ZIONS BANCORPORATION

October 3, 2012

Ms. Suzanne Hayes

Assistant Director

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

Re:    Zions Bancorporation

Form 10-K for Fiscal Year Ended December 31, 2011

Filed February 29, 2012

Definitive Proxy Statement on Schedule 14A

Filed April 12, 2012

Form 10-Q for Fiscal Quarter Ended June 30, 2012

Filed August 8, 2012

File No. 001-12307

Dear Ms. Hayes:

We have received your comment letter dated September 28, 2012 related to the filings referenced above.

As acknowledged today with Aslynn Hogue, we expect to provide our response to your comment letter no later than October 30, 2012.

/s/ Alexander J. Hume
Name:	Alexander J. Hume
Title:	Senior Vice President and Corporate Controller