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Via U.S. Mail and Facsimile to (816) 983-8080
                                                          February 22, 2007

  J. Daniel Stinnett, Esq. Vice President, Secretary and General Counsel Commerce Bancshares, Inc. 1000 Walnut Kansas City, Missouri 64141
RE:     Commerce Bancshares, Inc.
            Form S-4
Filed on February 6, 2007
            File Number 333-140475

Dear Mr. Stinnett:
I have reviewed your document and have the following comments.   I have
restricted my review to the description of the consideration to be received by
shareholders of South Tulsa Financial Cor poration and to the equivalent per share
information required by Item 3(f) of the form .  Where indicated, I th ink you should revise
your document in response to these comments.   If you disagree, I will consider your
explanation as to why my comment is inappl icable or a revision is unnecessary.  Please
be as detailed as necessary in your explanation.
The purpose of our review process is to assist you in your compliance with the
applicable disclosure requirements and to e nhance the overall disclosure in your filing.  I
look forward to working with you in these respects.  I welcome any questions you may have about my comments or a ny other aspect of my review.  Feel free to call me at the
telephone number listed at the end of this letter.

J. Daniel Stinnett, Esq., Vice Presi dent, Secretary and General Counsel
Commerce Bancshares, Inc.
Page 2

Comments pertaining to the prospectus

1. On the cover page, please explain in clear and concise plain English what
shareholders of South Tulsa will recei ve if the transaction is consummated.

2. During my screening of your document, I did not see the information required
by Item 3(f) of Form S-4.  Please incl ude that information in the prospectus.

      *   *   *   *   *
Closing Comments

As appropriate, please amend your filing and respond to these comments.  You
may wish to provide us with marked copies of the amendment to e xpedite our review by
showing deleted sections as strikethrough and added sections as underlining.  Please
furnish a cover letter with your amendment th at keys your responses to our comments
and provides any requested supplemental info rmation.  Detailed cover letters greatly
facilitate our review.  Please understand th at we may have additional comments after
reviewing your amendment and responses to our comments.

 We urge all persons who are responsible  for the accuracy and adequacy of the
disclosure in the filings reviewed by the sta ff to be certain that they have provided all
information investors require for an info rmed decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy  of the disclosures they have made.
  Notwithstanding our comments, in the ev ent the company requests acceleration of
the effective date of the pending registration statement, it should furnish a letter, at the
time of such request , acknowledging that:

• should the Commission or the staff, acti ng pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;

• the action of the Commission or the staff,  acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the company from its full
responsibility for the adequacy  and accuracy of the disclosure in the filing; and

J. Daniel Stinnett, Esq., Vice Presi dent, Secretary and General Counsel
Commerce Bancshares, Inc.
Page 3

• the company may not assert this action as  defense in any proceeding initiated by
the Commission or any person under the fe deral securities laws of the United
States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.

We will consider a written request for acceleration of the effective date of the
registration statement as a confirmation of th e fact that those reque sting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te to the proposed public offering of the
securities specified in the above registration statement.  We will act  on the request and,
pursuant to delegated authority, grant acce leration of the effective date.

            If you have any questions regard ing this letter, please f eel free to contact me at
202-551-3418.

Sincerely,

William Friar Senior Financial Analyst

cc:  Dennis P. Wilbert, Esq.  Blackwell Sanders Peper Martin LLP  4801 Main, Suite 1000  Kansas City, Missouri 64112  Fax number 816 983-8080   C. Bruce Crum, Esq.  McAfee& Taft  Tenth Floor, Two Leadership Square  211 North Robinson  Oklahoma City, Oklahoma 73102