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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

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
October 9, 2012
Author
/s/ Hugh West
Form
UPLOAD
Company
COMMERCE BANCSHARES INC /MO/ (CBSH) (CIK 0000022356)

Letter

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

Show Raw Text
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