EXHIBIT 99.4

                              ZIONS BANCORPORATION

                               OFFER TO EXCHANGE
ITS FIXED/FLOATING RATE SUBORDINATED NOTES DUE OCTOBER 15, 2011 WHICH HAVE BEEN
 REGISTERED UNDER THE SECURITIES ACT OF 1933 FOR ANY AND ALL OF ITS OUTSTANDING
          FIXED/FLOATING RATE SUBORDINATED NOTES DUE OCTOBER 15, 2011

       THE EXCHANGE OFFER AND WITHDRAWAL RIGHTS WILL EXPIRE AT 5:00 P.M.,
           NEW YORK CITY TIME, ON JANUARY   , 2002, UNLESS EXTENDED.

                                                               December   , 2001

To Our Clients:

    Enclosed for your consideration is a prospectus dated December   , 2001 (the
"prospectus") and the accompanying letter of transmittal (which together
constitute the "exchange offer") relating to the offer by Zions Bancorporation
to exchange up to $200,000,000 aggregate principal amount of its Fixed/ Floating
Rate Subordinated Notes due October 15, 2011 (the "new securities"), which have
been registered under the Securities Act of 1933, as amended (the "Securities
Act"), for a like principal amount of its outstanding Fixed/Floating Rate
Subordinated Notes due October 15, 2011 (the "old securities"). As set forth in
the prospectus, the terms of the new securities are identical in all material
respects to the old securities, except that the new securities have been
registered under the Securities Act and therefore will not be subject to certain
restrictions on their transfer and will not contain certain provisions providing
for an increase in the interest rate thereon under the circumstances set forth
in the exchange and registration rights agreement described in the prospectus.
Old securities may be tendered in a principal amount of $1,000 and integral
multiples of $1,000.

    We are forwarding the enclosed material to you as the beneficial owner of
old securities held by us for your account or benefit but not registered in your
name. Only we may tender old securities in the exchange offer as the registered
holder, if you so instruct us. Therefore, Zions Bancorporation urges beneficial
owners of old securities registered in the name of a broker, dealer, commercial
bank, trust company or other nominee to contact such holder promptly if they
wish to exchange old securities in the exchange offer.

    Accordingly, we request instructions as to whether you wish us to exchange
any or all old securities held by us for your account or benefit pursuant to the
terms and conditions set forth in the prospectus and letter of transmittal. We
urge you to read carefully the prospectus and letter of transmittal before
instructing us to exchange your old securities.

    You should forward instructions to us as promptly as possible in order to
permit us to exchange old securities on your behalf before the exchange offer
expires at 5:00 P.M., New York City time, on January   , 2002, unless extended.
A tender of old securities may be withdrawn at any time prior to the expiration
time, which means 5:00 P.M., New York City time, on January   , 2002 or the
latest time to which the exchange offer is extended.

    We call your attention to the following:

        1.  The exchange offer is for the exchange of $1,000 principal amount of
    new securities for each $1,000 principal amount of old securities.
    $200,000,000 aggregate principal amount of the old securities was
    outstanding as of December   , 2001.

        2.  THE EXCHANGE OFFER IS SUBJECT TO CERTAIN CONDITIONS. SEE "THE
    EXCHANGE OFFER--CONDITIONS TO THE EXCHANGE OFFER" IN THE PROSPECTUS.

        3.  Zions Bancorporation has agreed to pay certain of the expenses of
    the exchange offer. It will pay any transfer taxes incident to the transfer
    of old securities from the tendering holder to Zions Bancorporation, except
    as provided in the prospectus and the letter of transmittal. See "The
    Exchange Offer--Fees and Expenses" in the prospectus and instruction 10 of
    the letter of transmittal.

    Zions Bancorporation is not making the exchange offer to, nor will it accept
tenders from or on behalf of, holders of old securities residing in any
jurisdiction in which the making of the exchange offer or the acceptance of
tenders would not be in compliance with the laws of such jurisdiction.

    If you wish us to tender any or all of your old securities held by us for
your account or benefit, please so instruct us by completing, executing and
returning to us the attached instruction form. THE ACCOMPANYING LETTER OF
TRANSMITTAL IS FURNISHED TO YOU FOR INFORMATIONAL PURPOSES ONLY AND MAY NOT BE
USED BY YOU TO EXCHANGE OLD SECURITIES HELD BY US AND REGISTERED IN OUR NAME FOR
YOUR ACCOUNT OR BENEFIT.

                                  INSTRUCTIONS

    The undersigned acknowledge(s) receipt of your letter and the material
enclosed with and referred to in your letter relating to the exchange offer of
Zions Bancorporation.

    This will instruct you to tender for exchange the aggregate principal amount
of old securities indicated below (or, if no aggregate principal amount is
indicated below, all old securities) held by you for the account or benefit of
the undersigned, pursuant to the terms and conditions set forth in the
prospectus and the letter of transmittal.

   Aggregate principal amount of old securities to be tendered for exchange:*
                                $______________

*I (we) understand that if I (we) sign this instruction form without indicating
an aggregate principal amount of old securities in the space above, all old
securities held by you for my (our) account will be tendered for exchange.

                                             
Signature(s)

Name(s) (Please print)

Taxpayer Identification or
Social Security Number(s)

Capacity (full title), if signing in a
fiduciary or representative capacity

Telephone (Include area code)

Address (Include zip code)

Date