[Frederic Dorwart, Lawyers Letterhead]

                                January 31, 2008

By U.S. Mail and filed on EDGAR

Mr. Christian N. Windsor, Special Counsel
United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 4563
100 F Street NE
Washington, D.C. 20549

         Re:  BOK Financial Corporation
              Definitive 14A
              Filed March 21, 2007
              File No. 00-19341

Dear Mr. Windsor:

     The  purpose of this  letter is to respond to the  comments  raised in your
letter to BOK Financial  Corporation (the "Corporation")  dated January 9, 2008.
Thank you for your feedback. Your comments and our responses are provided below.
Corporation responses are in bold.

     The  Corporation  acknowledges  that (1) the Corporation is responsible for
the adequacy and accuracy of the disclosure in its filing; (2) staff comments or
changes to  disclosure  in  response  to staff  comments  do not  foreclose  the
Commission  from  taking any action  with  respect  to the  filing;  and (3) the
Corporation  may not  assert  staff  comments  as a  defense  in any  proceeding
initiated by the Commission or any person under the federal  securities  laws of
the United States.

Compensation Discussion and Analysis, page 16

1.   In your response to prior  comments 6 and 7, you indicate that you will not
     disclose  the  individual  Net Direct  Contribution  targets  for the prior
     fiscal year for each of the Named executive officers, because those targets
     are confidential. Please provide the staff with your analysis as to how you
     concluded  that  disclosure  of the targets in the  following  year's proxy
     statement would cause competitive harm to BOK Financial.

     BOK Financial has further  evaluated the competitive harm in disclosing the
Net Direct  Contribution  targets for those individuals who were Named executive
officers in 2007 and who will again be the Named executive  officers in the 2008
BOKF proxy  statement.  BOKF shall provide the following  disclosure in the 2008
proxy statement, updated with 2007 Net Direct Contribution target information:

     The Net Direct  Contribution  target for the three named executives  (other
than the CEO and CFO whose annual  incentive is based solely on EPS Growth),  is
100% of the planned Net Direct Contribution for such executive's respective area
of  responsibility.  For  2006,  the Net  Direct  Contribution  targets  were as
follows:

                   Mr. Bradshaw -   $162,638,161
                   Mr. Ellinor -    $176,509,920
                   Mr. Pickryl -    $182,893,792

     For 2006,  the named  executives  attained  their Net  Direct  Contribution
targets as follows:  Mr. Bradshaw attained 104.93%, Mr. Ellinor attained 103.46%
and Mr. Pickryl attained 105.99%.

     In the event there are, in future  years,  Named  executives  who have more
narrow  areas  of  responsibility   for  which  disclosure  of  the  Net  Direct
Contribution target could provide more competitive harm, we undertake to discuss
our concerns with the Commission in advance.

     If you have any questions regarding the foregoing responses or if we may be
of any further assistance, please do not hesitate to call me at (918) 583-9958.

                                       Very truly yours,

                                       /s/ Tamara R. Wagman

                                       Tamara R. Wagman,
                                       Assistant General Counsel



cc:  Stanley A. Lybarger,
     Chief Executive Officer
     BOK Financial Corporation