Item 7.01 Regulation FD Disclosure

On September 15, 2009, holders of the September 15, 2015 series of Zions Bancorporation subordinated notes (CUSIP: 989701 AJ6) that are convertible into the company's Series A or Series C preferred stock converted $0.4 million principal amount of the notes into 17,320 depositary shares each representing a 1/40th interest in a share of Series C preferred stock (representing 433 shares of Series C preferred stock in the aggregate). No note holders elected to convert into Series A preferred stock. The converted notes constitute approximately 0.04% of the original combined $1.17 billion principal amount of all three series of convertible subordinated notes.

The cumulative amount of subordinated notes converted during the third quarter of 2009 equaled $27.8 million, all of which converted into the company's Series C preferred stock, equaling 1,110,280 depositary shares each representing a 1/40th interest in a share of Series C preferred stock (representing 27,757 shares of Series C preferred stock in the aggregate). The third quarter converted notes constitute approximately 2.37% of the original $1.17 billion principal amount of the convertible subordinated notes.

The conversion dates for the convertible subordinated notes occur only on semi-annual interest payment dates. The next such dates are:

· November 15, 2009 for convertible 5.65% notes due on May 15, 2014;

· November 16, 2009 for convertible 5.50% notes due on November 16, 2015.

· March 15, 2010 for convertible 6.00% notes due on September 15, 2015.