Cavanal Hill Investment Management, Inc..

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BOKF, NA
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SECURITIES AND EXCHANGE COMMISSION (COMMISSION)
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
PAY DISGORGEMENT OF $984,200.73, PREJUDGMENT INTEREST OF $83,520.63 AND A CIVIL MONEY PENALTY OF $600,000.00 TO THE COMMISSION.
IMPLEMENT ADDITIONAL POLICIES AND PROCEDURES REGARDING THE ACCEPTANCE OF NEW UNRATED CONDUIT MUNICIPAL FINANCING BUSINESS;
ENHANCE THE TICKLER SYSTEM CURRENTLY USED; IMPLEMENT AUTOMATED REPORTING; ENHANCE SUPERVISORY REVIEW OF THIS BUSINESS;
PROVIDE TRAINING; CERTIFY IN WRITING, COMPLIANCE WITH THESE UNDERTAKINGS.
3.
Date Initiated (MM/DD/YYYY): 
09/09/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-17533
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Municipal
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON SEPTEMBER 9, 2016, BOKF, NA ("BOKF"), AN AFFILIATE OF CAVANAL HILL INVESTMENT MANAGEMENT, INC. ENTERED INTO A CONSENT DECREE (THE
"CONSENT DECREE") WITH THE SECURITIES AND EXCHANGE COMMISSION (THE "SEC"). BOKF NEITHER ADMITTED NOR DENIED THE FINDINGS OF THE
CONSENT DECREE. THIS MATTER RELATES TO BOKF'S RELATIONSHIP WITH CHRISTOPHER BROGDON WHO HAS BEEN ACCUSED BY THE SEC OF
VIOLATING ANTIFRAUD PROVISIONS OF THE FEDERAL SECURITIES LAWS. BOKF SERVED AS INDENTURE TRUSTEE AND DISSEMINATION AGENCY FOR
SEVERAL CONDUIT MUNICIPAL BOND OFFERINGS FOR WHICH MR. BROGDON'S ENTITIES ACTED AS BORROWER SINCE 2000. THE CONSENT DECREE
STATES THAT BOKF, PRIMARILY THROUGH THE ACTIONS OF A FORMER BOKF EMPLOYEE, ALLOWED MR. BROGDON TO PERPETUATE HIS FRAUD BY
FAILING TO PERFORM DISCLOSURE AND NOTICE OBLIGATIONS BOKF OWED TO BONDHOLDERS. CAVANAL HILL INVESTMENT MANAGEMENT, INC. MAKES
THIS DISCLOSURE SOLELY BECAUSE CAVANAL HILL INVESTMENT MANAGEMENT, INC. IS A SUBSIDIARY OF BOKF, NA. NEITHER CAVANAL HILL
INVESTMENT MANAGEMENT, INC. NOR ANY MEMBER OF CAVANAL HILL INVESTMENT MANAGEMENT, INC. WAS NAMED OR IMPLICATED IN THE ABOVE
REFERENCED VIOLATION.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision & Order of Offer of Settlement

11. Resolution Date (MM/DD/YYYY):
09/09/2016
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 600,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PAY DISGORGEMENT OF $984,200.73, PREJUDGMENT INTEREST OF $83,520.63 AND A CIVIL MONEY PENALTY OF $600,000.00 TO THE
COMMISSION. IMPLEMENT ADDITIONAL POLICIES AND PROCEDURES REGARDING THE ACCEPTANCE OF NEW UNRATED CONDUIT MUNICIPAL
FINANCING BUSINESS; ENHANCE THE TICKLER SYSTEM CURRENTLY USED; IMPLEMENT AUTOMATED REPORTING; ENHANCE SUPERVISORY REVIEW
OF THIS BUSINESS; PROVIDE TRAINING; CERTIFY IN WRITING, COMPLIANCE WITH THESE UNDERTAKINGS.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
FINE, DISGORGEMENT AND INTEREST PAID IN FULL ON 9/14/2016.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON SEPTEMBER 9, 2016, BOKF, NA ("BOKF"), AN AFFILIATE OF CAVANAL HILL INVESTMENT MANAGEMENT, INC. ENTERED INTO A CONSENT DECREE (THE
"CONSENT DECREE") WITH THE SECURITIES AND EXCHANGE COMMISSION (THE "SEC"). BOKF NEITHER ADMITTED NOR DENIED THE FINDINGS OF THE
CONSENT DECREE. THIS MATTER RELATES TO BOKF'S RELATIONSHIP WITH CHRISTOPHER BROGDON WHO HAS BEEN ACCUSED BY THE SEC OF
VIOLATING ANTIFRAUD PROVISIONS OF THE FEDERAL SECURITIES LAWS. BOKF SERVED AS INDENTURE TRUSTEE AND DISSEMINATION AGENCY FOR
SEVERAL CONDUIT MUNICIPAL BOND OFFERINGS FOR WHICH MR. BROGDON'S ENTITIES ACTED AS BORROWER SINCE 2000. THE CONSENT DECREE
STATES THAT BOKF, PRIMARILY THROUGH THE ACTIONS OF A FORMER BOKF EMPLOYEE, ALLOWED MR. BROGDON TO PERPETUATE HIS FRAUD BY
FAILING TO PERFORM DISCLOSURE AND NOTICE OBLIGATIONS BOKF OWED TO BONDHOLDERS. CAVANAL HILL INVESTMENT MANAGEMENT, INC. MAKES
THIS DISCLOSURE SOLELY BECAUSE CAVANAL HILL INVESTMENT MANAGEMENT, INC. IS A SUBSIDIARY OF BOKF, NA. NEITHER CAVANAL HILL
INVESTMENT MANAGEMENT, INC. NOR ANY MEMBER OF CAVANAL HILL INVESTMENT MANAGEMENT, INC. WAS NAMED OR IMPLICATED IN THE ABOVE
REFERENCED VIOLATION.