stories/how-bok-financial-uses-vanilla-to-review-trusts-faster))

Most of BOK's public writing about AI is about other people's use of it: fraud warnings to clients and economic commentary from its investment strategists, who expect AI capital spending to support growth. That commentary is market analysis, not a description of the bank's own operations. ([BOK Financial](https://bokfinancial.com/Insights/articles/business-fraud-has-changed-so-have-the-warning-signs), [BOK Financial (published in the Denver Business Journal)](https://bizjournals.com/denver/news/2025/10/16/prepare-businesses-fraudulent-payments.html), [BOK Financial](https://bokfinancial.com/insights/articles/ai-infrastructure-may-drive-growth-for-decades), [BOK Financial](https://bokfinancial.com/Insights/articles/railroads-and-the-internet-may-offer-insight-into-the-path-ahead-with-ai))

## What does the BOK Financial profile record on this topic?

| Date | Move | Detail | Sources |
| --- | --- | --- | --- |
| 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) |
| 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) |
| 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) |
| 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 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) |
| 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 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) |
| 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) |

## Common questions

### Does BOK Financial have an AI strategy?

Not a published one. Its 10-K says it continues to evaluate and selectively deploy AI, machine learning and generative AI, with each initiative reviewed for data quality, bias, regulatory compliance and ethics. Chief data and analytics officer Shanthi Pudota leads enterprise data and AI strategy and describes a data-first model meant to let analytics and AI scale responsibly. CEO Stacy Kymes's 2025 shareholder letter does not mention AI.

### Who leads AI at BOK Financial?

Shanthi Pudota, senior vice-president and chief data and analytics officer, who joined from Expedia Group, Discover Financial Services and Fannie Mae, leads enterprise data and AI strategy. Chief information officer Derek Martin runs enterprise operations and IT, and chief risk officer Mindy Mahaney oversees information security. BOK has no chief AI officer.

### How does BOK Financial's board oversee AI?

According to the 2025 10-K filed on February 18, 2026, the board receives periodic updates on the governance structure and risk-management approach for AI but does not approve individual AI capabilities. Each AI initiative goes through an internal governance process assessing data quality, bias, regulatory compliance and ethical considerations.

### Has BOK Financial talked about AI on earnings calls?

No. The transcripts of the four calls from October 2025 (Q3 2025) to July 2026 (Q2 2026) carry no AI remark, and the first- and second-quarter 2026 10-Qs mention AI only in the glossary and in the economic forecast. BOK's public statements on AI come mainly from its data chief, its security chief and its own published articles.
## Deeper on BOK Financial

- [How does BOK Financial use AI against fraud and in credit?](https://www.bankingnewsai.com/banks/bok-financial/fraud-and-credit-ai)


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