EXHIBIT 23.3

                          INDEPENDENT AUDITORS' REPORT


The Board of Directors and Shareholders
Zions Bancorporation:


We have audited the accompanying consolidated balance sheet of Zions
Bancorporation and subsidiaries as of December 31, 1999, and the related
consolidated statements of income, cash flows, and changes in shareholders'
equity and comprehensive income for each of the years in the two-year period
ended December 31, 1999. These consolidated financial statements are the
responsibility of the Company's management. Our responsibility is to express an
opinion on these consolidated financial statements based on our audits.

We conducted our audits in accordance with auditing standards generally accepted
in the United States of America. Those standards require that we plan and
perform the audits to obtain reasonable assurance about whether the financial
statements are free of material misstatement. An audit includes examining, on a
test basis, evidence supporting the amounts and disclosures in the financial
statements. An audit also includes assessing the accounting principles used and
significant estimates made by management, as well as evaluating the overall
financial statement presentation. We believe that our audits provide a
reasonable basis for our opinion.

In our opinion, the consolidated financial statements referred to above present
fairly, in all material respects, the financial position of Zions Bancorporation
and subsidiaries as of December 31, 1999, and the results of their operations
and their cash flows for each of the years in the two-year period ended December
31, 1999, in conformity with accounting principles generally accepted in the
United States of America.


                                         /s/KPMG LLP



Salt Lake City, Utah
February 7, 2000