SEC v. BOKF, NA (2016)

Settled

Checked against the primary document on October 2, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

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In September 2016 the SEC settled charges against BOKF, NA, the indenture trustee on Christopher Brogdon's fraudulent senior-living bond offerings, for failing to act on red flags. It agreed to a cease-and-desist order, disgorgement of $984,200 and a $600,000 civil penalty.

The record

Structured fields for this action, as recorded in our case library.
Agency	SEC
Release number	3-17533
Date filed	2016-09-09
Date resolved	2016-09-09
Status	settled
Asset class	bonds
Criminal parallel	No
Bars imposed	registration bar
Defendants	BOKF, NA (individual)
Cited as charged or alleged	Exchange Act s.10(b) and Rule 10b-5 ; Securities Act s.17(a) (statutes and rules cited in the document; not a finding that they were violated)
Techniques

What was ordered

Civil penalty: $600k
Disgorgement: $984k
Prejudgment interest: —
Total relief: $1.6m
Alleged gain: —

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The order finds that BOKF, mainly through a former senior vice president, allowed Brogdon to continue the fraud while not performing its disclosure and notice duties, and that its staff concealed problems and red flags about the bond offerings. It finds violations of Section 17(a) of the Securities Act and Section 10(b) of the Exchange Act.

The sanctions are a cease-and-desist order, $984,200 of disgorgement and a $600,000 penalty; the record had the penalty but not the disgorgement.

No technique tag is applied. The word "Ponzi" appears once, in an email in which an employee reported that others had called the offerings Ponzi schemes; the trustee is not charged with running or paying into one.

Timeline

2016-09-09 Administrative proceeding instituted (cease-and-desist)

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

SEC order

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Record added September 10, 2026. submit a correction.