“BOKF was in a crucial gatekeeper position to stand up for bondholders and notify them about material problems with the bonds, but instead turned a blind eye and chose to protect Brogdon and the fees it collected from his deals,” said Lara Shalov Mehraban, Associate Regional Director of the SEC’s New York Regional Office. 

Without admitting or denying the SEC’s findings, BOKF agreed to pay disgorgement of $984,200.73 of the fees the bank collected from its work with Brogdon.  The bank also agreed to pay interest totaling $83,520.63 and a penalty of $600,000.  BOKF promptly terminated Neilson following an internal investigation and reported its misconduct to the SEC.