EXHIBIT 21

LIST OF SUBSIDIARIES

ZIONS BANCORPORATION

AT DECEMBER 31, 2008

SUBSIDIARY	STATE OR JURISDICTION OF INCORPORATION/ORGANIZATION
Zions First National Bank	Federally chartered doing business in Utah and Idaho
California Bank & Trust	California
Amegy Corporation	Texas
National Bank of Arizona	Federally chartered doing business in Arizona
Nevada State Bank	Nevada
Vectra Bank Colorado	Federally chartered doing business in Colorado and New Mexico
The Commerce Bank of Washington	Federally chartered doing business in Washington
The Commerce Bank of Oregon	Oregon
Cash Access, Inc.	Utah
Great Western Financial Corporation	Utah
MP Technology, Inc.	Utah
NetDeposit, LLC	Nevada
Stockmen’s (AZ) Statutory Trust II (not consolidated)	Connecticut
Stockmen’s (AZ) Statutory Trust III (not consolidated)	Connecticut
Welman Holdings, Inc.	Utah
Zions Capital Trust B (not consolidated)	Delaware
Zions Insurance Agency, Inc.	Utah
Zions Management Services Company	Utah
Zions Municipal Funding, Inc.	Utah