SEC Comment Letter for COMMERCE BANCSHARES (CBSH) — Oct 9, 2012
COMMERCE BANCSHARES INC /MO/ (CBSH) (CIK 0000022356)
Date: Oct. 9, 2012 · CIK: 0000022356 · Accession: 0000000000-12-055556
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October 9, 2012 Via E -mail James L. Swarts Vice President and Secretary Commerce Bancshares, Inc. 1000 Walnut Street Kansas City, MO Re: Commerce Bancshares, Inc . Form 10-K for the Fiscal Year Ended December 31, 2011 Filed February 22, 2012 Form 10 -Q for the Quarterly Period Ended March 31, 2012 Filed May 4 , 2012 File No. 000 -02989 Dear Mr. Swarts : We have completed our review of your filings . We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing s and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the di sclosure in the filing s to be certain that the filing s include the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Hugh West Hugh West Accounting Branch Chief