SEC Comment Letter for COMMERCE BANCSHARES (CBSH) — Oct 21, 2011
COMMERCE BANCSHARES INC /MO/ (CBSH) (CIK 0000022356)
Date: Oct. 21, 2011 · CIK: 0000022356 · Accession: 0000000000-11-061782
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File numbers found in text: 000-02989
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October 21, 2011 Via E-mail James L. Swarts Vice President and Secretary Commerce Bancshares, Inc. 1000 Walnut Street Kansas City, MO 64106 Re: Commerce Bancshares, Inc. Form 10-K for Fiscal Year Ended December 31, 2010 Filed February 25, 2011 Form 10-Q for Fiscal Quarter Ended March 31, 2011 Filed May 9, 2011 File No. 000-02989 Dear Mr. Swarts: We have completed our review of your f ilings. We remind you that our comments or changes to disclosure in res ponse to our comments do not fore close the Commission from taking any action with respect to the company or the filings and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclosure in the fi lings to be certain that the filings includes the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Michael Seaman for Suzanne Hayes Assistant Director